Environmental Impact Statement 

for an Early Site Permit (ESP) at the 

North Anna ESP Site

Final Report

Appendices E & F

U.S. Nuclear Regulatory Commission

Office of New Reactors

Washington, D.C. 20555-0001

NUREG-1811, Vol. 2
 NUREG-1811, Vol. 2

Environmental Impact 

Statement for an

Early Site Permit (ESP) at

the North Anna ESP Site

Final Report

Appendices E & F

Manuscript Completed: November 2006

Date Published: December 2006

Division of Site and Environmental Reviews

Office of New Reactors

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001
December 2006 iii NUREG-1811, Volume II

Abstract

This environmental impact statement (EIS) has been prepared in response to an application |

submitted to the U.S. Nuclear Regulatory Commission (NRC) by Dominion Nuclear North Anna,

LLC (Dominion), for an early site permit (ESP). The proposed action requested in Dominion’s

application is for the NRC to (1) approve a site within the existing North Anna Power Station

(NAPS) boundaries as suitable for the construction and operation of one or more new nuclear

power generating facilities and (2) issue an ESP for the proposed site located at NAPS. The

proposed action does not include any decision or approval to construct or operate one or more

units; these are matters that would be considered only upon the filing of applications for a

construction permit and an operating license, or an application for a combined license.

In its application, Dominion proposed a plan for redressing the environmental effects of certain

site preparation and preliminary construction activities; that is, those activities allowed by

Title 10 of the Code of Federal Regulations (CFR) 50.10(e)(1), performed by an ESP holder

under 10 CFR 52.25. In accordance with the site redress plan, the site would be redressed if

the NRC issues the requested ESP (containing the site redress plan), the ESP holder performs

these site preparation and preliminary construction activities, the ESP is not referenced in an

application for a construction permit or combined license, and no alternative use is found for the |

site.

This EIS includes the NRC staff’s analysis that considers and weighs the environmental impacts

of constructing and operating two nuclear units at the North Anna ESP site or at alternative

sites, mitigation measures available for reducing or avoiding adverse impacts, and public

comments on both the staff’s Draft EIS and the Supplement to the Draft EIS (SDEIS). It also |

includes the staff’s recommendation to the Commission regarding the proposed action.

As part of the NRC review of the application, the NRC solicited comments from the public on the

Draft EIS, which was issued in December 2004, and the SDEIS, which was issued in July 2006

in response to changes proposed by Dominion in Revision 6 of its Environmental Report. 

These changes involved adopting a different cooling approach for the proposed new Unit 3 and

increasing the maximum power output for both of the proposed new units (i.e., Units 3 and 4). 

Volume II of this document sets forth all public comments received concerning the Draft EIS and

the SDEIS and the NRC staff’s responses to these comments, organized by subject matter. 

The comment letters on the Draft EIS are in the NRC’s document management system

(ADAMS) under accession number ML0514720560. Comment letters on the SDEIS are under |

accession number ML063060459. ADAMS can be accessed through the NRC’s website at |

www.nrc.gov. Where appropriate, changes were made to the Draft EIS and SDEIS and are

identified by change bars in the margins of this Final EIS.

The staff’s recommendation to the Commission related to its environmental review of the

proposed action is that the ESP should be issued. This recommendation is based on (1) the

Environmental Report (ER) submitted by Dominion; (2) consultation with Federal, State, Tribal,

and local agencies; (3) the staff’s independent review; (4) the staff’s consideration of public
NUREG-1811, Volume II iv December 2006

comments on both the Draft EIS and the SDEIS; and (5) the assessments summarized in this

Final EIS, including the potential mitigation measures identified in the ER and in the EIS. In

addition, in making its recommendation, the staff has concluded that the alternative sites

| considered are not obviously superior to the proposed site. Finally, the staff concludes that the

site preparation and preliminary construction activities enumerated in 10 CFR 50.10(e)(1) would

not result in any significant adverse environmental impact that cannot be redressed.
December 2006 v NUREG-1811, Volume II

Contents

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

Abbreviations/Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

1.0 Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

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

1.2 Public Comments Concerning the Draft EIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

1.3 Disposition of Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4

1.4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-6

2.0 Major Issues and Responses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.1 NRC Regulatory Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

2.2 NRC’s Safety Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3

2.3 Alternative Energy Sources, Cost of Power, Need for Power . . . . . . . . . . . . . . . . 2-4

2.4 Issues Associated with Lake Anna . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5

2.5 Human Health and Radiation Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-6

2.6 Socioeconomic Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7

2.7 Fuel Cycle Impacts Including Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-8

2.8 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-9

3.0 Comments Within Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

3.1 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5

3.2 Meteorology and Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

3.2.1 Meteorology Data and Local Climatology . . . . . . . . . . . . . . . . . . . . . . . . . 3-8

3.2.2 Impact of Waste Heat . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11

3.2.3 Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-13

3.2.4 Severe Weather . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-16

3.2.5 Global Warming and Greenhouse Gas Emissions . . . . . . . . . . . . . . . . . 3-16

3.3 Water Use and Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

3.3.1 Groundwater Use and Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-19

3.3.2 Surface Water Use and Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-20
NUREG-1811, Volume II vi December 2006

3.3.2.1 Water Supply and Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-23

3.3.2.2 Water Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-34

3.3.2.3 Water Temperature . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-40

3.3.2.4 Waste Heat Treatment Facility . . . . . . . . . . . . . . . . . . . . . . . . . 3-52

3.3.2.5 Water Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-55

3.3.2.6 Drought-Related Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-64

3.3.2.7 Flow and Water Budget . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-67

3.3.2.8 Heat Dissipation System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-83

3.3.2.9 Downstream Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-97

3.3.2.10 Applicant’s Comments and Corrections . . . . . . . . . . . . . . . . . 3-101

3.3.2.11 Other Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-102

3.3.2.12 Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-105

3.4 Ecology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-112

3.4.1 Terrestrial Ecology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-112

3.4.2 Aquatic Ecology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-117

3.4.2.1 Construction Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-117

3.4.2.2 Operational Impacts–General . . . . . . . . . . . . . . . . . . . . . . . . 3-119

3.4.2.3 Entrainment and Impingement Impacts . . . . . . . . . . . . . . . . . 3-124

3.4.2.4 Impacts on Fisheries–General . . . . . . . . . . . . . . . . . . . . . . . . 3-131

3.4.2.5 Impacts on Striped Bass . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-136

3.4.2.6 Downstream Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-144

3.4.3 Threatened and Endangered Species . . . . . . . . . . . . . . . . . . . . . . . . . 3-148

3.4.4 Wetlands . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-149

3.4.5 Other Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-152

3.5 Socioeconomics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-153

3.5.1 Region of Socioeconomic Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . 3-153

3.5.2 Economic and Taxes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-156

3.5.3 Population . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-162

3.5.4 Housing and Public Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-165

3.5.5 Property Values Related to Water Levels . . . . . . . . . . . . . . . . . . . . . . . 3-172

3.5.6 Recreational Issues Related to Water Levels . . . . . . . . . . . . . . . . . . . . 3-175

3.5.7 Roads and Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-179

3.5.8 Site Aesthetics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-186

3.5.9 Other Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-188
December 2006 vii NUREG-1811, Volume II

3.6 Historic and Cultural Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-191

3.7 Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-193

3.8 Site Redress Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-196

3.9 Human Health (Nonradiological Impacts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-198

3.10 Human Health (Radiological Impacts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-203

3.10.1 Comments Related to Regulatory Limits and 

Occupational Exposure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-203

3.10.2 Cancer and Health Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-206

3.10.3 Opinions and Statements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-216

3.10.4 Supportive of Nuclear Power as It Relates to Human Health . . . . . . . . 3-217

3.10.5 Plant Emissions and Environmental Dispersion . . . . . . . . . . . . . . . . . . 3-218

3.10.6 Other Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-223

3.11 Uranium Fuel Cycle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-224

3.11.1 Permanent Waste Storage and the Proposed 

Yucca Mountain Repository . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-224

3.11.2 Need for Reprocessing Spent Fuel . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-234

3.11.3 Expiration of Low-Level Waste Pact with Barnwell . . . . . . . . . . . . . . . . 3-236

3.11.4 Opposition to Generation of Additional Waste . . . . . . . . . . . . . . . . . . . 3-237

3.11.5 Comments Favorable to New Units . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-239

3.11.6 Other Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-240

3.12 Transportation of Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-246

3.13 Decommissioning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-250

3.14 Postulated Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-251

3.14.1 General Opposition Based on Potential Accident Risks . . . . . . . . . . . . 3-251

3.14.2 Design-Basis Accident Calculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-253

3.14.3 Severe Accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-254

3.15 Mitigation Measures and Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-259

3.16 Cumulative Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-264

3.17 Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-270

3.17.1 No-Action Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-270

3.17.2 System Design Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-271

3.17.3 Alternatives Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-272

3.17.3.1 General Alternative Sites Comments . . . . . . . . . . . . . . . . . . . 3-272

3.17.3.2 Brownfield Alternative Site . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-273
NUREG-1811, Volume II viii December 2006

3.17.3.3 Surry Plant Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-274

3.17.3.4 Savannah River Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-276

3.18 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-284

4.0 ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP . 4-1

4.1 ESP Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2

4.1.1 Plant Parameter Envelope (PPE) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20

4.1.2 Public Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-25

4.2 NEPA Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-36

4.3 Editorial Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-42

4.4 Comments Supporting or Opposing the ESP . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-45

4.4.1 Support for the ESP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-46

4.4.2 Opposition to the ESP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-57

4.5 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-68

5.0 Comments Outside the Scope of the EIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

5.1 Alternative Energy Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2

5.2 Cost and Need for Power . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-16

5.3 Emergency Preparedness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-25

5.4 Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-30

5.5 Security and Terrorism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-36

5.6 NRC Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-46

5.7 Comments in Support or Opposed to Nuclear Power . . . . . . . . . . . . . . . . . . . . . 5-48

5.7.1 Support for Nuclear Power . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-49

5.7.2 Opposition to Nuclear Power . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-59

5.8 Miscellaneous Out of Scope Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-70

5.9 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-73

6.0 Commenter Reference Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
December 2006 ix NUREG-1811, Volume II

Abbreviations/Acronyms

ABWR advanced boiling water reactor

ac acre(s)

ACE U.S. Army Corps of Engineers

ACR-700 Advanced CANDU Reactor

ADAMS Agencywide Documents Access and Management System |

AEC U.S. Atomic Energy Commission

ALARA as low as reasonably achievable

ALWR advanced light-water reactor

ATWS anticipated transient without scram

BEA Bureau of Economic Analysis

BMP best management practices |

Bq becquerel(s)

Btu British thermal unit(s)

BWR boiling water reactor

C Celsius

CEDE committed effective dose equivalent

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

cfs cubic feet per second

Ci curie(s)

cm centimeter(s)

COL combined construction and operating license, combined license |

CP construction permit

CWA Clean Water Act of 1977 (also known as the Federal Water Pollution Control Act)

CWIS cooling water intake system

CZMA Coastal Zone Management Act

d day

DBA design-basis accident

dBA decibels |

DEIS draft environmental impact statement |

DGIF Department of Game and Inland Fisheries |

DOE U.S. Department of Energy

EAB exclusion area boundary

EC energy conservation mode

EIS environmental impact statement
NUREG-1811, Volume II x December 2006

EPA U.S. Environmental Protection Agency

ER environmental report

ESBWR economic simplified boiling water reactor

ESE east-southeast

ESP early site permit

ESRP Environmental Standard Review Plan

F Fahrenheit

| FR Federal Register

ft foot, feet

FWPCA Federal Water Pollution Control Act (also known as the Clean Water Act of 1977)

FWS U.S. Fish and Wildlife Service

gal gallon(s)

GEIS generic environmental impact statement

gpd gallons per day

gpm gallons per minute

GT-MHR gas turbine-modular helium reactor

ha hectare(s)

HLW high-level waste

HPS Health Physics Society

hr hour(s)

IAEA International Atomic Energy Agency

| ICRP International Commission on Radiological Protection

IEEE Institute of Electrical and Electronics Engineers, Inc.

in. inch(es)

INEEL Idaho National Engineering and Environmental Laboratory

IRIS international reactor innovative and secure

ISFSI independent spent fuel storage installation

kg kilogram(s)

km kilometer(s)

kV kilovolt(s)

kWh kilowatt hour(s)

L liter(s)

LAAC Lake Anna Advisory Committee

lb pound(s)

LLW low-level waste

LOCA loss-of-coolant accident
December 2006 xi NUREG-1811, Volume II

LOS level-of-service

LPZ low population zone

LWR light-water reactor

m meter(s)

m/sec meter(s) per second

m3

/d cubic meter(s) per day

m3

/s cubic meter(s) per second

MBq million Becquerel(s)

mGy/yr milligray per year

MGD million gallons per day

mi mile(s)

MIT Massachusetts Institute of Technology

mL milliliter(s)

mph miles per hour

mrad millirad(s)

mrem millirem(s)

MSL mean sea level

mSv millisievert(s)

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

MTU metric ton(s)-uranium

MW megawatt(s)

MWC maximum energy conservation mode

MWd/MTU megawatt-days per metric ton of uranium

MW(e) megawatt(s)-electric

MW(t) megawatt(s)-thermal

MWh megawatt hour(s)

NA not applicable

NAPS North Anna Power Station

NCDC National Climatic Data Center

NCHS National Center for Health Statistics

NCRP National Council on Radiation Protection and Measurements

NEPA National Environmental Policy Act of 1969

NESC National Electric Safety Code

NHPA National Historic Preservation Act

NIEHS National Institute of Environmental Health Sciences

NNE north-northeast

NOAA National Oceanographic and Atmospheric Administration

NOx nitrogen oxide(s)

NPDES National Pollutant Discharge Elimination System

NRC U.S. Nuclear Regulatory Commission
NUREG-1811, Volume II xii December 2006

| NUG non-utility generator

ODCM Offsite Dose Calculation Manual

OL operating license

OSHA Occupational Safety and Health Administration

PBMR pebble bed modular reactor

PCB polychlorinated biphenyl

PPE plant parameter envelope

ppm parts per million

PWR pressurized water reactor

RCIC reactor core isolation cooling

REMP radiological environmental monitoring program 

rms root mean square

ROI region of interest

RRY reference reactor-year

RSA Rapidan Service Authority

Ryr-1 per reactor year

s second

SAIC Science Applications International Corporation

SCDHEC South Carolina Department of Health and Environmental Control

SCDNR South Carolina Department of Natural Resources

SDEIS Supplement to the Draft EIS

SER safety evaluation report

SHPO State Historic Preservation Officer

SODI Southern Ohio Diversification Initiative

SOx sulfur oxide(s)

SPCC Spill Prevention Control and Countermeasure

SR State Route

SRS Savannah River Site

SSAR Site Safety Analysis Report

SSE south-southeast

Sv sievert(s)

SWR Service Water Reservoir

SWU separative work units

TEDE total effective dose equivalent

TRU transuranic (waste)

TVA Tennessee Valley Authority
December 2006 xiii NUREG-1811, Volume II

UCO uranium oxycarbide

UFSAR Updated Final Safety Analysis Report

UHS ultimate heat sink

U.S. United States

USCB U.S. Census Bureau

USDA U.S. Department of Agriculture

USEC United States Enrichment Corporation, Inc.

USGS U.S. Geological Survey

VAC Virginia Administrative Code

VTAX Virginia Department of Taxation |

VDCR Virginia Department of Conservation and Recreation

VDEQ Virginia Department of Environmental Quality

VDGIF Virginia Department of Game and Inland Fisheries

VDOT Virginia Department of Transportation 

VDSS Virginia Department of Social Services

VEC Virginia Employment Commission

VEPCo Virginia Electric & Power Company (Virginia Power) |

VNHP Virginia Natural Heritage Program

VPDES Virginia Pollutant Discharge Elimination System

yd yard(s)

yr year(s)

WHTF Waste Heat Treatment Facility
Appendix E

Comments and Responses on 

the Draft Environmental Impact Statement

 and the Supplement to the Draft Environmental Impact Statement 
December 2006 1-1 NUREG-1811, Volume II

Appendix E – Public Comments and Responses

1.0 Overview

1.1 Background

This environmental impact statement (EIS) was prepared in response to an application

submitted to the U.S. Nuclear Regulatory Commission (NRC) by Dominion Nuclear North Anna,

LLC (Dominion), for an early site permit (ESP). An ESP is a Commission approval of a site or

sites for one or more nuclear power facilities and is a separate action from the filing of an

application for a construction permit (CP), an operating license (OL), or a combined construction

permit and operation license (combined license or COL) for such a facility. The proposed action

is the issuance, under the provisions of Title 10 of the Code of Federal Regulations (CFR) Part

52, of an ESP for the North Anna ESP site for nuclear power facilities with characteristics

that fall within a plant parameter envelope (PPE) and to authorize site preparation activities as

described in the site redress plan. The proposed action does not include any decision or

approval to construct or operate one or more units; these are matters that would be considered

only upon the filing of applications for a CP, an OL, or a COL. This Final EIS includes the NRC

staff’s analysis that considers and weighs the environmental impacts of constructing and

operating two nuclear units at the North Anna ESP site, or at alternative sites, and mitigation

measures available for reducing or avoiding adverse impacts. It also includes the staff’s

recommendation to the Commission regarding the proposed action.

This EIS was prepared in accordance with the provisions of the National Environmental Policy

Act of 1969 (NEPA), guidance from the Council on Environmental Quality, and the provisions of

10 CFR Parts 51 and 52. As outlined by NEPA, the NRC initiated the scoping process by

publishing in the Federal register a Notice of Intent to prepare an EIS and conduct scoping

(68 FR 65961). NRC invited Dominion, Federal, State, Tribal, and local government agencies;

local organizations; and individuals to participate in the scoping process by providing oral

comments at public meetings held on December 8, 2003, or by submitting written suggestions

and comments no later than January 9, 2004, or both. The public comments received during

the scoping process are provided in Appendix D of Volume I of this Final EIS. In addition, the

NRC environmental review team visited the North Anna site and its vicinity during

December 2003.

Subsequent to the site visit and the scoping meeting and in accordance with NEPA and

10 CFR Part 51, the staff determined and evaluated the potential environmental impacts of

constructing and operating two nuclear power plants at the North Anna ESP site and issued its

preliminary findings in a Draft EIS on December 2, 2004 (NRC 2004). The Draft EIS included

(1) the results of the NRC staff’s preliminary analyses, which considered and weighed the
Introduction

NUREG-1811, Volume II 1-2 December 2006

environmental effects of the proposed action (issuance of the ESP) and of constructing and

operating two nuclear units at the ESP site; (2) mitigation measures for reducing or avoiding

adverse effects; (3) the environmental impacts of alternatives; and (4) the staff’s preliminary

recommendation regarding the proposed action.

During the course of preparing the Draft EIS, the staff reviewed the Environmental Report

submitted by Dominion (Dominion 2006); consulted with Federal, State, Tribal and local

agencies; and followed the guidance set forth in the NRC review standard RS-002, Processing

Applications for Early Site Permits, to conduct an independent review of the issues

(NRC 2004a). The review standard draws from the previously published NUREG-0800,

Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants

(NRC 1987), and NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear

Power Plants (NRC 2000). In addition, the staff considered the public comments related to the

environmental review received during the scoping process.

1.2 Public Comments Concerning the Draft EIS and the

Supplement to the Draft EIS

On December 10, 2004, a Notice of Availability was published by the NRC in the Federal

Register (69 FR 71854) announcing the publication of the Draft Environmental Impact

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

(NRC 2004b). The Draft EIS was published by the NRC for comment by Federal, State, Tribal,

and local government agencies as well as interested members of the public. The NRC made

the Draft EIS available for public comment in accordance with 10 CFR 51.73. On December 17,

2004, the U.S. Environmental Protection Agency (EPA) issued a Notice of Filing of the Draft EIS

(69 FR 75535), initiating the comment period for the Draft EIS . 

Dominion proposed (1) changing its approach for cooling proposed Unit 3 from a once-through

cooling system, as described in previous versions of the ER, to a closed-cycle system and

(2) increasing the maximum power level per unit from 4300 megawatts-thermal (MW(T)) to

4500 MW(t) for the proposed Units 3 and 4 (hereafter referred to as Units 3 and 4). Under the

revised cooling system approach, Unit 3 would use a closed-cycle, combination wet and dry

cooling system. The NRC staff determined that the changes to the proposed action in Revision

6 of the application were substantial; therefore, the staff prepared a Supplement to its Draft EIS

(referred to as the SDEIS) pursuant to 10 CFR 51.72. The SDEIS was issued for public

comment on July 14, 2006 (71 FR 40096). The SDEIS (NRC 2006) evaluated changes to the

Unit 3 cooling system and the increase in power level proposed by Dominion after the Draft EIS

was published. The evaluation presented in the SDEIS replaced the evaluation of the impacts

associated with the originally proposed once-through cooling system for Unit 3 and modified the

analysis of impacts related to the power level increase. These revised evaluations, along with
Introduction

December 2006 1-3 NUREG-1811, Volume II

the public comments received on the analysis presented in the SDEIS, are incorporated into this

Final EIS together with comments received concerning the original Draft EIS and the staff’s

consideration of such comments. The comment period on the SDEIS was extended by 15 days

in response to requests from the public and the Commonwealth of Virginia (71 FR 46927).

As part of the process to solicit public comments on the Draft EIS and the SDEIS, the staff:

& placed copies of the Draft EIS and the SDEIS at the Louisa County Public Library

& made the Draft EIS and the SDEIS available in the NRC’s Public Document Room in

Rockville, Maryland

& placed copies of the Draft EIS and the SDEIS on the NRC website at:

www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1811/index.html

& provided copies of the Draft EIS and the SDEIS to any member of the public that

requested a copies

& sent copies of the SDEIS and the Draft EIS to certain Federal, State and local agencies

& published a notice of availability of the Draft EIS and the SDEIS in the Federal Register

(69 FR 71854), (71 FR 40096), respectively

& filed the Draft EIS and the SDEIS with EPA.

During the comment periods, the NRC held public meetings in Mineral, Virginia, on

February 17, 2005, and August 15, 2006. During the public meetings, the staff described the

preliminary results of the NRC environmental review, answered questions, and provided

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

and SDEIS. Approximately 300 people attended each meeting, and attendees provided oral

comments. A certified court reporter recorded oral comments and prepared written transcripts

of each meeting. In addition to comments received at the public meetings, the NRC received

thousands of letters and e-mail messages with comments. The comments contained in the

transcripts of the public meetings and in the letters and e-mails are addressed in this volume of

the EIS. The comment period closed on March 1, 2005, for the Draft EIS and on

September 12, 2006, for the SDEIS.

The NRC has published compendiums of the transcript and the written comments received

during the public comment periods in public records dated June 16, 2005, for the Draft EIS and

November 2, 2006, for the SDEIS. The comment letters, e-mail messages, and transcripts of

the public meeting are available from the Publicly Available Records component of NRC’s

Agencywide Documents Access and Management System (ADAMS) under accession numbers
Introduction

NUREG-1811, Volume II 1-4 December 2006

ML051720560 and ML063060459. ADAMS is accessible at http://www.nrc.gov/readingrm/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 each written comment and the transcripts of the public meetings.

1.3 Disposition of Comments

This volume contains the comments extracted from comment letters and e-mail messages

provided to the staff during both comment periods, as well as the comments from the

transcripts.

Each comment letter, e-mail message, or transcript was assigned a commenter number, so the

comments could be traced to the original transcript or communication containing their

comments. Comments received on the Draft EIS are identified as DW for draft written comment

and DT for draft transcript comment followed by the number of the comment. Comments

received on the SDEIS are identified as SE for supplement e-mailed comments, SW for

supplement written comments, and ST for supplemental transcript comments followed by the

comment number.

Each comment within a written comment letter, email message, or transcript was given a

number, which follows the commenter number. For example, a person may have provided 10

specific comments during the Draft EIS public meeting. The commenter would be assigned a

commenter number, such as DT-35. The first comment was identified as comment DT-35 1,

and each subsequent comment was numbered sequentially (e.g., DT-35 1 through DT-35 10). 

Tables E-6.1 and E-6.2 are indexes of commenter names and comment numbers sorted

alphabetically and numerically with the associated accession number from the NRC’s ADAMS

record keeping system. In the alphabetically sorted table, commenters who represented a

stated organization are listed both by the submission individual’s name and the organization.

Four e-mail messages or postcard comments on the Draft EIS were sent to the NRC by

hundreds of individuals. These written comments are referred to as mass mailings and are

identified in each comment and in the commenter list as in as commenter DMM1 (comments

1 through 12), D MM2 (comments 1 through 4), DMM3 (comments 1 through 4), and DMM4

(comments 1 through 17). Comments from these four letters were considered and are

addressed once. In addition to the mass mailings, some of the commenters used one or more

of the mass mailing comments in personalized letters and e-mail messages. If the comment

letters received were duplicates sent by the same person but on different days, they were
Introduction

December 2006 1-5 NUREG-1811, Volume II

labeled as duplicates, and were addressed as one commenter letter. If the letters were

different, each letter was addressed individually.

After the comment period, the staff considered and dispositioned all comments received. To

identify each individual comment, the NRC staff reviewed the transcripts of the public meetings

and each letter and e-mail message received related to the Draft EIS and the SDEIS. 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.

The following chapters present the comments and the NRC responses to them grouped by

similar issues:

& Chapter 2. Major Issues and Responses

& Chapter 3. Technical Comments Within the Scope of this EIS

& Chapter 4. ESP Process, NEPA Compliance, Comments Supporting or Opposing

the ESP

& Chapter 5. Comments Outside the Scope of this EIS

& Chapter 6. Commenter Reference Tables.

Within the chapters the staff separated the comments received on the Draft EIS and the SDEIS

unless the same comment was received on both the Draft EIS and SDEIS, in which case the

comment was addressed once with both comment numbers listed after the comment.

When the comments resulted in a change in the text of the Draft EIS or SDEIS, the

corresponding response refers the reader to the appropriate section of the report where the

change was made. Tables E-6.1 through E-6.5 provide lists of commenters identified by name,

affiliation (if given), commenter number, and the source (public meeting or written comments)

provided subsequent to the meeting) of the comment. Tables E-6.1 through E-6.3 include

commenters responding to the Draft EIS. Tables E-6.4 and E-6.5 include commenters

responding to the SDEIS.

Comments are summarized in Chapter 2 for major issues. 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
Introduction

NUREG-1811, Volume II 1-6 December 2006

policies, comments on the NRC regulatory process in general, and comments on NRC

regulations. These comments are provided in Chapters 4 and 5. If appropriate, these

comments were forwarded to the cognizant organization within the NRC for consideration.

Many comments specifically addressed the scope of the environmental review, analyses, and

issues contained in the Draft EIS, including comments about potential impacts and proposed

mitigation. Responses to these comments are provided in Chapters 3.

1.4 References

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, “Early Site Permits;

Standard Design Certifications; and Combined Licenses for Nuclear Power Plants.”

68 FR 65961. “Dominion Nuclear North Anna, LLC, North Anna Early Site Permit; Notice of

Intent To Prepare an Environmental Impact Statement and Conduct Scoping Process.” Vol. 68,

No. 226. November 24, 2003.

69 FR 71854. “Dominion Nuclear North Anna, LLC; Notice of Availability of the Draft

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

Associated Public Meeting.” Vol. 68, No. 237. December 10, 2004.

69 FR 75535. “Environmental Protection Agency Environmental Impact Statements; Notice of

Availability.” Vol. 69, No. 242. December 17, 2004.

71 FR 40096. “Environmental Protection Agency, Environmental Impact Statements; Notice of

Availability.” Vol. 71, No. 135. July 14, 2006.

71 FR 46927. “Dominion Nuclear North Anna, LLC; Notice of the extension of the Public

Comment Period on the Supplement to the Draft Environmental Impact Statement for the Early

Site Permit (ESP) at the North Anna ESP Site.” Vol. 71, No. 157. August 15, 2006.

Dominion Nuclear North Anna, LLC (Dominion). 2006. North Anna Early Site Permit

Application – Part 3 – Environmental Report. Revision 9, Glen Allen, Virginia.

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

December 2006 1-7 NUREG-1811, Volume II

U.S. Nuclear Regulatory Commission (NRC). 1987. Standard Review Plan for the Review of

Safety Analysis Reports for Nuclear Power Plants. NUREG-0800, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan:

Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555,

Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004a. Processing Applications for Early Site

Permits. RS-002, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004b. Draft Environmental Impact Statement for

an Early Site Permit (ESP) for the North Anna ESP Site. NUREG-1811, Washington, D.C.

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

an Early Site Permit (ESP) for the North Anna ESP Site, Supplement 1. NUREG-1811,

Washington D.C.
December 2006 2-1 NUREG-1811, Volume II

2.0 Major Issues and Responses

Major issues raised through the comment process in response to (1) the North Anna early site

permit (ESP) Draft Environmental Impact Statement (Draft EIS) (NRC 2004) and (2) the

Supplement to the Draft EIS (SDEIS) (NRC 2006) are provided in this chapter along with a

summary of the U.S. Nuclear Regulatory Commission (NRC) responses to such comments. 

The topics addressed herein are:

& NRC’s regulatory process

& NRC’s safety review

& alternative energy sources, cost of power, need for power

& issues associated with Lake Anna

& human health and radiation impacts

& socioeconomic impacts

& fuel cycle impacts.

Detailed responses to the topics that are within the scope of this environmental review are

summarized in Chapters 3 and 4. Comments that are not within the scope of the EIS are listed

in Chapter 5 along with a general response.

2.1 NRC Regulatory Process

A number of comments addressed the NRC review process for an ESP and the extent of the

NRC’s environmental review at the construction permit (CP), operating license (OL) or

combined license (COL) stage for an application that references an ESP. Several commenters,

asserting that little or no design information exists, questioned the validity of the plant parameter

envelope (PPE) for bounding the design characteristics of a reactor that might ultimately be built

at the proposed ESP site. Other commenters questioned how the NRC could provide finality at

the COL stage for environmental issues resolved at the ESP stage given that changes could

occur subsequent to an ESP approval. Finally, one commenter stated that there was no

requirement for the NRC to produce an EIS at the COL stage. While the comments and the

staff’s responses are generally couched in terms of the relationship between the ESP and COL

environmental reviews, the responses apply equally to the review of a CP or OL application that

references an ESP.

The NRC regulations governing the application addressed in this EIS require that an applicant

for an ESP provide the NRC with an environmental report (ER) that meets the requirements of

10 CFR 51.45 and 51.50 (see 10 CFR 52.17). Title 10 of the Code of Federal Regulations

(CFR) Section 52.17 also requires that the applicant’s Environmental Report (ER) focus on the

environmental effects of construction and operation of a reactor or reactors that might be built at

the proposed site. Additionally, 10 CFR 52.18 requires that the staff prepare an EIS for the
Affected Environment

NUREG-1811, Volume II 2-2 December 2006

application that focuses on the same matters. Both the ER and the EIS must include an

evaluation of alternative sites to determine whether there is any obviously superior alternative to

the site proposed. Certain issues, however, such as the benefits of the action and alternative

energy sources, may be deferred to a later licensing stage. 

For an ESP, the NRC prepares an EIS that resolves numerous issues based on existing

environmental site characteristics, as well as bounding values of power plant design parameters

postulated in the application. These issues are subject to issue preclusion in a proceeding on

an application referencing the ESP (i.e., such an issue would not be subject to litigation in the

later licensing proceeding). NRC regulations allow an ESP applicant to defer an issue (such as

the benefits assessment as Dominion Nuclear North Anna LLC [Dominion] has elected here) but

also require that a COL applicant referencing such an ESP address the issue in its application. 

An application referencing an ESP must also demonstrate that the design of the facility falls

within the parameters specified in the ESP. In addition, the application should indicate whether

the site is in compliance with the terms of the ESP. Such an application should also identify

whether there is new and significant information on any issue resolved in the ESP proceeding

and address any unresolved issues.

In its application for an ESP, Dominion provided environmental site characteristics, but did not

provide a detailed design of a reactor or reactors and the associated facilities that might be built

at the North Anna ESP site. Rather, in lieu of detailed design information, Dominion referenced

a PPE as a surrogate for a specific plant design. That is, it provided bounding values of design

parameters for a plant that might be built at the site and assessed the environmental impacts

associated with those bounding values.

The PPE consists of bounding values for specified parameters rather than the characteristics of

any specific reactor design. If the design selected in a subsequent application referencing any

ESP that might be issued in this proceeding is not bounded by the environmental PPE values

specified in such an ESP, then the NRC staff will determine whether such new information is

significant. In its review of any future application referencing such an ESP, if new and

significant information is identified with respect to an issue resolved in the ESP proceeding, the

staff will address that information in the EIS on that application.

Regarding the proposition that an EIS would not be required for an application referencing an

ESP, issuance of a CP and a COL are major Federal actions; therefore, the provisions of

10 CFR 51.20 would apply, and preparation of an EIS for such a proposed action would be

required.
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December 2006 2-3 NUREG-1811, Volume II

2.2 NRC’s Safety Review

Many comments received in response to the North Anna Draft EIS addressed the NRC safety

evaluation. Commenters primarily questioned why safety issues, including emergency

preparedness, are outside the scope of the environmental review. A number of commenters

specifically questioned why security and terrorism are outside the scope of the environmental

review. In addition, commenters expressed concern regarding terrorist attacks at nuclear power

plants in general, and at any additional units at the North Anna ESP site in particular.

As specified in NRC regulations, the staff conducts a two-pronged review of an ESP application

(see 10 CFR 52.17, 52.18, 100.20, 100.21, and 100.23). In its review, the staff analyzes the

environmental impacts of the applicant’s proposal and, in tandem, reviews the applicant’s

compliance with NRC site safety requirements. Because the NRC conducts both reviews in

parallel, some members of the public, in response to the staff’s request for comments on the 

Draft EIS, provided comments on safety matters. Such comments, as explained below, are

beyond the purview of the NRC’s environmental review, and are not addressed in this EIS.

The purpose of an EIS is to disclose the reasonably foreseeable environmental impacts arising

from an applicant’s proposed action. Further, pursuant to the Commission’s regulations, an

ESP EIS focuses on the impacts of construction and operation of a new nuclear unit or units

that might be built on a proposed ESP site. This EIS focuses on the impacts of constructing

and operating such a facility on the proposed North Anna ESP site. Consequently,

consideration of comments on the safety of the site or any facility that might be built on it,

including comments on emergency planning, are beyond the scope of the matters addressed

herein. The staff, however, has forwarded comments that address safety issues to the

appropriate NRC staff members for their consideration (ML0517301530).

Security is a safety issue evaluated in the staff’s safety evaluation report (SER, NUREG-1835

and Supplement 1). With respect to security, the staff evaluated the application to determine

whether the characteristics of the proposed site are such that adequate security plans and

measures can be developed (see 10 CFR 100.21(f)). In its SER, the staff found that the ESP

site characteristics would allow an applicant for a COL or a CP to develop adequate security

plans and measures for a reactor that such an applicant might construct and operate on the

ESP site. Should an application be submitted referencing any ESP that might be issued for the

North Anna ESP site, the staff would review the security measures proposed in the application

to determine whether those measures satisfy the regulations in effect at that time.

With respect to environmental impacts resulting from terrorism, the Commission has determined

that the National Environmental Policy Act of 1969 (NEPA) does not require the NRC to

consider such impacts in rendering licensing decisions (NRC 2002). See Private Fuel Storage,

L.L.C. (Independent Spent Fuel Storage Installation), CLI-02-25, 56 NRC 340 (2002). Since
Affected Environment

NUREG-1811, Volume II 2-4 December 2006

that decision, the Court of Appeals for the Ninth Circuit ruled that an evaluation of terrorism was

required in an environmental assessment for an independent spent fuel storage installation at a

reactor site. See San Luis Obispo Mothers for Peace v. NRC, 449 F.3d 1016 (9th Cir. 2006). In

its decision, the Court of Appeals specifically rejected the rationale for the Commission’s

decision that the impacts of terrorism need not be considered under NEPA. However, inasmuch

as the licensee in the Mothers for Peace case has filed a petition for a writ of certiorari with the

United States Supreme Court, the Ninth Circuit’s decision may yet be modified or reversed. 

Given the ongoing nature of these developments, the Commission has not altered its position

regarding evaluation of the environmental impacts of a terrorist attack. Finally, the Mothers for

Peace decision applies only in the Ninth Circuit. Accordingly, the NRC staff response to this

comment is still controlled by the Commission decisions ruling that the impacts of terrorism

need not be addressed in the context of NRC environmental reviews under NEPA. The

rationale for these decisions is set forth below.

First, the Commission does not currently have a method or theory with which to perform a

meaningful analysis of the environmental impacts of terrorism with respect to a particular facility. 

Second, in the absence of specific information indicating that a terrorist attack on a specific

facility is likely to occur, NEPA does not require consideration of postulated terrorist attacks. 

Third, the public aspect of the NEPA processes conflicts with the need to protect certain

sensitive information because (1) a review of terrorism under NEPA would involve examination

not only of how terrorists could cause maximum damage but also how they might best be

thwarted, and (2) confidentiality in this area protects against the risks that terrorism poses to

public health and safety. In light of the foregoing discussion, issues with regard to terrorism are

not appropriate topics for an EIS, and the staff has not addressed such issues in this EIS.

It is important to point out that the NRC and other Federal agencies have raised their vigilance,

and their licensees’ vigilance, with respect to security, and have implemented initiatives to

evaluate and respond to possible threats posed by terrorists. The NRC routinely assesses

threats and other information provided by other Federal agencies and sources. Ultimately,

however, while these are legitimate matters of concern, they will continue to be addressed

through the ongoing regulatory process as a current and generic regulatory issue that affects all

nuclear facilities.

2.3 Alternative Energy Sources, Cost of Power, Need

for Power

Several commenters questioned the deferral of the review of alternative energy sources, cost of

power, and the need for power until the COL stage.

An ESP does not approve the construction or operation of a nuclear power plant. Actions

authorizing such construction and operation, which could be either the issuance of a CP and
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December 2006 2-5 NUREG-1811, Volume II

OL, or a COL, require separate environmental reviews and preparation of separate EISs. The

benefits assessment can be prepared as part of the CP or COL application, and evaluated by

the NRC staff when such an application is submitted. Accordingly, 10 CFR 52.17(a)(2) affords

an ESP applicant the flexibility to defer consideration of the benefits of construction and

operation of a facility that might be built at the proposed ESP site (e.g., the need for power).

The benefits of construction and operation of a facility at the proposed ESP site would be

assessed if any ESP that might be issued were referenced in a COL or CP application. If such

an ESP is never referenced in another application, a facility for which that ESP resolved issues

would not be built, and the benefits assessment need not be performed. In this same context,

an ESP applicant need not include an assessment or discussion of alternative energy sources

in its environmental report. Rather, an applicant may choose to defer consideration of

alternative energy sources to the COL or CP application (68 FR 55905). Here,

Dominion chose not to assess alternative energy sources or the benefits of construction and

operation of a reactor or reactors at the North Anna ESP site, including the need for power. 

Accordingly, this EIS does not consider such issues.

2.4 Issues Associated with Lake Anna

The Draft EIS and the SDEIS comment process generated comments concerning water use by

Dominion’s potential construction and operation of new nuclear units on Lake Anna. A number

of commenters expressed concerns about the increase in frequency, duration, and magnitude

of the decline in lake level; the decrease in stream flows downstream of the dam; the increase

in water temperature; and the decline in aquatic habitat quality in the lake and downstream. In

response to concerns in these areas received from the Commonwealth of Virginia and local

citizens, Dominion changed its proposal for the Unit 3 cooling system from a once-through

system to a closed-cycle, combination wet and dry cooling system. The new cooling system

essentially eliminates the thermal impacts to the lake; however, consumptive water use and

lake level remain affected by the new cooling system. The staff performed an independent

assessment of the new cooling system impacts to Lake Anna and concluded the impacts to

Lake Anna would be MODERATE in drought conditions and otherwise SMALL. (Significance

levels are defined in the Chapter 1 [Volume I] of this EIS.)

Several commenters incorrectly implied that NRC has authority over setting water use and

water quality standards. The authority for setting water quality and water use policy for Lake

Anna resides with the Virginia Department of Environmental Quality. Issuance of an ESP in no

way diminishes or interferes with the Commonwealth of Virginia’s authority to set water quality

and water policy for Lake Anna, nor does it alter the responsibility of Dominion to obtain all the

required permits and certifications from the Commonwealth of Virginia.
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NUREG-1811, Volume II 2-6 December 2006

Regarding the striped bass fishery, construction of the dam in 1972 created an artificial lake that

provides habitat for a fishery maintained by continuous artificial stocking. The fishery stocking

program is managed by the Virginia Department of Game and Inland Fisheries (VDGIF) and is

expected to be an ongoing program. The incremental changes resulting from the addition of a

closed-cycle, combination wet and dry cooling system essentially eliminated the thermal

impacts to Lake Anna and associated impacts on striped bass habitat in the lake. Habitat

changes naturally occur in the North Anna River during the year. They are most noticeable

during high-flow conditions that occur in the winter and early spring, and during low-flow

conditions that occur in the summer and early fall. Habitat changes can be exacerbated during

drought years, or years with abnormally high precipitation.

Although there is no evidence that striped bass live or spawn in the North Anna River below the

dam, this species does utilize areas of the Pamunkey River for spawning, but generally not

during the times when low-flow conditions would occur. VDGIF has expressed concern,

however, that other species (e.g., herring, shad, resident sucker and minnow) may be

influenced by low-flow conditions associated with the operation of Unit 3, and that impacts to

habitat in or near the North Anna River would occur because of the operation of Unit 3. While it

is unlikely that the impacts of the operation of Unit 3 would be sufficient to destabilize the

existing fish populations in Lake Anna or the North Anna River, it is possible that the additional

periods of reduced flow over the North Anna Dam could influence some resident fish species

and also result in additional impacts to downstream habitat, especially during drought events. 

The staff recognizes the importance of these potential impacts and has revised the Final EIS to

address the concerns of VDGIF and other commenters. Detailed responses to these comments

are provided in Chapter 3.

2.5 Human Health and Radiation Impacts

Some of the comments related to the assertion that there are higher incidences of cancers

around nuclear power plants. Some commenters stated that there is a 73 percent increase in

deaths from breast cancer since the North Anna Unit 1 and 2 reactors began operating while

others refuted the basis for the statistics suggesting higher regional incidences of cancer. Other

concerns were related to infant mortality, cancer, and heart disease. A number of comments

stated the regulatory limits were not protective of workers or the environment. Some of the

comments related to the release of radioactive material to the environment, both for the

proposed units and the currently operating units. There were some questions regarding how

the analysis for doses to construction workers was performed. There was also a concern that

the staff did not take into account that infants may consume food grown or raised near the

power plant.

The NRC is committed to protecting the health and safety of both the workers and the public

that live around nuclear power plants. The staff continues to review new data related to health
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December 2006 2-7 NUREG-1811, Volume II

effects from radiation to both humans and the environment and has reviewed the literature

discussing the possible cause and effect relationship between reactor operations and the

incidence of cancer. The staff notes that the position of the National Cancer Institute (NCI) is

that there is “...no evidence that an excess occurrence of cancer has resulted from living near

nuclear facilities.” Regulatory standards for doses to workers and the public are developed

using extensive research by national and international organizations and are protective of health

and safety. In addition to meeting regulatory limits, the operators of the nuclear reactors must

also demonstrate that they maintain doses to workers “As Low As Reasonably Achievable,” or

ALARA. The radiological waste systems, when designed, must also meet the ALARA

requirements of Appendix I of 10 CFR Part 50. Small amounts of radioactive material from

nuclear reactors may be released into the environment as a result of plant operations. The

operators of the reactors must monitor these releases and report them annually to the NRC if

they are within regulatory limits, and sooner in the event of an unplanned release or if a release

exceeds regulatory limits. The data from these releases are used to estimate doses to the

public and the environment, and NRC reviews the information to assure that the reactor

releases are within release limits. More detailed responses to the comments are provided in

Chapter 3. Regarding the questions related to the staff’s analysis in the EIS, revisions have

been made where necessary to improve clarity.

2.6 Socioeconomic Impacts

Some of the commenters expressed confusion over, or disagreement with the region of study

used for the socioeconomic analysis. Most asserted that a wider geographic area extending

beyond Orange, Louisa, Spotsylvania, and Henrico Counties and the City of Richmond should

have been assessed. There were several comments regarding the positive impact of the

existing North Anna facilities on the economy of Orange County, but several questions were

asked about the potential impacts of additional nuclear facilities at the North Anna ESP site on

the amount and distribution of local government tax receipts (especially in light of electricity

sector deregulation in Virginia). There were several comments concerning the current rapid

rate of population growth in the region of the ESP site, and concerns were expressed that the

number of personnel employed to build and operate the plant would place a significant

additional burden on roads, housing and other infrastructure, and public services in the region. 

Several commenters noted that road upgrades mentioned in the EIS were unlikely to occur

because of State-level budget constraints. There were several comments expressing concern

about the expected reductions in lake levels and increases in temperatures in Lake Anna, and

potential negative effects on recreation, recreation-related businesses, and property values

surrounding Lake Anna. As noted in Section 2.4, Dominion has changed its proposal for the

cooling system for Unit 3 to a closed-cycle system, essentially eliminating the thermal impacts

to the lake.
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NUREG-1811, Volume II 2-8 December 2006

The staff developed its socioeconomic region of analysis beginning with an area approximately

50 miles in radius, which conforms to NRC environmental review procedures and other

regulatory guidance. The actual focus of the socioeconomic analysis was on those counties in

which approximately 79 percent of the operations workforce for North Anna Power Station

(NAPS) Units 1 and 2 live, and especially Louisa and Orange Counties, which are expected to

see the majority of the measurable socioeconomic impacts. 

Regarding population growth, Dominion had estimated that about 80 percent of the construction

workforce would come from the labor force already residing in the region. The staff expects 

that this factor, combined with the fact that any population increases resulting from construction

and operation of the two new units at NAPS are expected to be distributed across the region

(especially the urban area of Richmond and Henrico County), would mean that the

community-service impacts caused by construction of new nuclear units at the North Anna site

would be small to moderate. Water and sewer infrastructure and educational facilities in

Orange and Louisa Counties would have to be expanded and upgraded even without new

facilities at the North Anna ESP site, so they could be scaled to accommodate the additional

growth. With respect to roads, the staff acknowledges that the Fredericksburg to

Washington, D.C., corridor is congested and that the local roads in the vicinity of Lake Anna can

be crowded during peak recreation periods. However, because most of the expected workforce

already lives in the region and is already counted in current congestion, because there are

multiple commuting routes to the North Anna site, and because the additional commuters would

be spread over multiple shifts, the staff determined that traffic impacts would be in the range of

SMALL to MODERATE.

The staff acknowledges that Lake Anna water levels can be lower, but determined that with the

closed-cycle, combination wet-dry cooling system for Unit 3 and dry cooling for Unit 4, lake

temperatures would not be noticeably higher. In addition lower lake levels mainly would be

experienced during periods of drought when low lake levels would result in exposed mud flats

and some unusable facilities anyway. In view of the already high and increasing property

values on the Waste Heat Treatment Facility and the expected influx of population and activity

to the region, the staff determined that changes in Lake Anna are unlikely to result in lower

property values. More detailed responses to these comments are provided in Chapter 3.

2.7 Fuel Cycle Impacts Including Transportation

Many comments addressed concerns about spent fuel in the spent fuel pool, storage of spent

fuel at the site and at a fuel repository, and transportation of the spent fuel to a final repository. 

Many comments were made regarding the long-term hazards from high-level and low-level

radioactive waste and management of the wastes. In some cases, commenters promoted the

idea of spent fuel reprocessing. Most comments stated that until there was resolution to the

spent fuel storage issue, no additional nuclear reactors should be built. Several commenters
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December 2006 2-9 NUREG-1811, Volume II

also expressed concern regarding the expiration in 2008 of the Southeast Low-Level Waste

Compact with Barnwell, South Carolina.

In the Waste Confidence Rule (10 CFR 51.23), the Commission expressed its confidence that

there will be a licensed high-level waste repository. If the proposed Yucca Mountain site is

found to be unsuitable as a site for a permanent repository, other sites will be considered. Until

a permanent high-level waste repository is operational, spent nuclear fuel will be safely stored

either onsite or at an interim storage facility. Federal energy policy discusses the possibility of

reprocessing spent fuel; however, only the no-recycle option is analyzed in this EIS. The

environmental impacts for transporting spent fuel were analyzed for both normal transportation

and accident conditions. Based on the results presented in the EIS, the staff concludes that the

impacts of transporting unirradiated fuel to and spent fuel and radioactive waste from the

Dominion ESP site are likely to be small for advanced light water reactor (LWR) designs and are

unresolved for gas cooled reactor designs. The analysis assumes that shipping containers for

advanced reactor fuel and wastes will provide protection equivalent to current LWR fuel cask

designs that historically have been used in the United States to safely transport radioactive

material, including unirradiated fuel, spent fuel, and wastes. Regarding the expiration of the

Southeast Low-Level Waste Compact with Barnwell in 2008, other waste generators in the

compact (e.g., hospitals that generate radioactive waste) rely on the Barnwell disposal facility,

and an alternate waste disposal location would need to be established prior to 2008. 

2.8 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, “Early Site Permits;

Standard Design Certifications; and Combined Licenses for Nuclear Power Plants.”

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

Criteria.”

68 FR 55905. “Nuclear Energy Institute; Denial of Petition for Rulemaking.” Federal Register.

Vol 68, No. 188, September 29, 2003.
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NUREG-1811, Volume II 2-10 December 2006

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

U.S. Nuclear Regulatory Commission (NRC). 2002. Private Fuel Storage, LLC (Independent

Spent Fuel Installation, CLI-02025, 56 NRC 340, Washington, D.C.

San Luis Obispo Mothers for Peace V. NRC, 449 F. 3d (9th Cir. 2006)

U.S. Nuclear Regulatory Commission (NRC). 2004. Draft Environmental Impact Statement for

an Early Site Permit (ESP) for the North Anna ESP Site. NUREG-1811, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2005. Safety Evaluation Report of Early Site

Permit Application in the Matter of Dominion Nuclear North Anna, LLC, for the North Anna Early

Site Permit Site. Accession No. ML05160246. Available at http://www.nrc.gov/reactors/newlicensing/esp/north-anna.html.

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

an Early Site Permit (ESP) for the North Anna ESP Site, Supplement 1. NUREG-1811,

Washington D.C.
 December 2006 3-1 NUREG-1811, Volume II

3.0 Comments Within Scope

In this chapter, the staff responds to comments received by the U.S. Nuclear Regulatory

Commission (NRC) regarding the Draft Environmental Impact Statement (Draft EIS) and the

Supplement to the Draft EIS (SDEIS) evaluating the Dominion Nuclear North Anna LLC

(Dominion) request for an early site permit (ESP) for two new units (Units 3 and 4) at the North

Anna Power Station (NAPS). References in the responses to “the EIS” or “this EIS” usually

relate to Volume 1 of this Final EIS and, occasionally, relate to the series of EIS documents

(Draft EIS, SDEIS, Final EIS).

Comments presented in this chapter are related to technical and editorial aspects of the

evaluation. For each topic, the comments are organized so that comments received on the

Draft EIS are listed first and comments received on the SDEIS are listed afterward. An

exception to this strategy was made when a comment submitted on the Draft EIS was repeated

exactly, or almost exactly, on the SDEIS in which case, the latter comment was noted together

with the previous one. A short summary of the general comments in each section is provided in

the following paragraphs.

Land Use (Section 3.1). Commenters expressed concerns about the relationship of the

additional units to the regional land use plans in light of the forecasts of land use and predicted

rapid population growth. Other commenters requested clarification of specific parts of the

document.

Meteorology and Air Quality (Section 3.2). Commenters expressed concerns about waste heat

and global warming, plant emissions, increased fog and ice fog from increased evaporation

from Lake Anna, carbon dioxide emissions, and dust and smog from construction.

Water Use and Quality (Section 3.3). Comments received on water use and water quality cover

a variety of topics. Some commenters requested baseline groundwater monitoring and

expressed concerns about the effects of construction on surrounding wells. Commenters

expressed concerns about the capability of Lake Anna to support the additional units. Many

commenters expressed concerns about the effects of additional units on Lake Anna’s water

level and possible contamination of the lake. Some commenters expressed views about other

options for cooling (including using dry cooling to cool Unit 3) and alternate water sources. 

Commenters expressed concerns about downstream water impacts of additional units as well

as overall water use, water quality, water level, water supply, and the description of the water

budget model. Some commenters expressed concerns about the projected increase in water

temperature in the Waste Heat Treatment Facility (WHTF) as it related to the previously

proposed once-through cooling system evaluated in the Draft EIS. Commenters indicated that

construction activity could resuspend heavy metals and polychlorinated biphenyls (PCBs)

already in the lake sediment. There were comments related to drought and the effects that it
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NUREG-1811, Volume II 3-2 December 2006

would have on the lake with additional units, particularly related to the once-through cooling

system for Unit 3 (no longer proposed) or the evaporative water loss from the wet cooling

towers of the closed-cycle, combination wet and dry cooling system. In addition to these

concerns, other commenters saw benefits from additional units such as longer recreational

seasons resulting from warmer water temperature, again related to once-through cooling. 

Finally, some commenters drew attention to the fact that Lake Anna is an artificial lake,

originally created for the purpose of cooling up to four reactors.

Ecology (Section 3.4). This section is divided into Terrestrial Ecology (Section 3.4.1), Aquatic

Ecology (Section 3.4.2), and Wetlands (Section 3.4.3). The majority of the comments were

related to aquatic ecology. With regard to terrestrial ecology, commenters expressed concerns

about bald eagles in the region and about the noise generated by dry cooling towers and the

basis for the staff assignment of SMALL as the impact level for bird collisions with the towers. 

One commenter suggested that there should be an analysis of additional transmission lines in

the Final EIS, and several commenters expressed concerns about the construction activity

effects on wetlands around Lake Anna. One commenter recommended additional information

on monitoring programs, and the Virginia Department of Environmental Quality (VEDQ) stated

that the ESP would not be expected to adversely affect the forests of the Commonwealth.

Many commenters expressed concerns over the increase in water temperature resulting from

any additional units using the lake water for cooling (using the once-through cooling system

evaluated in the Draft EIS), and the effects that such an increase could have on aquatic

species, especially the striped bass, and other aquatic organisms. Some commenters

expressed concerns about entrainment and impingement of aquatic organisms that could result

from the increase in water use by the cooling system. Some commenters expressed concerns

about the potential for a decrease in lake water level during droughts and the effects on aquatic

life in Lake Anna. Commenters also expressed concerns about downstream ecosystem effects

from additional units. Several commenters expressed their views that the lake was created as a

cooling pond for four units and that the striped bass (a non-native, but thermally sensitive

species) should not take precedence over other needs.

Some commenters expressed concerns about the potential impacts to wetlands from

construction and operation of two additional units and about wetland mitigation and preservation

efforts.

Socioeconomics (Section 3.5). Comments received on socioeconomics cover a variety of

topics. One commenter asked about the NRC review guidance identifying the size of the region

the NRC uses for a site evaluation. Several commenters expressed concerns about the

availability of a workforce to construct additional units. There were comments regarding

positive and negative economic aspects of additional units. Some commenters indicated that

the additional units would create additional jobs, additional tax revenue, and other related

benefits. Some commenters expressed concerns that additional units could disrupt business,
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 December 2006 3-3 NUREG-1811, Volume II

especially if recreation, such as fishing and boating on Lake Anna, was affected. Some

commenters indicated that traffic on local roadways would be affected. Some commenters

suggested that additional economic information be included in the Final EIS. Some

commenters expressed concerns about the availability of housing for construction workers, the

effect of additional units on the housing values in the Lake Anna area, and possible increased

demand on the transportation, educational, and health care systems. Some commenters

expressed concern about the aesthetic aspect of the height of the cooling towers. Finally, some

commenters requested additional information about the population data included in the

document.

Historic and Cultural Resources (Section 3.6). One commenter requested that cultural resource

assessments be performed as part of this Final EIS; one commenter questioned the nature of

communications with Native American tribes that were conducted for this EIS and sought to

determine what mitigation measures would be employed should such resources be discovered.

Environmental Justice (Section 3.7). Several comments were received regarding environmental

justice. One expressed appreciation for the environmental justice section, and asked for

clarification regarding the poverty level in Louisa County. The other recommended that the

NRC review the population data and the potential effects of potential plant development within

the 50-mi radius around North Anna. Another asked for the EIS to include more extensive

information related to environmental justice.

Site Redress (Section 3.8): Two of the comments received on the site redress plan were

submitted by the VDEQ. These comments offered insight on disposal of radioactive soils,

lead-based paint, and asbestos. Several commenters expressed concerns about the site

preparation activities that would be allowed under the ESP.

Human Health (Radiological Impacts) (Section 3.9). Some commenters expressed concerns

about cancer that could be caused by exposure to radioactive material and about the potential

for a possible increase in the incidence of cancer near the North Anna plant. Several

commenters expressed concerns about the potential for release of radioactive material from the

plant and the health of the local population. Commenters expressed concerns about the

potential for infant mortality and one commenter requested disease and mortality studies be

performed for the local area. Several commenters expressed concerns about health in relation

to environmental radiation exposure. One commenter questioned the adequacy of the Federal

occupational radiation worker limit of 5-rem per year. There were also comments that concerns

about radioactivity were overstated and that alternative forms of power production had a higher

risk than the nuclear power alternative.

Human Health (Nonradiological Impacts) (Section 3.10). This section lists comments that

principally focus on human health impacts of construction and operation of new facilities that are

not related to potential radiological releases. Specifically, the comments address noise and
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NUREG-1811, Volume II 3-4 December 2006

impacts of electromagnetic fields and potential health impacts from recreational use of the

existing plant’s waste heat treatment facility. One commenter questioned why the applicant

could defer application of the National Electric Safety Code (NESC) on the transmission lines

until the combined license (COL) stage. The commenter also suggested that the increased

transmission capacity would exceed NESC standards for electrostatic fields and potentially

increase the leukemia hazard for humans. One commenter suggested that noise from

construction activities may not be an appropriate comparative measure for operational noise

impacts.

Uranium Fuel Cycle (Section 3.11). Commenters expressed concern that this EIS does not

address the possible security threats of storing radioactive waste on site. Some commenters

suggested that nuclear power is not emission free if the mining, transportation, enrichment, and

construction activities associated with nuclear power plants are taken into consideration. One

commenter suggested that using nuclear fuel actually removes it from the environment, thus

cleaning up the planet. Concerns were expressed about the disposal of both high and low-level

waste, and the permanent nature of nuclear waste. Several commenters expressed concerns

about the proposed repository at Yucca Mountain and the need for a solution to the waste

issue. Several commenters addressed the politics involved in the nuclear waste issue, with

some commenters taking issue with the elimination of U.S. restrictions on importing uranium

from foreign sources, some commenters suggesting that the waste storage issue is being held

hostage by politics, and one commenter suggesting that the problems of waste management

are political and not technical in nature. Several commenters encouraged fuel reprocessing and

suggested that this option should be addressed in this EIS. Some commenters expressed

concerns about solid waste and spent fuel, and about the storage of spent fuel at the North

Anna site until a more permanent solution is finalized. Other commenters expressed their views

that spent fuel is safely stored at the North Anna site and at other similar sites.

Transportation (Section 3.12). Commenters expressed concerns about safe transport of

nuclear waste and about the increased volume of waste to be transported with additional

reactors.

Decommissioning (Section 3.13). Commenters expressed concerns about the cost of

decommissioning and the consequences if any company owning a nuclear power plant went

bankrupt. Commenters also suggested that any new reactor would add additional

contamination, and asserted that the extent of cleanup would depend on the political clout of the

community and waste storage solutions at the time.

Postulated Accidents (Section 3.14). Many of the comments addressed events similar to the

Chernobyl and Three Mile Island accidents. In addition, concerns about the reactor vessel

head, such as the Davis-Besse reactor head situation, were mentioned. Many commenters

expressed concerns about the safety of nuclear power and focused on the likelihood and

consequences of human error, while others expressed concerns that an external security threat
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 December 2006 3-5 NUREG-1811, Volume II

could increase the possibility of problems. Several commenters suggested that reduced water

availability could increase the likelihood of an unexpected accident. Some commenters stated

that the risks of nuclear power outweigh the benefits, and suggested that the cost of liability and

cleanup were important factors to consider. Transportation accidents were also mentioned.

Mitigation Measures and Controls (Section 3.15). The VDEQ provided most of the comments

about mitigation measures. The comments were recommendations with regard to future

construction should Dominion receive an ESP.

Cumulative Impacts (Section 3.16). Comments included concerns about cumulative

environmental effects with the proximity of other reactors at the North Anna site, and the

cumulative effects over time on the downstream hydrology and biology from the existing and

any additional units. One commenter suggested that the NRC staff evaluate cumulative effects

from pre-dam conditions. One commenter suggested that regional transportation and roads

would be affected by traffic from any additional units above that from the operation of the

existing units.

Alternatives (Section 3.17). Several commenters questioned the suitability of the North Anna

site for additional units, as opposed to locating them at Surry Nuclear Power Station or the

Savannah River Site. Some commenters requested more information, including inclusion of life

extensions of the existing plants or their retirement, and more population data. One commenter

sought additional information about brownfield sites, and one questioned the impact level of the

no-action alternative. One commenter suggested that the Savannah River Site has undergone

a comparable level of study and suggested that several of Savannah River’s impact levels

stated in this EIS be changed from MODERATE to SMALL. One commenter expressed the

concern that making direct comparisons among the sites was difficult because several factors

are not inherently the same at all sites.

3.1 Land Use

Comment: ODEC’s [Old Dominion Electric Cooperative] joint ownership should be

acknowledged similar to DEIS Page 2-5, Line 34. [page 2-1, line 31]. (DW-0423 3)

Response: The staff agrees with this comment. Section 2.1 of this EIS was modified to reflect

the comment.

Comment: Table 2-1 shows the Land Use in four nearby counties. On this and other

measures, the DEIS review of the Existing Environment should include a forecast of the

conditions over the twenty year life (since the timing for the action is uncertain) of the ESP as

the baseline. Given the rapid population growth in the area, the 2002 data cited is already

obsolete and huge changes are already forecast for the region even without considering the
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NUREG-1811, Volume II 3-6 December 2006

proposed project. Spotsylvania, for example, is one of the fastest growing areas of the State. 

If the DEIS showed current conditions and forecasts for say 5, 10, 20 year intervals as the

baseline, the impacts of the project could be put into better perspective. (DW-0438 20)

Response: NRC regulations state that NRC EISs are to discuss possible conflicts between the

alternatives and the objectives of land-use plans, policies, and controls for the area concerned

[10 CFR Part 51, Subpart A, Appendix A.7(c)]. The land use information in Table 2-1 was

included in this EIS as background information for the reader. Louisa, Orange, and

Spotsylvania Counties have comprehensive land use plans in place as required by

Section 15.2-2223 of the Code of Virginia. The additional units do not appear to present a

land-use conflict because they would be located on the NAPS site which is zoned for industrial

use by Louisa County as noted in Section 4.1.1 of this EIS. While projections of population

growth are considered in this EIS, forecasts of future land use in Louisa County and adjacent

counties are beyond the scope of this EIS. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: Page 2-5 line 1 states that the Lake Anna Special Plan is “final.” Please verify this

statement. Furthermore, it would be useful to state whether the Plan addresses nuclear

expansion in the region and/or nuclear evacuation plans. There may be a disconnect between

local planning and the proposed project. (DW-0438 13)

Response: In this case, “final” was used to distinguish it from a draft document. The Plan

does not address nuclear expansion in the region and/or nuclear evacuation plans. The

wording in Section 2.1 of this EIS has been revised to clarify that the plan is a platform to

coordinate planning among local jurisdictions.

Comment: Page 2-7 line 26 lists a variety of local planning documents. What do these plans

say about nuclear material transport, nuclear material storage, power generation facilities,

nuclear waste storage, and nuclear waste transport through the jurisdictions? Simply listing the

local planning documents does not define the current planning environment against which the

proposed action is to be judged as an overlay. As stated in comment 13, there are disconnects

between local planning and the proposed project. (DW-0438 16)

Comment: Page 5-1 line 40 states that “any growth would be managed” because the counties

have land-use plans. Just because the counties have plans, doesn’t mean that growth is

managed. Furthermore, at least for several of the adjacent counties, the plans do not

specifically contemplate the proposed action. (DW-0438 123) 

Response: Louisa, Orange, and Spotsylvania Counties have comprehensive land use plans in

place. The plans are periodically updated by the county planning agencies. The staff assumes

that land use plans would be updated by local jurisdictions to consider impacts attributable to

the construction and operation of new nuclear generating units at the North Anna ESP site. If
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 December 2006 3-7 NUREG-1811, Volume II

Dominion were granted an ESP, the staff believes that local planning agencies would have

sufficient time to modify their planning documents to reflect construction activities at the North

Anna site. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: The conclusion of Section 4.1.1 is that the Construction phase would only have

“SMALL” impacts (defined on page xxii as “not detectable or so minor that they will neither

destabilize nor noticeably alter any attribute...”). This is obviously false for a project with a

capital cost of greater than $500 million and with about 5,000 construction jobs in a largely rural

region. (DW-0438 88)

Response: Section 4.1.1 addresses land-use impacts at the NAPS site and in the vicinity. 

New construction for the proposed Units 3 and 4 would occur entirely on the North Anna ESP

site at NAPS on land that was previously disturbed by construction. Therefore, onsite land use

impacts for such construction would be small. Some offsite land use impacts could occur,

principally for new housing and retail stores. Nevertheless, the staff views the land-use impacts

associated with construction of two new units at the North Anna ESP site as SMALL. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: According to Louisa County Code of Ordinance, Division 7 - Industrial District,

Section 96-162, Permitted Uses, none of the 30 “restricted use” categories include electrical

generating units explicitly. A conditional use permit may not be required for construction of new

generating units. [page 4-2, line 3] (DW-0423 21)

Response: The staff agrees with this comment. Section 4.1.1 of this EIS was modified to

delete the reference to a conditional use permit.

Comment: The wording in Table 10-2 and Page 10-6 appear to be inconsistent regarding land

use impacts. ER Section 5.8.2 concludes that there would be no unavoidable adverse

environmental impacts. The Comprehensive Plans for the nearby counties already incorporate

projected growth in population and the demand for public services, regardless of whether part of

this increase in population growth consists of new operations personnel for new units at the

ESP site. [page 10-6, line 35; page 10-7, line 4, Table 10-2] (DW-0423 51)

Response: Table 10-2 in this EIS was revised to reflect the conclusion that there would be no

adverse impacts during operation. Any adverse land use impacts would have occurred during

construction.

Comment: According to the Department of Conservation and Recreation’s Division of

Chesapeake Bay Local Assistance, the project area, which is in Louisa County (Draft EIS,

page 2-5, Section 2.2.1), is not within a Chesapeake Bay Preservation Act jurisdiction. 

(DW-0439 49) (SW-0017 79)
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NUREG-1811, Volume II 3-8 December 2006

Response: This comment from the VDEQ confirms that the North Anna site is not within a

Chesapeake Bay Preservation Act jurisdiction. Accordingly, no changes were made to this EIS

as a result of this comment.

Comment: 1) The DEIS refers to the saprolite beneath the site as unsuitable for use as a fill

material for plant construction. Instead of “fill,” this should be “structural fill.” 2) The DEIS

indicates that fill material will need to be imported to the ESP site during construction and

excavated material will have to be moved to another location. Again, this should be “structural

fill” rather than “fill” since all of the excavated material can be used as general fill. 3) Also, as

stated in SSAR Section 2.5.4.5.3, bedrock excavated for the deeper foundations can be

crushed and used as structural fill. Thus, structural fill would only need to be imported to the

ESP site as an alternative or supplement to the onsite crushed rock. [page 2-17, line 38]

(DW-0423 5)

Response: Section 2.4 of this EIS was revised to indicate that the saprolite beneath the site is

unsuitable for use as a structural fill material for the foundations of safety-related plant

structures.

3.2 Meteorology and Air Quality

3.2.1 Meteorological Data and Local Climatology

Comment: Page 2-14 line [number not provided] and other parts of the report use inconsistent

meteorological reporting periods and thus an inconsistent data set. (DW-0438 27)

Comment: Page 2-14 line 14 reports on storms during the period from January 1950 through

July 31, 2003. This is an arbitrary time period which [does not] include Hurricane Isabel, for

example. (DW-0438 28)

Response: Data sets of different time periods are common in reporting of meteorological data

depending on the analysis. Long-term data (30 years) are necessary to establish normal values

for climatological variables such as mean temperature, the highest and lowest temperatures,

and mean rainfall and snowfall, and for use in estimating extreme values of meteorological

parameters such as passage of extreme events in the region of the site. Climatological data for

short periods are generally evaluated by comparing climatological normals for representative

National Weather Service sites to provide a basis for determining the reasonableness of the

short-term climatological data. In the case of reported storms between 1950 and 2003, the time

period covers the information available from the National Climatic Data Center. Data collected

onsite are necessary to estimate the dilution characteristics to assess radiological impacts to

the local surrounding areas and to determine the impacts resulting from accidental releases of
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radionuclide material to the atmosphere. The data periods for these assessment purposes

were adequate. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Page 2-25 [apparently reference is to page 2-15 in hard copy of report]

line 25 states that good data is available from 1/1/96 to 12/31/01 yet line 32 states that only a

portion of this interval was used for the DEIS analysis data. Why? Furthermore, the use of a

three year data set is arbitrarily low. (DW-0438 29)

Comment: The same limited three-year climatological data set that was used in the DEIS is

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 5-58 line 38 e.g.) used elsewhere

in the document. (SE-0045 11)

Comment: More than three years of meteorological data should be used in Section 5.10.1. 

(DW-0438 162)

Response: Meteorological data are collected continuously at the NAPS site. For purposes of

the ESP application, Dominion chose to present a fixed period from that overall data set. One

to three years of representative meteorological data are generally sufficient to characterize the

site and are consistent with the period of record set forth in NRC guidance. Accordingly, no

changes were made to this EIS as a result of these comments.

Comment: Page 2-15 line 36 states “The NRC staff expects that the current monitoring system

would remain operational.” The applicant should be required to stipulate to this and add

additional monitoring (for example, relative humidity) as may be required. (DW-0438 30)

Comment: Page 2-13 line 15 states that relative humidity is not measured at the site. 

Regional warming of the Lake contributes to microclimates, increased humidity, and intermittent

ground fog. This parameter should be measured. (DW-0438 24)

Comment: The small data set cited in 29 [DW-0438 29] is especially problematic given that it is

used for the radioactive dispersion assessments (Page 2-16, line 5). (DW-0438 31)

Response: The staff has determined that one to three years of representative meteorological

data are sufficient to estimate the likely impacts from both routine and accidental releases,

which for EISs are based on typical meteorological conditions. However, as is the case at

NAPS, meteorological monitoring programs would continue during the period of operation of the

facility. Dew point and ambient temperatures are also measured at the site. From ambient and

dew point temperatures, relative humidity can be calculated.
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NRC guidance, with regard to the meteorological monitoring system are set forth in various

documents including Regulatory Guide 1.23, “Onsite Meteorological Programs,” and Regulatory

Guide 1.97, “Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and

Environs Conditions During and Following an Accident.” Accordingly, no changes were made to

this EIS as a result of these comments.

Comment: A relative humidity of greater than 90 percent and ambient temperature less than

32°F are conditions required for the formation of ice from steam fog. [page 5-37, line 32] 

(DW-0423 34)

Response: Steam fog can occur at humidity conditions of less than 90 percent and

temperatures above 32°F. To avoid confusion, the phrase “steam fog formation” used in the

Draft EIS was changed.

Comment: Page 2-12 line 4 confirms that the prevailing winds are from the south-southwest. 

This is just one reason that impacts on Fredericksburg and the DC metropolitan area should be

assessed. (DW-0438 23)

Response: The statement that prevailing winds at the site are from the south-southwest is

correct. The environmental analyses were not limited to one wind direction or another, but

reflect the variability that does exist. For each environmental analysis that considered wind

direction, the distances (for example, low population zone) used in the analysis are

appropriately established in relation to the distance from the site or where exposure is

important.

NRC regulatory guidance for certain environmental analyses outline local and regional regimes.

Because Fredericksburg is within the 80-km (50-mile) region of the NAPS site, it was included in

the radiological assessment in Section 5.9 (routine releases) and Section 5.10 (postulated

accidents). Washington, D.C. is outside the 80-km (50-mile) region and was thus not included

in the analysis.

Air quality impacts resulting from the operation of equipment onsite (for example, standby diesel

generators) would not be significant compared to ambient air quality conditions (i.e.,

concentrations of air pollutants from natural and man-made sources, such as vehicle emissions

and industrial sources) that could be measured at those locations. Concentrations of pollutants

in the region are expected to remain below the National Ambient Air Quality Standards for

criteria pollutants. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: As stated in ER section 5.3.3.1, steam-fog-induced icing conditions are very

infrequent at the site. Consequently, ice buildup on transmission lines, switchyard, insulators

and structures due to steam fog would not be anticipated. (SE-0050 8)
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 December 2006 3-11 NUREG-1811, Volume II

Response: The comment relates Dominion’s experience at the North Anna site. Accordingly,

no changes were made to this EIS as a result of this comment.

3.2.2 Draft EIS: Impact of Waste Heat

Comment: When I was part of the construction efforts for Byron Nuclear Plants 1 & 2, their

natural draft cooling towers were praised and touted as the largest and most northern towers

yet constructed. And fully capable of handling the waste heat from the 2 plants. One issue that

they didn’t take into account, however, was the impact of humid air--result was that at the

hottest and most humid (August) days (when the power was most needed), Com Ed had to

back down their outputs by about 5-8% for those days. Towers didn’t work as well as planned.

So (while I support the ideas of Dominion), I believe we should carefully re-visit the calculations

on heat removal--just to make sure we’re accounting for the relevant factors and make sure

there’s still some margin. (DW-1237 1)

Response: Design-level analysis on heat dissipation for cooling towers would be conducted

as part of the safety evaluation if Dominion receives an ESP and the ESP is referenced in a

COL application. However, design-level information is not necessary to evaluate the impact

of cooling towers on the environment. The staff evaluated the impact of discharging

9.7 x 109

 BTU/hr to the environment. With regard to the effectiveness in performance of wet

and dry or just dry cooling towers, it may be an element in the benefits assessment that would

be performed at the COL stage. Accordingly, no changes were made to this EIS as a result of

this comment.

Comment: What microclimatic temperature increases and secondary impacts could result from

the dry cooler operations (Page 5-38 line 3)? (DW-0438 150)

Response: The microclimatic changes from the use of dry cooling are not expected to be

significant because the waste heat would be readily absorbed into the atmosphere through

convective and mechanical mixing. Accordingly, no changes were made to this EIS as a result

of this comment.

Comment: Page 2-13 line 27 indicates that heavy fog is an issue at the site. The increased

warm water from the proposed project would contribute to increased heavy fog during some

cooler days. The impacts to traffic from this occurrence should be addressed in the DEIS. 

(DW-0438 25)

Comment: The impacts to traffic from increased fog occurrence...should be addressed in the

SDEIS. (SE-0045 12)
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Comment: Ground fog is a serious problem along Route 208 in the vicinity of the Lake at times

(Page 5-37). This problem will be worse if the Lake waters are heated up. (DW-0438 149)

Comment: No mention is made of the impacts of the increased warm water in the Lake on

ground fog and the traffic impacts associated therewith. (DW-0594 8)

Response: These comments related to conditions discussed in the Draft EIS in which

Dominion proposed a once-through cooling system. Dominion revised its proposal to a

closed-cycle, combination wet and dry cooling system for Unit 3 and dry cooling towers for

Unit 4. Operation of the cooling towers in the wet mode would release warm, moist air into the

atmosphere creating elevated plumes. As the plumes lose buoyancy and reach ground level,

there is a potential for fogging and icing. The staff estimates the maximum hours of fogging to

be 70 hours per year beyond naturally occurring fog. A majority of the estimated fogging would

occur within 1000 ft south-southeast from the cooling towers, but could extend as far as 5200 ft. 

Fogging was estimated to occur in all seasons except summer, but primarily in late fall and

winter. During the time the cooling towers operated in the dry mode (which would result in no

additional adverse impact and could result in a slight improvement), the atmosphere, rather than

Lake Anna, would be the sink for the waste heat. This would not lead to increased ground fog

in or around the site area. Section 5.2 of this EIS has been changed to reflect the atmospheric

impacts resulting from the proposed change in the cooling system for Unit 3.

Comment: [T]he cooling towers that you have cooling the air temperature. What is that going

to do from a thermal heat pollution to the atmosphere? (ST-0001 3)

Comment: These cooling towers will emit plumes of steam fog formation, which can create

fog-icing conditions in the vicinity an average of 70 hours per year (or if three hours per day this

equates to 23 extra days of year of fog and/or icing condition on the adjoining roadways).

...What type of mitigation can be done to avoid any traffic problems on adjoining roadways? 

(SW-0005 7)

Comment: What type of mitigation can be done to avoid any traffic problems on adjoining

roadways as a result of the fog and icing conditions approximately an extra 23 days a year? 

(SE-0003 7)

Comment: We're concerned about ...The impact of additional fog and icing from wet cooling

towers on local roadways. (ST-0014 17)

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the ESP]

...Impact of additional fog and icing from wet cooling towers on local roadways. (SE-0022 29)
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 December 2006 3-13 NUREG-1811, Volume II

Response: Operation of the cooling towers in the wet mode would release warm, moist air into

the atmosphere creating elevated plumes. As the plumes lose buoyancy and reach ground

level, there is a potential for fogging and icing. The staff estimates the maximum hours of

fogging to be 70 hours per year beyond naturally occurring fog. No icing is expected to occur. 

A majority of the estimated fogging would occur within 1000 ft south-southeast from the cooling

towers, but could extend as far as 5200 ft. Fogging was estimated to occur in all seasons

except summer, but primarily in late fall and winter. During the time the cooling towers operated

in the dry mode (which would result in no additional adverse impact and could result in a slight

improvement), the atmosphere, rather than Lake Anna, would be the sink for the waste heat. 

This would not lead to increased ground fog in or around the site area or in the vicinity of the

roadways. Section 5.2 of this EIS has been changed to reflect the atmospheric impacts

resulting from the proposed change in the cooling system for Unit 3.

3.2.3 Air Quality

Comment: The construction of the plant - including truck traffic, smog and building waste, will

be negligible compared to the clean air savings from operation of the facility. (DW-0370 3)

Comment: The construction of the plant, including truck traffic, smog ...will be detrimental to

the environment. (DW-MM1 3)

Comment: [Regarding Dominion’s Site Safety Analysis.] Section 4.4.1.1.4 - Recreational

Facilities - Where this information mentions that fugitive dust would not be a discernible impact

on Lake Anna or adjacent environs, additional information should be evaluated. This

information mentions discernible impact. To whose discretion? (DW-0191 7)

Response: Long-term construction emissions are expected to be negligible compared to the

clean air savings from operation of the facility versus operation of other large-scale energy

production facilities over the lifetime of power-production facilities. Over the short term,

activities related to construction could impact the existing local air quality. However, Dominion

has committed to implementing a construction management plan to minimize the impact (see

Section 4.10). The VDEQ has the ultimate responsibility to determine whether Dominion’s dust

control plan is sound and implemented properly. Accordingly, no changes were made to this

EIS as a result of these comments.

Comment: Page 4-4 line 9 states “potential” mitigation measures. The DEIS should specify

the actual mitigation measures to be used which should be stipulated by the applicant. 

(DW-0438 89)

Response: Dust control plans would be developed if Dominion would seek to proceed with

construction activities including site preparation activities. In Section 4.10, Measures and

Controls to Limit Adverse Impacts During Construction Activities, the staff stated that it relied on
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NUREG-1811, Volume II 3-14 December 2006

the dust control plan in its assessment of impacts. All activities are expected to be conducted

by Dominion in accordance with the Commonwealth of Virginia requirements for visible and

fugitive dust and emissions from mobile sources. Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: Please list the “bounding values” of the non-radiological pollutants that would be

permitted to be released during [operation of] auxiliary boilers and generators from the

proposed new reactors. (DW-0437 60)

Comment: Please list the non-radiological emissions and amounts that are permitted to be

released from the existing plants under the Exclusionary General Permit, as well as the

2000 emission statement. What are the expected emissions with the two additional reactors at

the site? (DW-0437 57)

Comment: The DEIS (page 2-17, lines 1-4) states that “additional records to be submitted

along with a certification for all [non radiological] emission sources” and that “the additional

emissions are expected to be limited to a short test period.” Please clarify the phrase “short test

period.” (DW-0437 59)

Response: The Exclusionary General Permit for non-radiological pollutants (discussed in

Section 2.3.2) that may be released at the entire NAPS site is restricted to 50 tons/yr for each of

the following pollutants: total particulate matter, particulate matter with a diameter less than

10 microns, sulfur dioxide, nitrogen oxides (NOx), carbon monoxide (CO), and all volatile

organic compounds (VOCs). The total actual emissions of each pollutant must not exceed

20 tons/yr to be exempt from certain recordkeeping and reporting requirements. The emissions

for all pollutants were well below the allowable limits for the 2000 reporting period. As

described in Section 2.3.2, emissions from equipment proposed to support the two additional

units are not expected to exceed the amounts reported for 2000 with the total emission levels

expected to be well below the allowable limits of the Exclusionary General Permit.

Site personnel periodically test the auxiliary boilers and diesel generators to confirm they are in

working order. Under the Exclusionary General Permit, the total hours of operation of the

auxiliary boilers and five diesel generators are limited to 3000 and 500 hours per year,

respectively. Typically, these limits are not approached. Accordingly, no changes were made

to this EIS as a result of these comments.

Comment: According to DEQ's Division of Air Program Coordination, the North Anna Power

Station is in an ozone non-attainment area. While the change in the cooling system itself will

not have any impact on air quality, all precautions are necessary to restrict emissions of volatile

organic compounds (VOCs) and oxides of nitrogen (NOx), during pre-construction activities
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 December 2006 3-15 NUREG-1811, Volume II

allowed under the Early Site Permit and also during implementation of the site redress plan in

the event the proposed addition of Units 3 and 4 does not materialize. (DW-0439 4)

(SW-0017 66)

Response: On April 30, 2004, Spotsylvania County was designated as non-attainment

according to the new U.S. Environmental Protection Agency (EPA) national ambient air quality

standard for 8-hour ozone levels which became effective as of July 15, 2004. VOCs and

nitrogen oxides (NOX) are precursors to the formation of ozone; thus, emissions from

construction and operating sources could contribute to ambient ozone levels in Spotsylvania

County. Subsequently, on December 23, 2005 (70 76165), EPA redesignated Spotsylvania

County as in attainment for ozone. Consequently, the staff considers it unlikely that emissions

associated with Units 3 and 4 would have an adverse affect on ozone levels in Spotsylvania

County.

States are expected to reduce areas of non-attainment through actions outlined in their State

Implementation Plan, which VDEQ administers for the Commonwealth of Virginia through the

permit process for point-source emissions. VDEQ is also working with local communities to

reduce area emissions from fossil-fuel transportation related activities. VDEQ would establish

the permit requirements if a construction permit (CP) or COL is requested. Section 4.10,

Measures and Controls to Limit Adverse Impacts During Construction Activities, states that the

staff relied on Dominion’s compliance with State and Federal permits required for the

construction of new units. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: Fuel-burning equipment used in construction activities may require an air pollution

control permit, depending on capacities and potential to emit air pollutants. (SW-0017 69)

Response: Dominion would have to obtain applicable permits for construction activities. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: What else is going to be evaporated beside the water? We know we have PCBs in

the lake. Is this a potential source, to put the PCBs out? How about other pollutants that are in

the water, are they going to be spread out into the atmosphere? (ST-0024 2)

Response: The droplets of the plume exiting from the cooling towers would contain

insignificant concentrations of chemicals suspended in the waters of Lake Anna at the point of

plant intake. As the water that feeds the cooling towers evaporates, most of the treatment

chemicals in the water fall as solids inside the towers and would be removed as part of standard

maintenance activities. The concentration of the chemicals remaining in the water vapor plume

would fall as drift to the ground and onto vegetation near the towers. Polychlorinated biphenyls

(PCBs) primarily exist in solid form in the lake sediments because they are not very water

soluble. Without mechanical actions such as dredging to resuspend PCB material into the
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NUREG-1811, Volume II 3-16 December 2006

water, any PCB concentrations at the point of the plant intake would be insignificant compared

to concentrations found in the sediment in the bottom of Lake Anna. Such concentrations would

be below levels of concern. Accordingly, no changes were made to this EIS as a result of this

comment.

3.2.4 Severe Weather

Comment: This wording [regarding Hurricanes] is inconsistent with ER Section 2.7.3.4

(ESP Application Revision 3). Hurricane Camille, a tropical depression by the time it passed

through the area within 100-nautical miles of the North Anna site, resulted in 11.18 inches of

rainfall at the nearby Louisa observation station. [page 2-14, line 8] (DW-0423 4)

Response: The discussion of hurricanes in Section 2.3.1.5 of the Draft EIS was modified in

this Final EIS to reflect the 24-hour rainfall total associated with the passage of the remnants of

hurricane Camille.

3.2.5 Global Climate and Greenhouse Gas Emissions 

Comment: I’m very concerned about greenhouse emissions and acknowledge that nuclear

power doesn’t emit greenhouse. (DT-0001 2a) 

Comment: Nuclear is being touted as clean, and I think we need to redefine that term. It does

reduce CO2 emissions, but I don’t feel that waste that lasts for hundreds of thousands of years

is clean. (DT-0044 2)

Comment: Finally, global warming. There are much better solutions. Global warming is

occurring. We need to take action, but more nuclear plants are not the answer. Further

investment in nuclear power would squander resources necessary to implement meaningful

climate change mitigation policies. (ST-0008 7)

Comment: [T]here is continuing discussion about impacts of energy use on the atmosphere

and particularly in terms of climatic effects and we need to start thinking about what are we

going to do as a society and as a state to address some of those issues. We believe that

nuclear energy is an important part of the overall energy supply picture because it assures a

diverse energy supply and it's something that can continue to be available to meet future needs. 

And nuclear is not emitting, a non-emitting source, from the perspective of carbon dioxide and

therefore, if we are concerned about carbon dioxide, if as a society we choose to do something

about limiting carbon emissions to the atmosphere, nuclear will be a vital part of that. 

(ST-0009 2)
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 December 2006 3-17 NUREG-1811, Volume II

Comment: [I]n the U.S., the studies show that it is not possible to maintain the existent

percentage of non-emitting energy sources that alone increase this percentage without the

contribution of nuclear power. This means that just to maintain the current level of

environmental quality we will need to build new nuclear power plants. (ST-0013 3)

Response: The NRC does not establish public policy regarding electric power supply

alternatives. The NRC does not promote the use of nuclear power as a preferred energy

alternative. In addition, the NRC does not regulate alternatives to producing electricity that do

not involve nuclear power. The NRC does evaluate energy alternatives as part of its CP and

COL licensing process.

Uncontrolled greenhouse gas emissions to the environment are 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 greenhouse gases

in large quantities, however, that only applies to the operation of the facility for the production of

electricity. Fossil fuels are often used as part of the infrastructure needed to operate a nuclear

power facility, notably, for the manufacture of the fuel that is used in the facility. Greenhouse

gas emissions from vehicle use to, from and at the plant would be comparable to vehicle use by

personnel for any other type of power generation. It is an important factor that the amount of

greenhouse gas emissions produced in the energy sector is not trivial; this is considered by

energy policy decisionmakers elsewhere in the government.

The U. S. Department of Energy (DOE) estimated that the greenhouse gases that would be

displaced if nuclear power plants replaced fossil-based electricity generation would be about

3.2 million metric tons of carbon per year for every unit of approximately 1000 MW(e). 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, then the amounts could be reduced even further. The greenhouse gas

emissions from nuclear power reactor operational activities are minimal and are principally from

auxiliary boiler operation and standby diesel generator testing. As for the fuel cycle greenhouse

gas emissions, the NRC estimated that the energy needed for the fuel’s life cycle for one year of

operation of a 1000 MWe 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 this EIS). Therefore, using the DOE

estimate and the 5 percent factor, approximately 160,000 metric tons of greenhouse gases

would still be produced for every 1000 MWe assuming a nuclear power plant was operating for

the entire year. (The fuel cycle produces about five percent of the CO2 that would be produced

per megawatt by a coal–burning plant.

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. With the increasing interest in the nuclear power program in
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NUREG-1811, Volume II 3-18 December 2006

the U.S., advancements in power reactor technology and uranium enrichment technology, the

total greenhouse gas emissions that may result from the fuel cycle may differ from those

described above. Depending upon the number of 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. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: The second myth of nuclear power is that it’s clean. The mining and refining of

uranium, transportation of fresh and spent fuel, construction of reactors and of the waste

repository all create carbon emissions. Uranium enrichment uses 93 percent of the

chloroflorocarbon or CFC gas made annually in the U.S. CFCs are greenhouse gases that trap

thousands of times more heat than carbon dioxide. (DT-0036 5)

Response: Section 6 of the Draft EIS evaluated the impacts of the uranium fuel cycle (to

include mining, milling, conversion, enrichment, and fuel fabrication) and transportation impacts. 

Impacts from carbon emissions were determined to be SMALL. Impacts of reactor construction

were evaluated in Section 4.2 and Section 4.8 of the EIS. The EPA has established the

Significant New Alternatives Policy (SNAP) Program to evaluate and regulate substitutes for

ozone-depleting chemicals, such as a number of chlorofluorocarbons (CFCs) used in chillers

and other refrigerants. Since implemented as part of the stratospheric ozone protection

provisions of the Clean Air Act (CAA) amendments of 1990, the production and atmospheric

release of ozone-depleting chemicals has been reduced substantially nationwide. There were a

number of CFC species that were candidates to be replaced by alternative chemicals. In the

case of one CFC, for example CFC-114 (1,2-dichlorotetrafluoroethane), the total annual

production reported to the Alternative Fluorocarbons Environmental Acceptability Study ranged

from a peak of 19,300 metric tonnes in 1986 before the CAA amendments of 1990 to a low of

300 metric tonnes as recently as 2003. This reduction nationwide was so substantial that the

Study no longer calculates the emissions of CFC-114; this should not indicate that industries

still using this CFC should not continue to improve, but that the alternatives already in use have

achieved the intended goals of CFC conversion to less depleting chemicals. Impacts of

construction of the waste repository were not evaluated as this will be a separate licensing

action. The Paducah Gaseous Diffusion Enrichment Facility, the only enrichment facility

currently operating in the United States, uses a chlorofluorocarbon (CFC) as a process coolant. 

CFCs leak from pipe joints, valves, coolers, and condensers in the facility, but the leak rate is

within the level allowed under EPA regulations. If the proposed American Centrifuge Plant,

using an alternate enrichment technology, is licensed by the NRC and becomes operational, the

emissions would be reduced even further. (References:

http://www.usec.com/v2001_02/Content/Investors/2004pdf/USEC2004AnnualReportFinancial.pdf and http://www.afeas.org). Accordingly, no changes were made to this EIS as a

result of this comment.
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 December 2006 3-19 NUREG-1811, Volume II

3.3 Water Use and Quality

3.3.1 Groundwater Use and Quality

Comment: This wording is inconsistent with ER Section 6.3.1. Wells around the SWR [service

water reservoir] are monitored every six months to evaluate the reservoir for leakage, assess

the effectiveness of horizontal drains beneath the existing units pump house, and determine the

flow rate and clarity of the associated discharge water. [page 2-21, line 13] (DW-0423 6)

Response: The discussion in Section 2.6.1.3 was modified to clarify the description of

groundwater monitoring.

Comment: Page 2-24 line 38 states that “there are no site-specific data available for the

chemistry of the groundwater underlying the ESP site.” Why not? Shouldn’t groundwater

monitoring wells, water sampling, and chemical analyses be part of the ongoing monitoring of a

nuclear power project that stores radioactive waste? Shouldn’t baseline monitoring be required

now as part of the impact evaluation of the proposed Units 3 and 4? This data is clearly on

point in evaluating a site as opposed to evaluating its operations (CP/COL). (DW-0438 42)

Response: The text in Section 2.6.3.2 has been clarified with regard to the availability of

groundwater quality data as it relates to nonradiological constituents. Groundwater quality data

(e.g., pH and conductivity) have not been collected specifically at the ESP site. However,

groundwater quality data have been obtained as part of the adjacent NAPS operating site’s

radiological monitoring program. Although site-specific groundwater quality data are not

available, the use of groundwater data from regional surficial aquifers provides an adequate

representation of the radiological perspective. 

Comment: [Regarding the comment that site-specific groundwater chemistry data would be

required for a construction permit or combined license] Draft Safety Evaluation Report (DSER)

Open Item 2.4-11 requests information necessary to demonstrate compliance with

10 CFR 100.20(c)(3). Dominion’s response to this DSER Open Item will provide the requested

information. [page 2-22, line 2] (DW-0423 10)

Response: Subsequent to issuing the Draft EIS, a permit condition was incorporated into the

Safety Evaluation Report (SER) (ML051250112) that precluded the need for the site-specific

groundwater chemistry data identified in 10 CFR 100.2(c)(3). While related to groundwater

issues, this is not specifically related to the scope of the environmental review and would

otherwise have been grouped with comments out of scope; it is retained here because it was

related to the comment above. For additional information, refer to the hydrology section of the

SER for the North Anna ESP. Accordingly, no changes were made to this EIS as a result of this

comment.
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NUREG-1811, Volume II 3-20 December 2006

Comment: The dewatering systems used during construction of the foundation of new reactors

and associated buildings would “depress the water table in the vicinity and possibly change the

direction of groundwater flow and the available capacity of local wells” (DEIS, Section 4.3.1,

lines 20-22). What would be the approximate duration of this depression, and how many local

groundwater users would be affected, including those users who might have their water diverted

from the importation that may be required (DEIS, Section 4.3.2, line 35)? (DW-0437 41)

Response: Dewatering would likely be needed in the vicinity of the reactor building during

construction of any additional units. The close proximity of Lake Anna and the discharge canal

to the drawdown point (reactor building) would limit the extent of the drawdown in the surficial

aquifer to within the boundaries of the relatively large area of the site. Any dewatering system

impacts would be local, likely confined to the existing NAPS site, and temporary during the

period of construction. Accordingly, no changes were made to this EIS as a result of these

comments.

Comment: Chapter 4, Pg 4-6, Line 12 - Can an analysis based on the groundwater available

and current information on re-charge rates be developed at this stage? (DW-1272 9)

Response: The water budget model is principally affected by operational impacts. The staff is

unable to determine the type of analysis the commenter is requesting regarding construction

impacts. Accordingly, no changes were made to this EIS as a result of this comment.

3.3.2 Surface Water Use and Quality

Comment: So what I would ask of NRC and Dominion would be to somehow publicly reassure

people if you do build these reactors that you’re not going to do anything to make the lake

significantly less usable than it is now. I think if that were done, I think you wouldn’t have the

problem with the perception and, therefore, with the potential lowering of the property values. 

I think as long as people know that you’re going to be able to use the lake normally and they

feel confident about that, then you don’t have this potential problem. (DT-0024 3)

Comment: Crucial issues that are not properly addressed in the Draft EIS include inadequate

water supplies required for the operation of another reactor, temperature increases in the lake

(and subsequent effect on fish species) and potential serious impacts on downstream aquatic

life due to reduced water flow. (DW-0401 3)

Comment: Water level and temperature changes resulting from operation of a new pair of

reactors would be regulated such that the effects would not exceed the bounds of the

environmental assessments. (DW-0370 5)
Comments Within Scope

 December 2006 3-21 NUREG-1811, Volume II

Comment: The issues addressed in the EIS concerning lake water levels and temperature,

and problems with stirring up contamination during construction are drastically under analyzed. 

(DW-0808 2)

Comment: [O]ther effects on the lake, such as temperature increases and reduced water

levels, are not fully analyzed. (DW-MM2 3)

Comment: The negative impacts of the construction process and future facility on the lake are

not fully understood, and have the potential to be devastating. (DW-0817 2)

Comment: [A]dditional power plants will have serious consequences for water temperature and

water levels at Lake Anna and the rivers that flow from it. (DW-0186 5)

Comment: More nuclear plants will have serious consequences to water temperature and

water levels at Lake Anna and the rivers that flow from it. (DT-0047 2)

Comment: Lake Anna may not be able to physically support the addition of new reactors. 

The increased water use associated with the new reactor will cause the lake level to drop

significantly. ...Lake temperature will be affected. (DW-0772 2)

Comment: Lake Anna can’t physically support the addition of new reactors. They will cause

the lake level to drop significantly and will raise water temperatures. (DW-1233 3)

Comment: These impending nuclear reactors will change the temperature of the lake where

the outflow goes and use a tremendous amount of water from an area in Central Virginia where

there is a lack of water already. (DW-0413 4)

Comment: Particularly, the DEIS has not fully examined the potential for the new reactors to

negatively impact Lake Anna through increased water temperatures, decreased lake levels and

reduced downstream water flow. These results would bring more environmental harm than that

which the NRC has characterized as “small to moderate.” (DW-1176 2)

Comment: Should Virginia experience any sustained droughts, the effects on the lake would

be more severe. Water levels can be expected to drop and temperatures rise even further. ...

Further construction near Lake Anna will disturb the environment, possibly destroying streams

and wetlands and polluting the environment with contaminants and heavy metals. (DW-0623 3)

Comment: Now Goochland County Supervisors have weighed in on the issue and determined

that the impact of another reactor on Lake Anna might lower the lake level. And many folks who

have built on the lake are opposed to expanding the power production of the plant, presumably
Comments Within Scope

NUREG-1811, Volume II 3-22 December 2006

based on safety issues. Well, to both groups I would like to point out that Lake Anna WOULD

NOT EXIST if it hadn’t been built by Dominion Power expressly for cooling the reactors. 

(DT-0063 4)

Comment: [W]e're still concluding that the supplemental DEIS has not –- is still deficient, and

not adequately analyzing that issue [of water use]. (ST-0030 3)

Comment: Building new reactors at North Anna will add further stress to the already-damaged

water resources, both local and regional water. (SE-0035 1)

Comment: It appears that there are major discrepancies in the water sections. In numerous

places the SDEIS asserts that data was lacking or simplified methodologies were used. 

(SE-0045 1)

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. (SE-0045 46)

Response: These general comments cover diverse aspects of surface water use and quality. 

Section 5.3 of this Final EIS and the responses to more specific comments, below, on water

quality, water levels, temperature, water modeling, and aquatic impacts provide additional

information and reflect the changes that were made in this Final EIS and their bases. 

Construction impacts would be limited by using best management practices. Additional

information on water budget calculations performed by the staff are included in Appendix K to

address these and other comments on water issues. Accordingly, no changes were made to

this EIS as a result of these comments.

Comment: I am also concerned that drops in water quality will adversely affect the

Chesapeake Bay, a concern that is not given enough consideration in the Draft EIS. As the

states in the Bay’s watershed are giving increased attention to the health of the bay, it would be

a grave mistake to further compromise the health of tributaries in the watershed. Decreased

water flows, increased temperature, and negative effects on vegetation and fish populations are

all likely to have negative impacts on the bay. These effects must be studied in detail and we

must be assured that the Bay’s health will not be further impacted. (DW-0617 4)

Comment: The Chesapeake Bay and its watershed are very important natural resources for

the Commonwealth of Virginia. Pollution and over fishing have had negative impacts on the

Bay that we are only now beginning to address and correct. The effect of decreases in lake

levels of Lake Anna or increases in temperatures, particularly during drought years, due to more

nuclear reactors has not been thoroughly considered for its potential effects on the Bay and its

watershed. (DW-0630 3)
Comments Within Scope

 December 2006 3-23 NUREG-1811, Volume II

Comment: [T]he need for greater efforts to preserve and restore the Chesapeake Bay

Watershed, of which Lake Anna is a part, has already been highlighted this year. Localities

have already initiated debate over a “flush tax” to pay for improvements in nutrient reduction

technology at wastewater treatment plants. The last thing the watershed needs now is

additional strain placed upon it by pollution created during the construction and operation of a

new reactor. (DW-0640 4)

Response: The staff has concluded that the additional nuclear units at the North Anna site

would not impair the water quality of the Chesapeake Bay. Additionally, any impact to the

Chesapeake Bay would be limited because of the relatively small contribution of the North Anna

River to the water volume in the Bay. The primary tributaries draining into the Chesapeake Bay

have a combined average flow of 2041 m3

/s (72,086 cfs). The streamflow gauge 45 km (28 mi)

downstream from the Lake Anna Dam reports an annual average flow of only 11 m3

/s (387 cfs). 

The change in average annual flow from the North Anna River resulting from operation of an

additional unit is not significant in comparison to the total flow into Chesapeake Bay and is not

expected to impact the health of the bay. Accordingly, no changes were made to this EIS as a

result of these comments.

3.3.2.1 Water Supply and Use

Comment: Lake Anna cannot physically support the addition of new reactors. Dominion’s

Early Site Permit application does not adequately address the increased water use associated

with new reactors, which will cause the lake level to drop significantly. (DW-MM4 2)

Comment: [C]onsider that Lake Anna is an artificial lake that was constructed to provide for

cooling of up to four reactors. The increased water use associated with the new reactor(s)

would be within the bounds of the lake’s constructed capacity. (DW-0370 4)

Comment: Water volume has been an issue with the current reactor. (DT-0054 2)

Comment: [Numerous concerns have been raised by PEC and others over] ... the ability to run

the additional reactors without creating a conflict with planned future use of the region’s water

resources. (DW-1157 3b)

Comment: As the Spotsylvania Board of Supervisors has pointed out in their proposal they

support, running nuclear plants uses vast quantities of water. This water is water that all

members of Virginia are dependent on. Building new reactors will cut into our supply and

pollute what exists. (DW-0408 4)

Comment: [T]hese are the reasons I think nuclear power is really bad. One, nuclear power

uses too much water. The nuclear reactors must draw on significant amounts of water in order

to operate and avoid a meltdown. Up to 2.5 billion gallons a day are used to cool the current
Comments Within Scope

NUREG-1811, Volume II 3-24 December 2006

nuclear reactors. Think of the mass drought us Virginians had in 2003. We couldn’t even flush

our own toilets. Think of how many toilets we could flush with 2.5 billion gallons of water. 

(DT-0008 4)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system. This revised design results in

considerably less nonconsumptive use of water and slightly less consumptive use of water. The

issues raised relevant to the general water supply in Lake Anna are addressed here. Large

volumes of water pass through nuclear power plants that use the type of once-through cooling

as evaluated in the Draft EIS, but little of this water is consumed in the process. In addition to

evaporative losses by this large water body as part of the natural water cycle, additional

evaporative losses also occur as a result of elevated lake temperatures. With a closed-cycle,

combination wet and dry cooling system, considerably less water is passed through the intake

and discharge structures. However, most of the water passing through the intakes is

consumptively used in the evaporation from the wet cooling tower portion of the revised design. 

Any contaminants in the blowdown water are regulated pursuant to 40 CFR Part 423 by the

EPA. The Virginia Pollutant Discharge Elimination System (VPDES), referred to hereafter as a

National Pollutant Discharge Elimination System (NPDES) permit, would limit the introduction of

pollutants to the water by a licensee, thereby preserving Lake Anna water quality. At the COL

stage, Dominion would be required to obtain a NPDES permit from the Commonwealth of

Virginia for operation of additional units. Accordingly, no changes were made to this EIS as a

result of these comments.

Comment: Very recently a report projected that nearby Charlottesville will run out of water by

2055 if current usage rates continue. Given the threat of a very real water shortage, it concerns

me that the cooling system for Unit 3 will have a “MODERATE” impact during droughts; what

about when there is NO water? (DW-0415 1)

Response: Lake Anna and the North Anna River do not supply water to Charlottesville,

Virginia. While the staff considered the effects of droughts, the staff does not believe that a “no

water” scenario is credible or warrants evaluation. Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: My overall conclusion on the water resource consumption issue is that this

watershed is already overtaxed by the existing reactor operations and cannot accommodate

additional water consumption by even one new reactor that uses once-through cooling or

withdrawals for evaporative cooling towers. (DW-0589 2)

Comment: Spotsylvania County recently passed a resolution against the additional reactors,

citing issues of future water supply. (DW-1157 5)
Comments Within Scope

 December 2006 3-25 NUREG-1811, Volume II

Comment: Neither the DEIS nor the proponent’s Environmental Report (ER) deals adequately

with the impact of project consumption on ecological and recreational values or on downstream

water use, in spite of issues raised by the Virginia Department of Environmental

Quality (VDEQ). (DW-0589 3)

Comment: [T]he DEIS fails to address foreseeable conflicts in water resource allocations that

would result downstream from the location of two additional reactors at the North Anna Site. 

(DW-1122 2)

Comment: The DEIS reveals that, due to a forecasted inability to meet its long-range water

resource requirements, Hanover County – the county immediately downstream from Lake Anna

– has incorporated into its Comprehensive Plan the construction of a new river intake on the

North Anna River that would withdraw the equivalent of 46 cfs of water. This would be in

addition to the 6.1 cfs currently withdrawn from the North Anna River by the Doswell Water

Treatment Plant in Hanover County. Moreover, the DEIS goes on to state that, in addition to

Hanover County, two other downstream counties are considering using the North Anna River, or

the Pamunkey River into which it flows, as future water sources to meet projected growth. 

DEIS, p.2-23. ... Despite the obvious conflicts, the DEIS provides no analysis of how these

conflicts might be resolved, simply concluding that “[a]ny future conflicts over water use fall

within the regulatory authority of the Commonwealth of Virginia.” DEIS, pp. 5-9 – 5-10. This

conclusory dismissal of the conflict as the concern of the State is an inadequate response under

both NEPA [National Environmental Policy Act] and relevant regulations. The Final EIS should

explore the issue in more detail, even to the point of recognizing that the proposed site is simply

not suitable for additional reactors due in part to irreconcilable conflicts over the use of water. 

(DW-1122 9)

Comment: [T]his projected growth and associated future water supply demand from the

North Anna River, especially in the four downstream counties, makes the accuracy of the EIS

tremendously critical. Insufficient consideration of the full potential of future water supply

demands poses a direct conflict during periods of drought, which are inevitable and have the

potential to be severe. (DW-1157 7)

Comment: What I found most interesting about legitimate comments pertaining to the EIS

during the proceedings was the impact a new nuclear power plant (or any power plant for that

matter), would have upon Lake Anna itself. I found this funny because Lake Anna would not

even be there if it were not for the two existing nuclear reactors at the North Anna Power Station

and was opposed to in the first place for its environmental impact upon the region. And now,

30 years later, people use the impact on the lake as a reason for not approving further

development. The irony is overwhelming and clearly indicates that people are too often focused

upon the negative impacts of something and not the positives. (DW-1148 4)
Comments Within Scope

NUREG-1811, Volume II 3-26 December 2006

Comment: Water issues surrounding any new nuclear power plants cooling needs are not met

under current supply scenarios at Lake Anna. NRC cannot postpone a study on the impacts

that this will have. (DW-1181 1)

Comment: At least one of these counties [Culpeper, Stafford, and Fluvanna] is relying on the

North Anna River to meet a portion of its future water demands. (DW-1157 6)

Comment: While most of the water that is withdrawn from Lake Anna is returned as hot water

in the southern portion of the lake, the Draft EIS does not state the consumptive use – how

much water is lost from evaporation – of the existing reactors. This information is crucial for

understanding the additional impact from the two proposed reactors and should be explicitly

provided in the Final EIS. (DW-0437 8)

Comment: [T]he project itself has real problems including inadequate cooling water.

...Dominion’s concession to use dry cooling for Unit 4 is indicative of the water limitations. 

(DW-0594 5)

Comment: I don’t believe you when you say the water at Lake Anna will be sufficient to cool

two additional reactors. We have already seen the water level of the lake drop dangerously low

during recent droughts. (DW-0614 4)

Comment: The Draft EIS analyzes water resource and quality impacts considering the addition

of the proposed Unit 3 as a once-through water-cooled unit and Unit 4 as a dry-cooled unit

having negligible effects on water supply (page 5-3, Section 5.3). DEQ’s Division of Water

Resources commented previously in regard to its concerns for the adequacy of Lake Anna as a

source of cooling water for a third nuclear reactor; these concerns remain. (DW-0439 9)

Comment: [T]he net water available varies greatly with the season and year-to-year variations

in rainfall. Lake Anna does not have nearly enough storage capacity to even out those

variations while maintaining the lake level within limits required for reactor cooling intake,

recreation, fishing and other objectives. It is clear from historical data and the model analysis in

the ER, as presented in Table 5.2-3 that the NPDES permit requirement of 40 cfs is not

achieved 43.9% of the time and that frequency is projected to increase to 52.4% with the

addition of Unit 3. Furthermore, even the minimum value allowed during drought conditions

(20 cfs) is not achieved 5.3% of the time and that frequency is projected to increase to 11.8%

with the addition of Unit 3. (DW-0589 11)

Comment: As stated in the DEIS (2.6.2.1 - Surface Water Use), growth in downstream

demands for water withdrawals could result in increase[d] water conflicts. Further, with three

downstream counties considering using the North Anna River as a water resource raises the

concern over an adequate water budget to accommodate additional power units at the

North Anna facility. The DEIS should include a comprehensive water budget. (DW-0422 7)
Comments Within Scope

 December 2006 3-27 NUREG-1811, Volume II

Comment: [T]he arguments made in the DEIS about water impacts in Section 5.3.2 simply

dismiss the importance of low flow impacts such as those that would occur from Unit 3 without

any cogent reasons, amounting essentially to arm waving rather than incisive analysis. The last

paragraph in that section does not logically follow from the facts presented, especially the

conclusions that impacts during severe droughts would only be moderate and that no mitigation

is required. We believe it would be highly inappropriate and arguably deceptive to proceed to

issue an early site permit while leaving all those issues insufficiently treated and apparently

unresolved until the COL process. The VDEQ also requested that the ESP not be issued until

the issues of aquatic impact are resolved. (DW-0589 15)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. Although the proposed cooling system has since been

changed to a closed-cycle, combination wet and dry cooling system as evaluated in Section 5.3

and Appendix K of the SDEIS and this Final EIS, to the extent that at least some portion of the

issues raised are still relevant to the water supply, they are addressed here.

The water use conflicts issue is a principal issue in this environmental review. Dominion revised

its consumptive water use values starting in Revision 6 of the ER to reflect the change in the

proposed cooling system for Unit 3. The effects of these revised values are evaluated in

Section 5.3. The staff performed an independent assessment of the impacts that additional

forced evaporative losses of water would have on the lake and downstream water budget. This

assessment was provided in Appendix K of the SDEIS and is included in this Final EIS. The

assessment was based on the hydrological conditions and the estimate of the rate of induced

evaporative loss listed in Appendix I from Dominion’s Plant Parameter Envelope (PPE). The

staff concluded that the induced evaporative losses associated with the operation of the

proposed closed-cycle, combination wet and dry cooling system for Unit 3 (approximately

19 cfs) would result in declines in the lake level and reductions in downstream flow. During

drought periods, the impact would exacerbate low lake levels and low downstream flow

conditions. During such drought conditions, the staff concluded the impacts would be

MODERATE. During non-drought conditions, the staff concluded the impacts would be SMALL. 

The staff did not state the impacts would be negligible. (The North Anna River is a tributary of

the Pamunkey, which is a tributary of the York River. The York River drains into the

Chesapeake Bay.).

The staff used widely accepted and validated modeling techniques in its analysis and concluded

that the lake would be sufficient to cool the additional unit using a closed-cycle, combination wet

and dry cooling system for Unit 3 and dry cooling towers for Unit 4. The staff relied on the

fundamental principle of the conservation of mass (in this case, conservation of water).

In determining the impact level, the staff considers the valuation of the water resource by the

Commonwealth of Virginia in assessing the impact. The Commonwealth of Virginia’s surface

water management area regulation is in 9 VAC 25-220. The Lake Level Contingency Plan and
Comments Within Scope

NUREG-1811, Volume II 3-28 December 2006

the license authorizing construction of the Lake Anna Dam to provide cooling water for

electricity generation are examples of two other Commonwealth-issued documents that were

considered in the evaluation of the North Anna water supply. The Commonwealth of Virginia

has jurisdiction over appropriating water. Drought conditions or increases in future water

demands could result in intervention by the Commonwealth on the apportionment of the water. 

Such intervention might include restricting activities, including plant operations, during periods

of water use conflicts. Additional information on the water budget calculations performed by the

staff are included in Appendix K of this EIS.

Comment: Page 2-22 line 30 mentions other surface water users. Have these entities been

directly consulted? (DW-0438 38)

Response: The staff met with representatives of Doswell Treatment Plant, local and county

agencies, and VDEQ staff during the course of its water use review. The outcomes of these

meetings were considered during preparation of the EIS. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: No adequate justification is provided in the DEIS or the ER for numerous deviations

from the terms of the NPDES requirements for minimum releases of water from Lake Anna, for

the conclusions about the degree of environmental impact during droughts, in the DEIS, or the

conclusion of the DEIS that no mitigation is required. The discussion about water impacts in the

DEIS appears to be perfunctory and the conclusions are not consistent with the projected water

flows and the issues raised by the VDEQ. (DW-0589 4)

Response: Reductions in flow to 0.57 m3

/s (20 cfs) from the normal minimum release of

1.1 m3

/s (40 cfs) are not violations of the existing NAPS NPDES permit. Both the 1.1-m3/s

(40-cfs) and 0.57-m3

/s (20-cfs) flows are specified in the Lake Level Contingency Plan issued by

the VDEQ. The VDEQ has the authority to specify and regulate release rates from the North

Anna Dam. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The two reactors that are already operating at North Anna withdraw 1.9 million

gallons of water per minute and then return hot water back into the lake. This utilization of

water already has a damaging effect on the lake... The proposed reactor units would mean a

great amount of additional water withdrawn per minute. It appears that it would be an increase

of 60% over current conditions. Increased heating of the water as well as increased

contamination by chemicals and radioactive particles would further degrade the water

conditions. ...Water is a necessity of life and it is not a renewable resource. How can you

blithely plan to continue to cause damage to our water supplies and our environment? 

(DW-0653 2)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the proposed change to a closed-cycle,
Comments Within Scope

 December 2006 3-29 NUREG-1811, Volume II

combination wet and dry cooling system, the quantity of water withdrawn from the lake is

substantially reduced. Cooling towers would consume water by evaporation, and the water

would be treated to minimize scale buildup and biological growth. Any change in the chemical

composition of the water would be small and would be regulated pursuant to 40 CFR Part 423

and by the NPDES permit issued by VDEQ for new nuclear units at the North Anna site. The

release of radioactive material from the plant would be negligible and within the Federal limits,

which are protective of public health and safety and the environment. Additional information

relating to water use and water quality impacts associated with the closed-cycle, combination

wet and dry cooling system is provided Section 5.3 of this EIS 

Comment: Neither the proponent’s ER nor the DEIS discuss in detail the impacts on the

North Anna River and the Pamunkey River that are likely to occur from increased periods of

below-minimum releases. While lower stretches are fed by other creeks, such as the

South Anna River, it seems likely that during drought periods those other sources of water also

will experience low flows. There is no discussion of the combined effects of low flows in those

other sources. (DW-0589 13)

Response: Drought conditions are not localized; they are typically regional with local variations

depending on such factors as topographic variations (mountains and valleys). The North Anna

and Pamunkey Rivers, and other water sources would have reduced flows during a drought. 

The operation of Unit 3 with a closed-cycle, combination wet and dry cooling system at North

Anna could aggravate low-water flow conditions associated with severe droughts, but this effect

would be limited by the proposed operating policy wherein the cooling towers would be

operated in the water conservation mode during periods of low lake level. The impacts to the

North Anna River below Lake Anna Dam during low-flow conditions are described in

Sections 5.3 and 5.4 and Appendix K of this EIS. The comment resulted in an expansion of the

discussion of the downstream impacts in those sections of this EIS.

Comment: [T]he fact that the fourth unit would be air cooled does not allay the Division’s

concern about the adequacy of Lake Anna as a water supply for a third nuclear reactor. The

Division looked at other nuclear reactors along the East Coast to compare the water resources

available to them with the water resources available at North Anna (see “Table 1,” first

enclosure to this [comment] letter). The conclusions drawn from that research are: 1) Most of

the intake locations are tidal and have an essentially unlimited water supply; 2) Of the remaining

locations, the North Anna location has the least abundant water supply, based on the average

flow of a small watershed (342 square miles) and a medium-sized reservoir; and 3) There is a

limited number of nuclear power stations located on non-tidal rivers. In these cases, the power

plants are on large rivers such as the Connecticut and the Susquehanna. In fact, the only

location remotely similar to North Anna’s situation is the Oconee plants on Lake Keowee in

South Carolina. However, immediately below Lake Keowee is Hartwell Lake, so the section of

non-tidal stream affected by consumptive loss is very short. (DW-0439 11) (SW-0017 19)
Comments Within Scope

NUREG-1811, Volume II 3-30 December 2006

Response: The staff concluded that during non-drought years there would be water in Lake

Anna sufficient to operate the proposed Unit 3 with a closed-cycle, combination wet and dry

cooling system. From the historical record, the staff determined that water availability could

have been an issue during 3 years of the 24-year period (from 1979 through 2002). The

adequacy of the water supply for a power station, whether it is nuclear or fossil fueled, is a

site-specific determination based on the plant design and the hydrological considerations of the

site. Although information from other regions and other watersheds may provide insights, the

analysis must be site specific such as that performed in this EIS. Additional information on the

water budget calculations performed by the staff are included in Appendix K of this EIS.

Comment: This DEIS wording is inconsistent with ER Table 3.1-9 which describes the cooling

water withdrawal rate of 1,140,000 gpm as a nominal design coolant flow. Actual maximum

circulating water flows would be dependent on the specific design of the circulating water

pumps, but would be within a few percent of this value. [page 3-7, line 3-4] (DW-0423 19)

Comment: This DEIS wording is inconsistent with ER Section 5.2.1.2. The average annual

evaporative loss is estimated to be 29 cfs, which assumes Unit 3 operates at a 100% plant

capacity factor. [page 3-8, line 15] (DW-0423 20)

Response: With the change from a once-through cooling system to a closed-cycle,

combination wet and dry cooling system, these comments (by Dominion) about proposed Unit 3

are no longer relevant. Accordingly, no changes were made to the EIS as a result of these

comments.

Comment: Regarding slide labeled “Lake Anna Usage” presented during Mary Ann’s [Mary

Ann Parkhurst, PNNL Project Team Leader] comments [during the February 17, 2005, public

meeting]. Residential was not listed–this is something I do not understand. Recreation is

occasional while residential is a 24/7 piece of the setting. Residential should be listed. 

(DT-0055 1)

Response: The presentation illustrated consumptive use of Lake Anna and recreational and

fishing use whether by residents of or visitors to the Lake Anna area. Water use impacts on

residents in the Lake Anna area were specifically discussed in the socioeconomics analyses in

this EIS, primarily within the context of property values. Accordingly, no changes were made to

this EIS as a result of this comment.

Comment: [P]eople talk about the improvement in the plan from the earlier plan, which was

flow-through cooling to the wet/dry tower cooling. And from what I've heard tonight, what we're

sacrificing for that is water. It's going to cost us more water, and I'm concerned about that. 

(ST-0007 2)
Comments Within Scope

 December 2006 3-31 NUREG-1811, Volume II

Comment: [T]he proposed reactors will further increase water evaporation from Lake Anna.

Lower lake and downstream water levels will threaten lake recreation, downstream fisheries,

and drinking water supplies. (SE-0034 2)

Comment: [I]ncreased water evaporation from the new reactors, and the effect of this water

loss on lake levels and on the downstream flow into the North Anna River, have not been

resolved. (SE-0035 3)

Comment: Evaporative cooling towers will siphon off an enormous amount of water,

continuously. ...The withdrawal of huge amounts of water from these relatively small reservoirs

fed by a relatively small watershed will most certainly adversely affect the local environment

especially the waterfront. During periods of low rainfall, drought, reservoir levels have

dramatically lowered reducing the existing surface acreage for "natural" evaporative cooling. 

(SW-0015 2)

Comment: The SDEIS does not deal adequately with the impact of project consumption on

ecological and recreational values or on downstream water use...There is no adequate

justification for the conclusions about the degree of environmental impact during droughts, or

the conclusion that no mitigation is required. (SE-0038 4)

Comment: Will this increase water usage create any problems with the entire watershed and

possibly increase drought cycles? (SE-0003 11)

Comment: [T]he North Anna watershed is too small to allow large water withdrawals. These

would adversely affect the beneficial uses of the North Anna River which flows into the

Pamunkey River, which flows into the Chesapeake Bay and then into the Atlantic Ocean. The

DGIF &VDEQ analysis clearly indicates that the 3rd unit would increase the drought cycle and

cause decreased water flows during March, April, May, June, July, August and October

(7 months) of each year. (ST-0014-5) (SE-0022 9)

Comment: We request that Lake Anna not be considered as a source for future municipal

water supply. (SW-0004 5)

Comment: If there is ever any thought of using the North Anna River or Lake Anna water for

future Louisa County water needs, now is the time to put the request into VDEQ and identify the

need. (SW-0005 8)

Comment: Both Louisa and Spotsylvania Counties have been designated in the top 100

fastest growing in the U.S. Both counties rely on wells and septic tanks for the majority of their

water supply. With the major increased growth projected and demand for water resources, it

would be reasonable to project that one or both counties may look to Lake Anna (the 3rd largest
Comments Within Scope

NUREG-1811, Volume II 3-32 December 2006

lake in the state) as a water source for drinking water and public use. How will the new 3rd and

4th reactors (if built) diminish either counties ability to use the lake as a future water source for

pubic water consumption? (SE-0003 4)

Comment: One set of the North Anna River Users should not benefit at the expense of another

set of users. Whatever, the final solution is for not decreasing the inadequate water supply in

the small water shed; the solution should not benefit one set of users at the expense of another

set of users. For example, the lake levels should not be raised which could cause property

damage to lake owners to quarantine more water so it could 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. (SE-0022 14)

Comment: [T]he Supplemental Draft EIS acknowledges that several communities along the

North Anna and Pamunkey Rivers are contemplating using the rivers as a source of drinking

water. This could create a conflict between water uses, with evaporative loss at the North Anna

nuclear plant interfering with downstream communities' ability to rely on North Anna and

Pamunkey Rivers for drinking water. While the ultimate resolution of this potential conflict may

be up to the Commonwealth of Virginia, the NRC is obligated to fully evaluate the potential for

such a conflict in the final EIS. (SE-0046 4)

Comment: 3.3.2.9-S. The Final EIS must fully analyze the consumptive water use for the

proposed closed-cycle, wet-dry Unit 3. Issues associated with water quantity and quality and

potential conflict over water use are still unresolved. Resolution of these issues should have

been accomplished prior to the NRC's stated position that the site preparation and preliminary

construction activities would not result in any significant adverse environmental impacts that

cannot be redressed. (SW-0017 4)

Response: The water use conflicts issue is a principal issue in this environmental review. In a

water budget, as with all other budgets, a finite resource is allocated to serve multiple

objectives. The management of water resources involves balancing tradeoffs among these

multiple conflicting objectives. In the case of the Lake Anna and North Anna River water

resource, these objectives include: providing water for current and likely future downstream

water users, providing water for downstream habitat, maintaining relatively stable lake levels,

and providing a reliable water supply for industrial facilities including the existing NAPS and

proposed Unit 3.

The staff make no attempt to balance these tradeoffs. Rather, the staff simply disclosed the

impacts. Establishing policies that balance water-related tradeoffs is the responsibility of the

Commonwealth of Virginia. Construction and operation of a plant at North Anna is predicated
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 December 2006 3-33 NUREG-1811, Volume II

on obtaining a variety of water related permits and certifications from the Commonwealth of

Virginia that are independent of a decision on this ESP application by the NRC.

In order to estimate impacts, the staff must rely on available information and past and existing

policies. The Lake Level Contingency Plan was considered by the NRC staff in the evaluation

of the North Anna water supply. Low flow releases from the dam are prescribed by the VDEQ in

the Plan. The policy of decreasing the release from 40 cfs to 20 cfs as the lake level drops

below 248 feet above mean sea level (MSL) is prescribed by VDEQ. The staff acknowledges

that water conflicts could increase due to the reduction in the water supply as result of

consumptive water losses from the operation of proposed Unit 3. These impacts would be

greatest when the available water supply is already limited because of climatic factors. Drought

conditions or increases in future water demands could result in intervention by the

Commonwealth in the apportionment of the water. Such intervention might include operational

restrictions during periods of water use conflict. The staff’s assessment related to water-related

impacts is documented in Section 5.3 and in Appendix K of this EIS. Accordingly, no changes

were made to this EIS as a result of these comments.

Comment: [Regarding Dominion’s ER] Section 2.3.1.1 Make-up water minus Blowdown

discharge equals 37.2 cfs (38.8 cfs @ 100%). This evaporation loss of make –up water is

almost equal to the discharge from the dam at 40 cfs. The removal of 49.6 cfs (51.7 cfs @

100%) for make-up water is a huge amount of water from the reservoir. Current Lake Anna

storage to 250 ft msl is 305,000 acre- feet or 99,400 million gallons of water. With 4246 cfs

(1.9 million gallons per minute ) discharge from Plant 1 and 2 (reference par 3.4.2.2 page

3-3-68) plus 51.7 cfs added from plant 3 for a total of 4297.7 cfs (1.93 million gallons per

minute), the entire lake volume is pumped every 36 days or about once a month. (SE-0004 8)

Response: The values of 37.2 cfs and 49.6 cfs mentioned in the comment are the maximum

instantaneous evaporation rate and the maximum instantaneous makeup water withdrawal rate,

respectively, for proposed Unit 3. (Because these are instantaneous maximums, the correction

for the 96 percent average load factor is not appropriate.) During EC mode operation, the

spillway would spill water downstream. Once the elevation drops below 250 ft, the spill ends,

the release from the dam is set to 40 cfs, and the plant enters MWC mode. Therefore, the

evaporative losses are generally greatest when the dam is already spilling a large amount of

water downstream. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The draft SEIS ... mischaracterizes the potential future [Hanover] County water

supply alternatives. The information submitted by Dominion indicated the County considered

multiple water supply options and retained two in the Comprehensive Plan. What was not

mentioned was that one of the rejected options was a run-of-the-river withdrawal, which appears

to be the option evaluated in the SEIS [Section 5.3.2, also in 7.3] since it equates the potential

future County withdrawal with the Lake Anna minimum releases. The alternatives included in

the County’s Comprehensive Plan, and addressed in more detail in the County’s Long-Range
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NUREG-1811, Volume II 3-34 December 2006

Water Resources Planning Study, both include the use of a quarry for off-stream storage, with

pumping to the quarry to be done during high flow conditions. Thus the comparison to minimum

releases is not relevant. A more helpful evaluation would be the affect on mean annual flow in

the North Anna River and its safe yield so the impact on the off-stream storage option can be

evaluated. (SE-0048 2)

Response: The staff agrees. The comparison of the minimum instream flow to the targeted

demand for Hanover County does not properly characterize the demand since any withdrawals

from the river could be supplemented with off-stream storage. Consequently, the text in

Section 5.3.2 has been revised. 

Comment: DEQ's Division of Water Resources commented previously in regard to its concerns

for the adequacy of Lake Anna as a source of cooling water for a third nuclear reactor because

the Lake Anna watershed is relatively small (342 square miles). ...Although the wet-dry cooling

method would withdraw less water than a once-through unit, addition of a wet-dry Unit 3 would

still increase the drought recurrence interval (from 6% for units 1 and 2 operating to 11% with a

wet-dry Unit 3 operating; it would increase to 11.8% with addition of Unit 3 as a once-through

unit) as well as increase the total weeks of flows that are 20 cubic feet per second (SDEIS

page 5-10, section 5.3.2). Unlike the existing NAPS once-through units, the majority of the

water withdrawn for Unit 3 condenser cooling would be consumed by the wet towers while

operating in the energy conservation mode, which is for most of the year as currently proposed

by the applicant. As stated in the SDEIS (page 5-10, section 5.3.2), consumption of water by

the wet towers would reduce the overall volume of water in the lake, thereby impacting the

quantity of water released at Lake Anna dam. (SW-0017 3)

Response: The principal environmental benefit associated with the wet-dry cooling method

system is in reducing the thermal impacts to Lake Anna. The improvement due to the reduction

in consumptive water losses would be modest with the wet-dry design. However, it is expected

that less consumptive water loss would result than with a once-through cooling system during

critical periods of extended low lake level where the plant could remain in MWC mode for long

periods. In Dominion’s analysis, all condenser cooling was assumed to be provided by dry

cooling (i.e. no consumptive water loss) when the air temperature was less than 67(F. This

could significantly reduce impacts in persistent low water periods that extend into cooler

months. The text of Section 5.3 has been revised to provide an expanded description of the

differences between Dominion and the staff’s estimate of the impacts.

3.3.2.2 Water Quality

Comment: [W]hat is this third unit going to be doing to our lake? We need to have some

baseline as to what the two units that are operating are doing to the lake. (ST-0002 4)
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 December 2006 3-35 NUREG-1811, Volume II

Response: The impacts associated with the operation of Unit 3 on Lake Anna are discussed in

Section 5.4.2. Baseline data, including both physical measurements and biological sampling,

have been collected from Lake Anna since its creation. The staff believes that sufficient

baseline data, summarized in Section 2.7.2, are available. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: There are already high levels of PCBs, polychlorinated biphenyls, in the lower lake. 

These chemicals are known to cause cancer and nervous system disorders. This situation is

likely to worsen if a nuclear plant is constructed and becomes operational. (DT-0047 4)

Comment: [Numerous concerns have been raised by PEC [Piedmont Environmental Council]

and others over] existing contaminants in the lake (PCB’s). (DW-1157 3a)

Response: The staff did not find a relationship between PCBs in the lake and the existing

nuclear facility. Some of the highest concentrations of PCBs have been observed in the upper

reaches of the lake that could not have been influenced by NAPS operations. This suggests

that the source of PCBs is in the upper portion of the watershed that drains into Lake Anna. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: [Referring to Dominion’s Site Safety Analysis.] Section 4.4.1.1.4 - Recreational

Facilities - This information also mentions installing a barrier to prevent the migration of turbid

water plume into the lake, if necessary. This should be a requirement based on Dominion’s

commitment to public safety and health measures and today’s environment concerning potential

hazardous risks to the public. (DW-0191 8)

Comment: The draft Environmental Impact Statement states that construction activities

permissible under the ESP may stir up heavy metals and other contaminants in the lake

sediment, while details about mitigation measures are murky. (DW-MM2 2)

Comment: According to the Draft EIS, the greatest construction impact on the aquatic

environment of Lake Anna would come from the construction of the new cooling water intake

structure and channel (DEIS, Section 4.4.2, lines 35-36), which would require activities such as

dredging that could result in a loss of habitat (DEIS, page 4-12) as well as the possible

resuspension of heavy metals left from mining activities. The mining runoff had previously

contaminated Contrary Creek and parts of the North Anna River downstream such that virtually

no aquatic life existed, and the contaminants may still remain in the region’s sedimentation

(DEIS, pages 4-12 and 4-13). The Draft EIS notes that any potential impacts from these

activities “would be addressed through the Clean Water Act Section 404 permit and Section 401

verification process” (page 4-13, lines 22-24). Is this considered a mitigation measure? 

(DW-0437 42)
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NUREG-1811, Volume II 3-36 December 2006

Comment: Dredging and other construction allowed under an ESP may also resuspend PCBs,

which are known contaminants in Lake Anna. A full analysis of PCBs in the sediments near the

site and the impact of construction should be included in the Final EIS. (DW-0437 43)

Response: Changes to the cooling system for Unit 3 from a once-through system to a

closed-cycle, combination wet and dry cooling system would reduce the size of the intake

structure needed and, therefore, would reduce the effect of dredging from the level evaluated in

the Draft EIS. Dredging for the proposed intake structure is expected to be very localized,

largely resulting from the complete or partial removal of the cofferdam. Prior to any construction

activities that could result in discharges from the North Anna site that might affect water quality,

the applicant would be required to obtain a Commonwealth of Virginia NPDES Construction Site

Stormwater Permit. Typically, impacts from construction activities related to surface water are

temporary, minor, and easily mitigated. The authority for protecting the nation’s nonradiological

water quality resides with the EPA under the Clean Water Act, and that statute prohibits the

NRC from intruding into such water quality matters. As permitted under the Act, the EPA has

delegated this authority to protect water quality to the Commonwealth of Virginia. Under the

Clean Water Act, issues involving dredging are the responsibility of the U.S. Army Corps of

Engineers (ACE). Issues of resuspension of PCBs, heavy metals, and sediment would be

addressed through the permits issued by VDEQ and the ACE. Issuance of an ESP would not

change the requirements for the applicant to obtain permits from the VDEQ and ACE. Sections

4.4.2 and 4.10 of this EIS address mitigation measures including installation of a turbidity

curtain to minimize the impacts of entrained sediment on the WHTF. Accordingly, no changes

were made to this EIS as a result of these comments.

Comment: This DEIS wording is inconsistent with DEIS Sections 5.4.2.6 and 5.4.2.7 and

ER Sections 5.3 and 5.10, which do not specify the need for a barrier (e.g., a turbidity curtain or

sheet piling) or some form of protection during operation. [page 4-13, line 28] (DW-0423 24)

Response: The wording in this EIS has been revised to reflect that a turbidity curtain or sheet

piling would be used during dredging. The reference to operations has been removed.

Comment: Suggest that this DEIS statement reflect that the creation of Lake Anna has

mitigated most adverse water-quality impacts from Contrary Creek area runoff, yielding a

beneficial effect in the drainage basin. [page 4-13, line 14] (DW-0423 23)

Response: The existence of Lake Anna and its impacts on water quality related to Contrary

Creek effluents are outside the scope of the ESP review. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: Page 4-44 line 32 change the word “may” to “would” [in relation to Dominion’s

statement that it may install a barrier between the ESP site and the lake to reduce the potential

for silt and soil entrainment through the existing units to the WHTF.] (DW-0438 119)
Comments Within Scope

 December 2006 3-37 NUREG-1811, Volume II

Comment: A full analysis of the water quality impacts should be included in the Final EIS,

including the list of effluents and discharge levels for Units 1 and 2 allowed under the current

VPDES permit, as well as the list of expected effluents and discharge levels for Units 3 and 4. 

(DW-0437 27)

Comment: As a general comment, one of the most fundamental issues involved in determining

the suitability of the North Anna site for additional nuclear units is the impact that the operation

of the additional units would have on water quality standards for Lake Anna and the North Anna

River, including the need to protect designated and existing uses. Designated uses of the North

Anna River include recreational uses, the propagation of aquatic life, wildlife uses, and the

production of edible natural resources. Any failure to maintain these existing uses within the

river would constitute a violation of State water quality standards and the anti-degradation policy

of Section 303 of the Clean Water Act (CWA). 33 U.S.C. 1313. (DW-1122 4)

Response: The existing uses of Lake Anna and the North Anna River should be preserved. 

Sections 4.3 and 5.3 of this EIS address the principal water quality parameters likely to be

affected by construction and operation of any additional units at the North Anna ESP site. The

authority for protecting the nation’s nonradiological water quality resides with the EPA under the

Clean Water Act, and that statute prohibits the NRC from intruding into such water quality

matters. As permitted under the Act, the EPA has delegated this authority to protect water

quality to the Commonwealth of Virginia. Part of its enforcement authority allows Virginia to

regulate construction and industrial stormwater impacts through the NPDES program and to

specify water quality monitoring programs. Recognizing that NRC authority is limited to

weighing the environmental effects of the proposed action, including the degradation, if any, of

water quality, and considering alternatives to the proposed action that are available for reducing

adverse effects, the NRC staff is confident that the Commonwealth of Virginia will specify water

quality limits in any future NPDES Storm Water and NPDES discharge permits that would be

protective of the environment and would be consistent with the Commonwealth’s water quality

standards. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Although the DEIS acknowledges that the operation of additional units will increase

the amount of heated effluent released into the lake, it fails to address whether or not the

additional heated effluent will result in violations of the maximum temperature thresholds

allowed by State regulations. (DW-1122 7)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, thermal discharges to the WHTF would be

substantially reduced, and heating of the lake would be negligible. A COL applicant referencing

an ESP would be required to obtain a NPDES permit from the Commonwealth of Virginia. As

permitted under the Clean Water Act, the EPA has delegated the authority to protect water

quality to the Commonwealth of Virginia. Part of its enforcement authority allows the
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NUREG-1811, Volume II 3-38 December 2006

Commonwealth to regulate construction and industrial stormwater impacts through the NPDES

program and to specify water quality monitoring programs. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: What about the environmental degradation of the lake? (DW-0729 5)

Response: The staff evaluated the water quality related impacts associated with additional

units at the NAPS site in Sections 4.3 and 5.3. The only significant impact to the lake is

expected to be a decrease in the pool elevation during dry periods. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: Has VPDES [VDEQ] been contacted about the possibility of adding biocides,

antiscalants, and dispersants into the water? (DW-0806 7)

Response: The NRC has not contacted the VDEQ, which performs VPDES reviews, about

additives. The staff is not aware of any discussions between Dominion and VDEQ regarding

the use of biocides, antiscalants, and dispersants in the water. A COL applicant referencing an

ESP would be required to obtain a NPDES permit from the Commonwealth of Virginia. 

Blowdown constituents are regulated by the EPA pursuant to 40 CFR Part 423. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: Has VDEQ been contacted with respect to the additions of units 3 and 4 about the

increased water temperature of the Lake and the lower Dissolved Oxygen levels? Will VDEQ

set a maximum temperature for water re-entering the reservoir [from] the WHTF at Dike 3 as a

part of their discharge permit? (DW-0806 10)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, thermal discharges to the WHTF would be

substantially reduced, and heating of the lake would be negligible. The NRC met with VDEQ on

January 19, 2005, to discuss the staff’s findings in the Draft EIS. VDEQ has provided

comments on the Draft EIS and the SDEIS. As permitted under the Clean Water Act, the EPA

has delegated the authority to protect water quality to the Commonwealth of Virginia. The

VDEQ has not indicated to NRC staff that it has a plan to set a maximum discharge temperature

limit. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Despite the significance of this issue to the question of site suitability, the DEIS fails

to undertake any serious analysis of compliance with water quality standards. The

recommendation that an ESP be issued is therefore premature. At the very least, any ESP

issued should state that it is expressly conditioned upon a subsequent determination by the

State that the proposed operations will comply with all State water quality standards, and that it

is invalid without such a State determination. (DW-1122 5)
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 December 2006 3-39 NUREG-1811, Volume II

Response: In 10 CFR 51.10(c), the NRC recognizes that responsibility for regulating

non-radiological pollution discharges rests with the EPA, who may and has delegated this to the

Commonwealth. Therefore, the NRC cannot impose non-radiological water quality conditions in

an ESP. Pursuant to Section 401 of the Clean Water Act, the NRC cannot issue an ESP

authorizing the discharge of non-radiological pollutants into any receiving water body unless the

applicant first obtains a Section 401 certification; in this case it must be obtained from VDEQ. 

The Section 401 certification by the Commonwealth of Virginia assures that the project is not

incompatible with Virginia’s water quality goals. In its October 6, 2005, response to an NRC

request for additional information regarding the status of the Section 401 certification, Dominion

requested an ESP permit condition to preclude undertaking any preconstruction activity that

would result in a discharge to navigable waters without either first receiving a Section 401

certification from the Commonwealth of Virginia or receiving a waiver from the Commonwealth. 

The proposed permit condition is included in Appendix J. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: [M]akeup water for [the Unit 3] tower would be treated with biocides, antiscalants

and dispersants. The SDEIS does not appear to contain an adequate discussion of the

treatment of the blowdown or the potential effects of the blowdown on Lake Anna and

downstream ecological resources. (SE-0038 5)

Comment: The chemicals that they talk about adding [to the Unit 3 cooling system], some of

them are phosphates, and this combined with the high temperatures can cause algae blooms. 

(ST-0028 6)

Comment: Lake Anna is already impaired and adding to the PCBs in the lake would be

reckless and dangerous to residents living in Central Virginia, as well as those living along the

North Anna River, the Pamunkey River, the York River and the Chesapeake Bay Region. 

(SW-0021 1)

Comment: Blowdown from unit 3 would be 12.9 cfs at 100 F for 100% reactor power.

Chemicals will be added including Phosphates. This combined with the temperature could

affect the algae bloom. Phosphates should not be used. (SE-0027 5)

Comment: [Regarding Dominion’s ER] Par 5.3.2.1 page 3-5-55 When discussion is made

relative to “extreme summer months” by Dominion, the blowdown should be based on 100%

reactor operations and not 96% as implied. We do not agree with Dominion’s statement

“blowdown discharges etc of Unit 3 would have very small, if not imperceptible, physical,

chemical, biological or ecological impacts to Lake Anna”. We believe the small impounded

(not free flowing river) reservoir of Lake Anna will be affected by the additional water

consumption due to “blowdown” which will add to the thermal heating of the water. Dominion

plans to add chemicals to the water, which would affect the biological and ecological character

of the water. (SE-0007 1)
Comments Within Scope

NUREG-1811, Volume II 3-40 December 2006

Comment: We request that the discharge of sewage effluent into Lake Anna be prohibited. 

(SW-0004 6)

Comment: [O]n page 7.4 of the EIS supplement, it is Chapter 7 of the Cumulative Impacts of

the entire operation...on the issue of water use and water quality, it says, "Water quality is

unresolved." ...[after] all the changes that are proposed, it's still hard for me to understand why

water quality is still unresolved. (ST-0035 2)

Response: The staff evaluated the water quality related impacts associated with additional

units at the NAPS site in Sections 4.3 and 5.3. The only significant impact to the lake is

expected to be a decrease in the pool elevation during dry periods.

The staff did not find a relationship between PCBs in the lake and the existing nuclear facility. 

Some of the highest concentrations of PCBs have been observed in the upper reaches of the

lake that could not have been related to NAPS operation. This suggests that the source of

PCBs is in the upper portion of the watershed that drains into Lake Anna. There is nothing that

suggests a new nuclear unit at the North Anna ESP site would add to the PCBs already in the

lake.

A COL applicant referencing an ESP would be required to obtain a NPDES permit from the

Commonwealth of Virginia. Discharges of effluents such as phosphate and the treated output

of the sewage treatment plant would be regulated by VDEQ through the VPDES permit

program. Blowdown constituents are regulated by the EPA pursuant to 40 CFR Part 423. 

While the staff reasonably anticipates that the discharge limits established by the VDEQ in an

VPDES permit would protect the waters of Lake Anna as required by the Clean Water Act, the

staff is specifically precluded from basing a NEPA impact conclusion on the mere fact that an

NPDES permit will be issued with respect to the resource under consideration. Because

Dominion did not provide specific information on station effluents other than for blowdown, the

impact is unresolved. Accordingly, no changes were made to this EIS as a result of these

comments.

3.3.2.3 Water Temperature

Comment: [I]t should not be necessary to refer to Dominion’s Environmental Report in order to

make sense of the EIS; the relevant temperature modeling tables should be included in the

Final EIS. Please also indicate whether (and if so, how) NRC Staff independently verified

Dominion’s modeling results. (DW-0437 18)

Comment: Page 5-5 line 15 discusses a methodology that was used to estimate evaporation

rates. Was the higher Lake temperature to be expected from the proposed Unit 3 included in

this analysis? (DW-0438 129)
Comments Within Scope

 December 2006 3-41 NUREG-1811, Volume II

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, thermal discharges to the WHTF would be

substantially reduced, and heating of the lake would be negligible. The discharge temperature

and flow from the closed-cycle, combination wet and dry cooling system were used in the

calculations. The staff independently reviewed Dominion’s modeling results as a starting point

and agrees that its model is calibrated for the existing information. Nevertheless, the staff

elected to conduct its own modeling as part of its independent assessment. The staff’s

modeling process, calculations, and results are provided in Appendix K of this EIS.

Comment: Considerable discussion is made of temperatures at various locations in the lake. 

Fundamental thermodynamics indicates that the additional heat to be dissipated by a new

power plant will be less than or equal to the flow rate of water that would need to be evaporated

to produce an equivalent latent heat of vaporization. As long as the flow rate of water needed

for total heat dissipation is less than the average flow rate into the lake, it is evident that water

temperature deviations within reason can be managed by engineered structures. If any lake

temperature issues are evaluated to be other than SMALL, the licensee should be afforded and

[an] opportunity to address the particular local issue with additional engineered structures or

systems. (DW-0645 4)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. Dominion can propose additional structures and

systems to further mitigate thermal impacts at any time. However, with the change in the

proposed cooling system for Unit 3 to a closed-cycle, combination wet and dry cooling system,

the increase in the temperature of the discharge from Unit 3 would not be significant, and any

basis for mitigation would not be related to the Unit 3 discharge. Accordingly, no changes were

made to this EIS as a result of this comment.

Comment: My question is about the heat load on the lake...The load on that portion of the

cooling lagoons is roughly a megawatt per acre. Do you propose to increase that heat load to,

say, one and a half megawatts? (DT-0003 1)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and the discharge temperatures relative to the existing

discharge from Units 1 and 2 or the proposed Unit 3. Although the proposed cooling system

has since been changed to a closed-cycle, combination wet and dry cooling system, to the

extent that at least some portion of the issues raised are still relevant to the water supply, they

are addressed here.

First, the NRC staff does not propose to increase heat loading to the WHTF. The proponent of

the action is Dominion; the NRC has a regulatory and licensing role to consider the proposal

presented by the applicant. Second, merely dividing the amount of heat entering the WHTF by
Comments Within Scope

NUREG-1811, Volume II 3-42 December 2006

the area of the WHTF is a simplistic representation of several complex processes. With the

closed-cycle, combination wet and dry cooling system, the additional heat load to the WHTF

would not be significant. In general, the heat load to the WHTF would increase at different rates

depending on environmental conditions, the number of units operating, the operating practices,

and the flow rate to the WHTF. However, the additional heat load to the WHTF from Unit 3 is

not considered significant relative to the heat load from NAPS Units 1 and 2. Accordingly, no

changes were made to this EIS as a result of these comments.

Comment: I am a resident whose property abuts the waste heat treatment facility of the

North Anna nuclear plant (known as the “hot side” of Lake Anna). I am writing to oppose the

use of additional water from Lake Anna to cool a third unit at the North Anna plant, as

envisioned by the draft environmental impact statement issued in connection with the

North Anna ESP. I oppose the use of water from Lake Anna mostly because it would increase

the water temperature in the waste heat treatment facility by 5 to 15 degrees. I purchased my

lot about three years ago based on the water being about 10 degrees warmer than the main

lake (known as the “cold side” in local vernacular). I found that acceptable. I do not find it

acceptable for that temperature to be increased by another 5 to 15 degrees. That would make

the water unusable for water sports for at least two months of every year and would chase the

fish to the cooler areas of the lake, making fishing useless. (DW-0190 1)

Comment: I don’t really think you really adequately addressed the effect of the increased

temperatures in the waste heat treatment section and in Section 3.22. Maybe you didn’t have

the data available, frankly, and that was in the [V]DEQ database, but there really will be a

moderate, not just a small environmental impact, and we’ve done a lot of research on this, Jack

[Cushing, NRC Environmental Project Manager], I think, because the temperature in that -- and

you may not have had this data actually -- many times between June and August, particularly,

the temperatures we have actually measured with real accurate Hydrolab instruments and

whatnot can very accurately measure down to a tenth of a degree Fahrenheit. The temperature

has often run from 93, 96 degrees. (DT-0029 4)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and the discharge temperatures relative to the existing

discharge from Units 1 and 2 or the proposed Unit 3. The proposed cooling system has since

been changed to a closed-cycle, combination wet and dry cooling system, which would have a

discharge temperature comparable to Units 1 and 2. The discharge flow, however, from Unit 3

would be less than 1 percent of the combined Units 1 and 2 flow.

The ER provided limited temperature data on the WHTF, which the staff did use in its analysis. 

The WHTF facility was licensed by the Commonwealth of Virginia as an industrial waste heat

treatment facility and, consequently, Dominion is not required to meet water quality standards

within the extent of the WHTF. While Dominion allows limited access to the waters of the

WHTF by residents, it is considered by the Commonwealth to be part of the industrial complex. 
Comments Within Scope

 December 2006 3-43 NUREG-1811, Volume II

Dominion’s proposed change in the cooling system for Unit 3 to a closed-cycle, combination wet

and dry cooling system would reduce the thermal discharge to the WHTF. A maximum

temperature increase of about 0.1(F is predicted in Lake Anna, and the Unit 3 thermal

discharge would not have a significant impact on the temperature of the WHTF. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: The maximum discharge temperature based on site characteristics would not

exceed 113(F (maximum inlet temperature of 95(F plus maximum condenser temperature rise

of 18(F from PPE). The PPE value of 127(F is not relevant in this instance. [page 3-7, line 1] 

(DW-0423 18)

Comment: Page 3-7: “Based on the PPE, the maximum temperature increase between the

intake and the discharge will be 10(C (18(F) and the maximum discharge temperature will be

52.8(C (127(F). Dominion specified in the PPE that the flow rate through the condenser will not

exceed 71,900 L/s (1,140,000 gpm).” I would like to see the basis for the 127(F conclusion

more explicitly spelled out. I believe the number is in error (too high) and does not appear to be

supported by the information in the ESP application. (DW-0826 1)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and the discharge temperatures relative to the existing

discharge from Units 1 and 2 or the proposed Unit 3. The proposed cooling system has since

been changed to a closed-cycle, combination wet and dry cooling system, which would have a

maximum discharge temperature of 100(F. Accordingly, no changes were made to this EIS as

a result of these comments.

Comment: The PPE methodology discussed on page 5-6 line 39 is too simplistic. Since both

ambient and water temperatures are hotter during the summer, a seasonal analysis should be

done. This would also permit better analysis of the temperature impacts on aquatic species

since their activities can be seasonal (Section 5.4.2.7 states that cool months would have

SMALL impacts on striped bass). (DW-0438 134)

Response: The staff conducted its independent assessment using seasonal temperature data

and the projected discharge temperature and volume from Unit 3 with a closed-cycle,

combination wet and dry cooling system. The process, calculations, and results of this

modeling are provided in Section 5.3.3 and Appendix K of this EIS.

Comment: What happens to temperatures and lake levels with the third plant operating? ... No

discussion in the ESP is presented as to how many units will be expected to operate at any

time. Will the EIS discuss the maintenance plan for the overall NAPS and to what percentage of

the time will all or some of the plants be running compared to existing Units 1 and 2’s history? 

(DW-0806 11)
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NUREG-1811, Volume II 3-44 December 2006

Response: The staff based its independent assessment on existing Units 1 and 2 with

once-through cooling systems and proposed Unit 3 with a closed-cycle, combination wet and

dry cooling system while operating at full load. This scenario results in the most conservative

assessment for postulating the effects on lake level. (Unit 4 would be air-cooled and would not

affect the lake.) This EIS does not discuss maintenance plans as part of this assessment

because any maintenance activities that involve derating or shutting down one or more units

would result in less adverse impacts on lake level and temperature. Therefore, the staff’s

analysis is conservative. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: Page 2-21 line 40 discusses that limited data is available. Why have no dye

experiments been done and the information used? Since hydrology is a key site characteristic

and not an operating parameter, deferring velocity flow measurements to the CP/COL stage is

not good science or proper EIS procedure. (DW-0438 37)

Comment: NRC should require Dominion to provide the necessary temperature and velocity

measurements for the Final EIS, and not wait until the COL stage (page 5-7, line 19). 

(DW-0437 6)

Response: Specific design information is not available at the ESP stage when the applicant

elects to use a PPE approach. The staff performed its assessment based on Dominion’s PPE

values for induced evaporation and maximum discharge temperature after concluding that

Dominion’s estimate of evaporation was not unreasonable. However, a COL applicant

referencing the ESP would need to demonstrate that actual plant characteristics fall within the

PPE values. Based on these comments, changes were made to Section 5.3.1 of this Final EIS.

Comment: The site can hardly be deemed suitable for additional units until it can be

determined whether Dominion will be able to discharge in compliance with existing temperature

standards or obtain another 316(a) variance for the impact that heated effluent from the

additional units will have on the lake. Consequently, the Final EIS must discuss Dominion’s

ability to meet temperature standards, as well as the need for - and likelihood of obtaining - a

further 316(a) variance. (DW-1122 8)

Response: The NRC is responsible under NEPA to assess the potential impacts of the

proposed action, including water quality. The EPA has the authority to regulate water quality

under the Clean Water Act, and that statute prohibits the NRC from intruding into such water

quality matters. EPA has delegated its authority to the VDEQ to enforce water quality

regulations in the Commonwealth of Virginia. Consequently, the VDEQ is responsible for

determining whether Dominion is able to comply with existing State water quality standards. 

Dominion is responsible for obtaining a Clean Water Act Section 316(a) variance from the
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 December 2006 3-45 NUREG-1811, Volume II

VDEQ. Part of VDEQ’s enforcement authority allows it to specify water quality monitoring

programs. The WHTF facility for Units 1 and 2 was licensed by the Commonwealth of Virginia

as an industrial waste heat treatment facility; as a result of that designation, the Commonwealth

does not require that Dominion meet water quality standards within the WHTF. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: There are several points throughout the DEIS where the finding that a particular

impact will be small is heavily, or even exclusively, based on the fact that Dominion is expected

to comply with the Clean Water Act and other statutes. See, e.g., Sections 4.4.2 (Aquatic

Ecosystems), 5.3.3 (Water-Quality Impacts), and 7.3 (Cumulative Impact on Water Use and

Quality). As stated above, this approach is flatly prohibited by NRC’s own regulatory guidelines

implementing NEPA. NRC regulations state that “[c]ompliance with the environmental quality

standards and requirements of the [CWA] (imposed by EPA or designated permitting states) is

not a substitute for and does not negate the requirement for NRC to weigh all environmental

effects of the proposed action, including the degradation, if any, of water quality, and to consider

alternatives to the proposed action that are available for reducing adverse effects.” 10 C.F.R.

§ 51.71 n.3. Thus, we would ask that the Final EIS include a more substantive and independent

analysis of environmental impacts in the sections cited above, including the likelihood that

Dominion will have to obtain a further CWA § 316(a) variance. (DW-1122 14)

Response: The NRC staff has performed an independent analysis on the water quality and the

environmental effects that the proposed action would have on Lake Anna. That analysis is

presented in Sections 5.3 and 5.4 and Appendix K of this EIS. Consistent with 10 CFR 51.71,

footnote 3, the staff did consider the environmental effects of the proposed action on Lake

Anna. The staff discussed that there could be adverse impacts associated with the construction

and operation of any additional units. The performance of the WHTF to dissipate heat in a

relatively predictable and reliable manner suggests that the small incremental heat load

associated with a closed-cycle, combination wet and dry cooling system for Unit 3 is expected

to follow a pattern similar to that exhibited by the heat load of the two existing units. The heat

load of the additional unit is not projected to be significant, and it is expected that the heat

transfer process (transport, loss, and diffusion of heat) in the lake would remain the same. 

Dominion is responsible for obtaining a CWA permit. Accordingly, no changes were made to

this EIS as a result of this comment.

Comment: 1) The DEIS phrase “WHTF conditions” is non-specific and should be further

defined. 2) The “approximately 19 percent” is non-specific and should be further defined as to

where and what (i.e., surface area, volume, temperature, etc.). [page 8-2, line 32] 

(DW-0423 46)

Comment: Page 8-2: “The staff estimates that the proposed once-through cooling system for

Unit 3 could extend waste heat treatment facility (WHTF) conditions into the main body of Lake

Anna. Based on the additional heat load and associated flow, the staff estimates that WHTF
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NUREG-1811, Volume II 3-46 December 2006

conditions could extend into approximately 19 percent of the main body of the lake.” “WHTF

conditions” is unclear, and should be defined. Please include a basis for the calculation of the

19 percent, and a more precise description of the conclusion. 19% of the surface area? 

Specifically where? 19% of the water volume? A temperature increase that is 19% of

something? (DW-0826 2)

Comment: It is hard to reconcile the statement on page 8-2 line 36 that “WHTF conditions

could extend into approximately 19 percent of the main body of the lake” with the SMALL impact

designation for this parameter. (DW-0438 171)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, the thermal discharges to the WHTF would be

substantially reduced, and additional heating of the lake from the operation of Unit 3 would be

negligible. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: DEQ's Division of Water Resources comment[s that]...the new cooling design

eliminates concerns about increased water temperature. (SW-0017 17)

Comment: I want to reiterate, the reason we [Dominion] made that choice [for a closed-cycle,

combination wet and dry cooling system for Unit 3] and that choice will probably add about

$200 million to the price of the plant we make the decision to build it, the reason we made that

choice was to eliminate thermal impact to the lake. There will be essentially negligible thermal

impact to either the waste heat treatment facility or the lake as a result of the third unit using this

system. And in addition, it would dramatically reduce the amount of water consumption that is

of particular interest during a drought condition. (ST-0009 3)

Comment: Dominion also is an excellent environmental steward, and has demonstrated that it

is a good neighbor by agreeing to spend $200 million on a cooling tower system to cool a

potential third reactor at the North Anna site. Dominion made this commitment to satisfy

concerns expressed by state regulatory agencies, and local citizens about the potential thermal

impacts on Lake Anna and the waste treatment facility from using the lake for once-through

cooling. (ST-0031 6)

Comment: [T]he other thing I appreciated you commenting on was the specific rise in

temperature to the cooling lagoons. I do live on the cooling lagoon side and so that obviously is

a big concern of ours...I know you said one-tenth of one degree. If that is true, then I'm

concerned for not -- I'm not as concerned as I was. You know right now, the lake is 102 to

104 during this time of the year. And that is obviously very, very hot. If it were to raise another

six degrees, it probably becomes not usable for most recreational purposes. So I guess if you

can confirm that with, you know, a scientific method, that that is what you came to and you are

sure that if you were living there you would be okay with it, then I'm okay with that. (ST-0001 2)
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 December 2006 3-47 NUREG-1811, Volume II

Comment: Are the 100 F temperature tied in with the maximum inlet water temperature or is

there some heat transfer from the cooling towers heating this water to this temperature? 

(SE-0027 6)

Comment: [Regarding Dominion’s ER] Dominion’s conclusion that thermal impacts would be

small is used to support their decision only and does not take into consideration the public’s use

of the lake. No data is presented which supports their conclusion. (SE-0007 11)

Comment: [Regarding Dominion’s ER] Table 3.1-9 Can you explain if the blowdown

temperature is only 100 degrees F, how this will change the temperature at the discharge canal. 

If water from units 1 and 2 are 103.6 degrees F, will this blowdown water cool the maximum

temperature a little.? (SE-0004 19)

Comment: NRC and VDEQ must fully analyze the impact of any further water temperature

increases resulting from the blowdown/discharges of the proposed unit 3 cooling towers or any

malfunction of any of the proposed cooling towers or current generating units. The existing

units 1 & 2 periodically exceed Clean Water Act limitations and any additional temperature

increases by the proposed cooling towers will only exacerbate the situation. (SE-0022 12)

Response: Dominion’s proposal to utilize a closed-cycle, combination wet and dry cooling

system for the ESP Unit 3 instead of its initial plan to use a once-through cooling system would

substantially reduce thermal impacts to Lake Anna. The blowdown discharge temperature is

limited to 100(F in Dominion’s proposed design. Whereas in a once-through design the

discharge temperature is inevitably higher than the inlet temperature, in a closed-cycle design

the water inlet and discharge temperatures are essentially independent. If the discharge

temperature of the existing NAPS units exceeds 100(F, addition of blowdown discharges from

Unit 3 at 100(F would reduce the temperature of the combined discharges. However, given the

small fraction of the blowdown discharge relative to the NAPS discharge, the staff concludes

that any benefits would be negligible. Pursuant to the Clean Water Act, enforcement of this or

any other nonradiological water quality standard is the responsibility of EPA (and in Virginia,

EPA’s delegate, VDEQ). The thermal discharges of the existing NAPS Units are regulated by

VDEQ. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Recent Lake Anna Civic Association (LACA) water studies have indicated that the

North Anna River (3 miles before it enters Lake Anna) is 13 degrees cooler then the central part

of the lake above the Rt 208 Bridge. Many areas of the entire lake (both main reservoir and

cooling lagoons) have recently experienced temperatures in the low to high ninety’s which

clearly exceeds the 89.6 degree F temperature limitation in the Clean Water Act. Some

residents have reported temperatures as high as 106 degrees F. The entire Lake Anna is being

heated as a result of the current power plant. ... Any additional heat transfer from the proposed
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NUREG-1811, Volume II 3-48 December 2006

third unit water cooling tower blow-down discharge will only compound the problem while the

proposed Unit 4 dry cooling air tower would have no additional heat transfer impacts to the lake. 

(ST-0014 6) (SE-0022 11)

Comment: [Regarding Dominion’s ER] Table 5.3-11 page 3-5-78 We feel this table is

misleading due to the fact that all available data for temperature was not used. If data is used

from 6/1/2005 to 8/31/2005, the following results are seen:

Table 5.3-11 Table Reconstructed using all current data through August 2005 Surface

Temperatures at Monitoring Stations in WHTF and North Anna Reservoir.

MAXIMUM DAILY TEMPERATURES

Discharge: 103.6 (actual), 102.4 (Dominion’s value)

Dike 3: 96.5 (actual), 95.0 (Dominion’s value)

Intake: 92.2 (actual), 90.1 (Dominion’s value)

AVERAGE DAILY TEMPERATURES (July – August)

Discharge: 100.5 (actual), 95.0 (Dominion's value)

Dike 3: 92.7 (actual), 88.9 (Dominion's value)

Intake: 87.1 (actual), 83.8 (Dominion's value)

These actual temperatures are up to 5 degrees F hotter than reported by Dominion in the table. 

Why wasn’t current data included? (SE-0007 9)

Response: Dominion’s proposal to utilize a closed-cycle, combination wet and dry cooling

system for ESP Unit 3 instead of its initial plan to use a once-through cooling system would

substantially reduce thermal impacts to Lake Anna. The blowdown discharge temperature is

limited to 100(F in Dominion’s proposed design. The staff did not review more recent data in

the WHTF after its earlier assessment of thermal impacts in the Draft EIS because the

temperature impacts related to Unit 3 would be reduced with the closed-cycle design. At the

request of the staff, Dominion did analyze the indirect impact on average lake temperature

resulting from the consumptive water loss and concluded it was about 0.1(F. The staff’s

assessment did include the critical low water period in 2001 and 2002, which remains the critical

period to date. Pursuant to the Clean Water Act, enforcement of this or any other

nonradiological water quality standard is the responsibility of EPA (and in Virginia, EPA’s

delegate, VDEQ). The thermal discharges of the existing NAPS Units are regulated by VDEQ. 

THE UHS blowdown is a small fraction of the normal cooling system and, therefore, is bounded

by the normal cooling system impacts. Accordingly, no changes were made to this EIS as a

result of these comments.

Comment: Temperature data used by Dominion even in the updated revisions of the

submittals do not reflect the current temperatures of the last few years. That data shows the

discharge canal temperatures have reached 104.6 F.... Sprayers in the discharge canal or other

alternative cooling methods could alleviate this problem during the hottest weeks at minimum

cost. (SE-0027 10)
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 December 2006 3-49 NUREG-1811, Volume II

Comment: [Regarding] sprayers in the discharge canal. ...in order to reduce some of the

temperature that is exited at the discharge canal, we might consider using some sprayers in the

discharge canal just during the time periods when the temperate really gets hot like it has been

lately. (ST-0028 2)

Comment: The existing NAPS units use a spray pond for an Ultimate Heat Sink (UHS). Why is

it so difficult to add sprayers to the discharge canal to reduce peak water temperatures when

necessary to keep the discharge temperature below 104 F? (SE-0027 2)

Response: The high temperatures referred to in these comments result from operation of

NAPS existing units. This EIS is limited to an evaluation of the impacts of construction and

operation of the effects of proposed new units. While the staff did consider the cumulative

impact of the existing NAPS units, the staff did not consider mitigation to impacts caused nearly

entirely by the NAPS units. Because staff concluded that the incremental thermal impact of the

proposed new units would be negligible, mitigation measures such as sprayers were not

considered. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: At present Dominion claims that water temperatures never exceed 104F at the

discharge point into the cooling lagoons of Lake Anna. As full time residents at Lake Anna for

twelve years we have measured temperatures in excess of 104F at this location. (SE-0012 2)

Comment: [The ER states that] Over the entire life of the existing units this 104 degree F

temperature has never been reached even in extreme drought conditions. We [Friends of Lake

Anna] have seen temperatures at the discharge of the canal but what are the temperatures

leaving the heat exchanger at the power plant and what are the temperatures in the Ultimate

Heat Sink (UHS) and in the discharge canal itself? (SE-0004 29)

Comment: [Regarding Dominion’s ER] Par 5.3.4.1 page 3-5-71 a) With discussion to [related

to] PAM (Primary Amoebic Meningoencephalitis), Dominion states the “highest temperatures

recorded are summarized in Table 5.3-9. ...no data is used after year 2002. In fact Dominion’s

data shows that on August 15, 2005, a temperature of 103.6 deg F. was recorded at the

Discharge canal. The current data should be included. (SE-0007 7)

Comment: [Regarding Dominion’s ER] Table 2.3-7 is misleading. Why is the temperature

from 2002 through 2005 ignored. The results would be different if this data was included. All

other data in the report includes data for more years than this temperature. Dominion’s data for

2005 show temperatures up to 103.6 degrees F in August. (SE-0004 9)

Comment: [Regarding Dominion’s ER] Par[agraph] 3.4.1.3.2 page 3-3-65 The maximum

intake water temperature for plants 1 and 2 is 95 degrees specified by the “Technical

Requirements Manual”. This says the output of the discharge canal into the cooling lagoons will

be 109 degrees F. This would be unhealthy. Would the plants 1 and 2 be shut down at this
Comments Within Scope

NUREG-1811, Volume II 3-50 December 2006

point? Plants 3 and 4 would still run up to 100 degrees input temperature. Would this higher

input temperature affect the blowdown or evaporation rates and water requirements (still

49.6/.96 = 51.7 cfs (23,190 gpm)? What would the discharge temperature to the cooling

lagoons be at this condition? (SE-0004 22)

Response: The 109(F temperature referred to in this comment results from operation of the

existing NAPS units. This EIS is limited to an evaluation of the effects of the proposed new

units. Pursuant to the Clean Water Act, NRC has no authority to regulate nonradiological

pollutant discharges into receiving waters. Therefore, any restrictions on the temperature of

water discharged to the WHTF or Lake Anna would be the responsibility of EPA and the VDEQ. 

However, the staff did base its assessment on the current constraints on operation provided by

VDEQ. Currently, the NAPS VPDES permit limits the amount of heat rejected to the WHTF

without any specific upper temperature limits. The staff concluded that the incremental thermal

impact of the new units utilizing the closed-cycle, combination wet and dry cooling system would

be negligible. The wet portion of a closed-cycle cooling system is primarily dependent on the

latent heat of vaporization of water, which is relatively independent of the range of water

temperatures expected to be experienced in the intake. Therefore, the staff in its independent

analysis concluded that the intake temperature would not significantly impact the evaporation

rates for the cooling tower. The rate of blowdown water is primarily a function of the intake

water chemistry. Water is blown down to limit the concentration of chemicals in the cooling

water through repeated cycles where water is evaporated. Unit 4 is proposed to be cooled with

a dry cooling tower system and therefore would not contribute to the discharge temperature. 

The adjustment for the annualized load factor of 96 percent is inappropriate for the calculation

of instantaneous maximum values. Correcting for the annualized load factor is only appropriate

in the case of values report as annual averages. Accordingly, no changes were made to the

EIS as a result of this comment. 

Comment: What happens if it [water from the cooling system] goes in at 101 instead? It's

measured at that. What happens if it goes in at 110? Do they just get to do it? (ST-0007 1)

Response: The staff assumes that the comment refers to the temperature of the combined

discharge from NAPS Units 1 and 2 and the proposed Unit 3. The Unit 3 discharge temperature

would be limited to 100(F. However, pursuant to the Clean Water Act, NRC has no authority to

regulate nonradiological pollutant discharges into receiving waters including with respect to

temperature. Establishing discharge temperature limits and enforcing such limits with the

enforcement authority granted them in the Clean Water Act are the responsibility of EPA and

the VDEQ. Accordingly, no changes were made to the EIS as a result of this comment. 

Comment: [Regarding Dominion’s ER] Par. 5.1.1.1 page 3-5-2. The conclusion that “the

change in temperature at the discharge point of the (cooling lagoons) due to operation of the

new units would be negligible and would not impact the current or future recreational uses of the

lake” is not true. Since the new units would not shut down until the input temperature reaches
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 December 2006 3-51 NUREG-1811, Volume II

100 degrees F, and the existing units at 95 degrees F, this would have a serious impact on the

current recreational uses on the lake. (SE-0004 23a)

Response: Once the temperature at the intakes reach 95(F, the NAPS Units 1 and 2 would

cease to operate. The remaining heat load and discharge flow from Unit 3 would be a very

small fraction of heat load and flow relative to the combined discharge with the NAPS operating. 

It is reasonable to expect that if this condition were to occur, Unit 3 cooling system would be in

MWC mode, which would further reduce the heat load and discharge flow to the WHTF. Based

on the low heat load, low discharge flow rate, and the long residence time in the WHTF without

NAPS in operation, the staff concluded that any impact to recreational uses to Lake Anna would

be minor. Recreational implications of the regional population are discussed in Section 3.5.6. 

No changes were made to the EIS based on this comment.

Comment: I want to ask the hydrologist if he recently read about the nuclear power plant in

France and other European countries. And they are returning water at a much higher level than

it is allowed. You know they are facing a very, very hot summer. That means both the

temperature of the lake probably or the cooling water that they use is already higher than they

had probably anticipated. Now have you all looked at this? Because, you know, we have had

increasingly hot summers. And we are, you know, probably in the throes of global warming.

...I just wanted to make people realize that the first two reactors are still once through. And, you

know, they are going to be using, in the case of higher temperatures initially, they are going to

be using more water through evaporation. Therefore, you add a third unit, you are still going to

increase the amount overall that is lost to evaporation. (ST-0002 2)

Response: The NRC staff is aware of water issues that occurred during the recent high

summer temperatures in France. The staff agrees that during warm summer months,

particularly in low water years, the existing once-through cooling system for NAPS Units 1 and 2

would result in greater consumptive water use through higher induced evaporation rates. This

increased water use would generally coincide with increased natural evaporation rates. If

summers become increasingly hot, the Commonwealth of Virginia could require changes in

operation of the NAPS and any new facilities to mitigate these impacts. Accordingly, no

changes were made to the EIS as a result of this comment. 

Comment: How many temperature sensors are placed around the lake by Dominion and the

State of Virginia? (ST-0008 1)

Response: In accordance with NAPS’s VPDES permit, there are eleven fixed continuous

temperature recorders. Ten are in Lake Anna and the WHTF and one is downstream in the

North Anna River. Additionally, fourteen temperature profile (from surface to bottom at 1-m

intervals) cross sections are sampled during two quarters of the year. No changes were made

to the EIS based on this comment
Comments Within Scope

NUREG-1811, Volume II 3-52 December 2006

3.3.2.4 Waste Heat Treatment Facility

Comment: ESP indicates the maximum temperature increase will be from 14 to 18(F across

the once passing through cooling or an increase of 4(F. There is no discussion as to the

expected temperatures in the WHTF (Warm Side). (DW-0806 5)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, thermal discharges to the waste heat treatment facility

would be substantially reduced, and thermal conditions generally would be unchanged in the

WHTF. Accordingly, no changes were made to this EIS as a result of this comment. 

Comment: Can Dike 3 handle the increased discharge of the third plant or will the Waste Heat

Treatment Facility (WHTF) (Warm side) level increase? ... The total draw from the once pass

through cooling for three plants is 3 Million gal/min or 4.38 Billion gal/day... Can dike 3 handle

4.38 billion gallons/day discharge into the main lake? (DW-0806 3)

Comment: What is the expected rise in water height of the WHTF from the current height when

Units 1, 2, and 3 are operating? If it is expected to be a foot or more, residents’ docks may be

under water. (DW-0806 4)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. Dominion has since proposed a closed-cycle,

combination wet and dry cooling system. Based on the small blowdown discharges, operation

of the proposed closed-cycle, combination wet and dry cooling for Unit 3 would not be expected

to raise the water level of the WHTF by any appreciable amount. Accordingly, no changes were

made to this EIS as a result of these comments.

Comment: What will happen to the Dissolved Oxygen (DO) in the WHTF at temperature 100(F

or higher? (DW-0806 8)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, the thermal discharges to the WHTF would be

substantially reduced, and any decrease of dissolved oxygen would be negligible. In general,

increases in water temperature can reduce the solubility of oxygen in water. However,

degassing of oxygen would only occur at or near saturated conditions. The solubility of oxygen

in water changes from 6.9 to 6.4 mg/L as the temperature increases from 35 to 40.6(C (95 to

105(F). However, some of the decrease in solubility may be offset by an increase in re-aeration

rates with higher temperatures. Additionally, if adequate nutrients exist in the water, increases

in water temperature are associated with increases in biological activity, which could deplete

dissolved oxygen under certain conditions. The dissolved oxygen level would not be expected
Comments Within Scope

 December 2006 3-53 NUREG-1811, Volume II

to decrease significantly in the WHTF with the addition of Unit 3 discharge to the existing units

nor depress the dissolved oxygen in the WHTF to levels detrimental to aquatic organisms. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: [Regarding Dominion’s ER] Par[agraph] 5.3.4 page 3-5-69 Impacts to Members of

the Public, Dominion added a sentence in the Revision 6 ESP application in this paragraph just

to solidify their point in dealing with the public. Dominion states “Virginia Power considers the

WHTF (Cooling Lagoons) to be an integral part of the power station, and as such it has never

been operated as an extension of the North Anna Reservoir for the purposes of public

recreational use.”...This is directly opposite to the Virginia Power public document from 1970

where they promoted the shoreline construction and recreational use of the entire lake both

warm and cold sides. ...How can the NRC, Environmental Protection Agency, National Oceanic

Administration and Dominion not consider the cooling lagoons as quasi public waters? What is

the North Anna River which provides about 25% of the water cooling for the power plant and the

water eventually feeds into the Atlantic Ocean? We do not understand the difference, please

explain. (SE-0007 3)

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. (SE-0045 26)

Comment: 104 degrees have continually been used as a benchmark for acceptable water

temperature on the WHTF. Anyone living here, and that number is growing significantly, would

tell you that that figure has become unacceptable. This is now a recreational facility, as is the

cold side. As I said before things change, and so must the concern for the health and welfare of

us using this facility. ...The heat generated by the power plant is now not only affecting the

warm side but is now affecting the public side, to a somewhat lesser degree, north of the

208 bridge. This alone should invoke concerns from various governing agencies. People

directly across from the third dike and just north of the main dam, have experienced water

temperatures approaching those on the warm side. (SE-0018 2)

Comment: The Waste Heat Treatment Facility (WHTF) is an erroneous designation (not

supported by state law) that is used throughout the ESP to describe the cooling lagoon portion

of Lake Anna and its usage should be stopped. The cooling lagoons should simply be referred

to as the “Cooling Lagoons”. This WHTF designation has caused the cooling lagoons to be

viewed and treated similar to a sewage treatment facility by many state agencies and as a result

are viewed as private waters and not afforded the protections or other amenities afforded public

waters. (SE-0002 1)

Comment: We also request that the all state agencies stop using the designation, Waste Heat

Treatment Facility to describe the cooling lagoons so it is not viewed and treated similar to a

sewage treatment facility. This designation affords no public protection for the over 8,000 users

of the cooling lagoons. (ST-0014 20) (SE-0022 33)
Comments Within Scope

NUREG-1811, Volume II 3-54 December 2006

Comment: We request that the Waste Heat Treatment Facility (WHTF) should be referred to

as the "Cooling Lagoons". Names immediately generate mental images when people hear

them. The reference to the clean water in the Cooling Lagoons as "WASTE" in the leading word

of WHTF immediately gives a bad and misleading image of the clean water and recreational use

of the Cooling Lagoons. ...We believe that the "Cooling Lagoons" nomenclature is more

accurately descriptive of their attractive nature and recreational use. (SW-0004 9)

Comment: We support the use of the terminology cooling lagoons instead of the waste heat

treatment facility. The reason is that when people hear the name "waste" in the leading word of

the WHTF, it immediately gives a bad name and a misleading image of the clean and

recreational use of the cooling lagoons. (ST-0004 6)

Comment: We request that the cooling lagoons be designated as "quasi public water".

...Changing the designation would require that the State of Virginia treat the Lake Anna Cooling

Lagoons as public waters for the purpose of application of Virginia regulations relating to the

health, safety, and welfare of the citizens living around and using the Cooling Lagoons. 

(SW-0004 8)

Comment: I object to the use of the term Waste Heat Treatment Facility (WHTF) to describe

the section of the lake on which I live utilized by Dominion. I do not wish or want to live next to

what can be viewed as a sewage treatment facility by both my friends and government

agencies. (SE-0019 3)

Comment: The issue is simple, once the warm side of the lake was opened up to speculation

and development, the rules should have changed. The warm side should no longer have been

considered a Waste Heat Treatment Facility, with the same guidelines as if we lived on sewage

treatment facility. This term should be changed and guidelines written that would adequately

insure the residents of the warm side the same health standards as any other public facility in

the state or nation. Our situation is definitely unique and should have been identified as such

when the power plant was first built. Realizing that this may have required necessary changes

to the plant and its cooling facilities, they could have been included in the plans and that time

and saved the Dominion and subsequently the taxpayers a lot of money. (SE-0018 1)

Comment: Both the main reservoir and the cooling lagoons are now populated and substantial

individual investment has been made by property owners. On the cooling lagoons most of

these individual investments were made after the abandonment of units 3 & 4. Dominion

Resources / Virginia Power cannot now turn back the clock and deny access or otherwise

render the cooling lagoons unusable for recreational purposes. (SW-0015 1)

Response: The designation of the WHTF by the Commonwealth of Virginia as an industrial

waste heat treatment is not subject to review by either the NRC or NOAA. While water

resources are always public, a state can permit the temporary “use” of the water. For instance,
Comments Within Scope

 December 2006 3-55 NUREG-1811, Volume II

municipal sewage is not regulated at the point that the effluents enter the sewage treatment

system but at the point the treated effluents are returned to the public waters. The responsible

permitting agency can specify the condition (water quality) of the water that is returned to public

waters. The condition of the water, during its “use”, is not generally restricted, whereas the

water’s condition when it is returned to public use is restricted. The staff’s assessment did not

question the designation of the WHTF as an industrial waste heat treatment facility. The name

of the Waste Heat Treatment Facility is the perogative of the owner, not the NRC. The NRC

cannot change the name of the WHTF to “Cooling Lagoons.” Accordingly, no changes were

made to this EIS as a result of these comments. 

Comment: It is unclear from the many various documents...to determine exactly what the

impact on both the cold side and cooling lagoons water level’s, water flows, and water

temperatures are when the 3rd and 4th reactors are activated. ...In some cases they use C,

(which requires the public to convert to Fahrenheit degrees. In other cases they use a notation

of thermal heat added to the water without any regard to what this means to Fahrenheit degree

temperatures. Dominion and the NRC should standardize the use Fahrenheit degrees so the

public can easily understand its impact in all ESP and COL documentation. (SE-0003 9)

Response: Throughout its review (except for this appendix in which most numbers are

presented in English units), the staff has presented temperature in both Fahrenheit and Celsius

for the convenience of the reader. Accordingly, no changes were made to this EIS as a result of

these comments. 

3.3.2.5 Water Levels

Comment: Lake Anna cannot physically support the addition of new reactors. The increased

water use associated with the new reactor will cause the lake level to drop significantly. 

(DW-MM1 4)

Comment: Among my concerns are: Increased water use associated with new reactors--lower

water levels have many undesirable consequences. (DW-0998 1)

Comment: The already deficient water level at Lake Anna appears to have been glossed over

and ignored. (DW-0431 5)

Response: These general comments question the sufficiency of the water supply to maintain

adequate water levels. Dominion revised its consumptive water use values and its plans for

maintaining water levels starting with Revision 6 of the ER to reflect the change in the cooling

system for Unit 3. The effects of these revised values are evaluated in Section 5.3. The staff

concluded that the evaporative losses associated with the operation of the proposed

closed-cycle, combination wet and dry cooling system for Unit 3 (approximately 19 cfs) could

result in additional declines in the lake level. During drought periods, the impact could further
Comments Within Scope

NUREG-1811, Volume II 3-56 December 2006

exacerbate low lake levels. During such drought conditions, the staff concluded the impacts

would be MODERATE. The staff used widely accepted and validated modeling techniques in its

analysis and concluded that the lake would be sufficient to cool the additional unit. In

determining the impact level, the staff considers the valuation of the water resource by the

Commonwealth of Virginia in assessing the impact. The Commonwealth of Virginia has

jurisdiction over allocating water. Drought conditions or increases in future water demands

could result in intervention by the Commonwealth on the apportionment of the water. Such

intervention might include operational restrictions during periods of water conflict. Additional

information on the water budget calculations performed by the staff are included in Appendix K

of this EIS.

Comment: Had a third reactor been a once through reactor, the same kind that they’re

proposing, been built and operating in October of 2002, the lake level would have dropped

another two feet, and the reactors would have had to shut down. This is from the draft EIS itself

and from Dominion. In response, Dominion has asked to allow the third proposed reactor to

operate until the lake level drops down to 242 feet above mean sea level. Not only would this

lowering of the shutoff point increase the risks during plant operations. It would also increase

the impacts on the lake and downstream. (DT-0019 8)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. While the additional evaporative loss associated with

the proposed Unit 3 closed-cycle, combination wet and dry cooling system could result in lower

pool elevations and a reduction in downstream flows during extended dry periods, this would

not result in any greater risks associated with the safe operation of the plant. The rate at which

the lake’s pool elevation would decline during a drought, such as the one in 2002, would be

gradual enough to safely derate or shut down one or more units before reaching the minimum

operating pool level. More information is provided in the staff’s Final Safety Evaluation Report

for the North Anna ESP (ML 051610246). The environmental effects of lower lake level and

downstream flows are evaluated in Section 5.3. Accordingly, no changes were made to this EIS

as a result of this comment.

Comment: The water resources are already inadequate for this site, and I think the best

numbers on that if you look at the percentage of time that the Virginia Department of

Environmental Quality’s discharge permit is violated... -- perhaps “violation” is the wrong term,

but you have to understand that the department wanted a minimum discharge of 40 cubic feet

per second (cfs), and except under drought conditions, whatever “drought” means, it can go

down to 20 cfs. If you look at the historical record of the two reactors, it is that the history of the

hydrological response is that 44 percent of the time, they’re discharging less than 40 cubic feet

per second, and five percent of the time they’re discharging even less than the 20 feet per

second, which was only supposed to be under drought conditions. (DT-0021 5)
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 December 2006 3-57 NUREG-1811, Volume II

Comment: You have to seriously question whether you can call something drought if it’s

happening 44 percent of the time. Those numbers, projected numbers under a third unit,

cooling of a third unit, would realize to 52 percent of the time when you’d be discharging less

than 40 cubic feet per second...And 12 percent of the time less than 20. Now, my main point is

that if you look at the draft environmental impact statement, it does not really analyze the impact

of that on the downstream uses in any detail, and I think the logic where they reached a

conclusion that would be a small impact most of the time and only moderate part of the time;

there’s no real analysis to support why you would reach that conclusion. (DT-0021 6)

Response: In determining the impact level, the staff considers the valuation of the water

resource by the Commonwealth of Virginia. The Lake Level Contingency Plan, which sets

discharge rates based on lake level, was considered by the NRC staff in the evaluation of the

North Anna water supply. Low flow releases from the dam are prescribed by the VDEQ in the

Plan. The policy of decreasing the release from 40 cfs to 20 cfs as the lake level drops below

248 feet above mean sea level (MSL) is prescribed by VDEQ. Drought conditions or increases

in future water demands could result in intervention by the Commonwealth on the

apportionment of the water. Such intervention might include operational restrictions during

periods of water use conflict. The water use conflicts issue is a principal issue in this

environmental review. Starting with Revision 6 of the ER, Dominion revised its consumptive

water use values to reflect the change in the cooling system for Unit 3. The effects of these

revised values are evaluated in Section 5.3. The staff performed an independent assessment

of the impacts that forced evaporative losses from the proposed wet cooling portion of the Unit 3

system would have on the lake and downstream water budget. This assessment is provided in

Appendix K of this EIS. The assessment was based on hydrological conditions and the

estimate of the rate of induced evaporative loss listed in Appendix I from Dominion’s Plant

Parameter Envelope (PPE). The staff determined that the evaporative losses associated with

the operation of a closed-cycle, combination wet and dry cooling system for Unit 3

(approximately 19 cfs) would result in declines in the lake level and reductions in downstream

flow. Accordingly, the staff concluded that during such drought conditions, the impacts could be

temporarily MODERATE. Additional information on the water budget calculations performed by

the staff are included in Appendix K of this EIS.

Comment: The minimum dam release required by the VPDES permit is normally 40 cfs. 

During a severe drought, a Lake Level Contingency Plan in effect allows a decrease in the

release in increments of 5 cfs down to a minimum rate of 20 cfs. The percent of time at 20 cfs is

5.3 percent. [page 5-7, line 34] (DW-0423 31)

Response: This comment relates to Revision 3 of the ER. The proposed cooling system for

Unit 3 has since been changed to a closed-cycle, combination wet and dry cooling system. The

staff concluded that the induced evaporative losses associated with the operation of a

closed-cycle, combination wet and dry cooling system for Unit 3 (approximately 19 cfs) could

result in reductions in downstream flow especially during drought periods. Based on updated
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NUREG-1811, Volume II 3-58 December 2006

estimates using bounding assumptions, the flow from the Lake Anna Dam would be 20 cfs from

6 to 11 percent of the time. Section 5.3.2 was revised to reflect the updated analyses.

Comment: This DEIS wording is inconsistent with ER Section 5.2.1.2. The average annual

evaporative loss is estimated to be 29 cfs, which assumes Unit 3 operates at a 100% plant

capacity factor. As a result, the predicted minimum water surface elevation of 243.4 ft msl on

DEIS Page 5-9 (line 24) for Units 1 and 2 plus Unit 3 using once through cooling is higher than

the corresponding 242.6 ft msl minimum water level estimated in ER Section 5.2.2.1. [page 5-6,

line 2 and at other locations within this section] (DW-0423 29)

Response: This comment relates to Revision 3 of the ER. The proposed cooling system for

Unit 3 has since been changed to a closed-cycle, combination wet and dry cooling system. 

Dominion’s revised PPE states that the forced evaporative losses associated with the operation

of a closed-cycle, combination wet and dry cooling system for Unit 3 would be approximately

19 cfs. The revised analysis based on the change in the cooling system indicates that the

minimum estimated water surface elevation would be 243.5 ft MSL, which is 1.7 ft lower than

the value estimated without Unit 3. Section 5.3 has been revised to reflect this evaluation.

Comment: In its application, Dominion has asked to allow the proposed third reactor to operate

until the lake level drops down to 242 feet above mean sea level. At the February 23, 2005

meeting between NRC and Dominion, Dominion stated that it has lowered the intakes for Unit 1

and 2. Please indicate how Dominion has modified the intake pipes in the Draft EIS. Does

Dominion intend to request that the shutoff point for the existing reactors be lowered to 242 feet

above mean sea level? (DW-0437 10)

Comment: ESP uses 242-foot level as the minimum lake level before shutdown for Unit 3. 

Unit 3 should use the 244-foot level not 242 as is currently used by Units 1 and 2 until NRC has

studied the proposed 242 level. (DW-0806 2)

Comment: Require intakes at all units remain at 244 feet - We question the wisdom to allow

Unit 3 to have an intake at 242 feet above sea level when Units one and two have been

regulated to 244 feet. Even at 244 feet, the problems experienced during the drought indicate

that a lower intake level could further compound the problem. (DW-1157 18)

Comment: The NRC Staff acknowledges that “operation of Unit 3 would increase the duration

of periods during drought conditions when the Lake Level Contingency Plan would be applied”

(page 5-9, line 34). The Final EIS should include a full analysis of the impacts on the lake and

downstream of lowering the level at which the two existing reactors, in addition to the proposed

Unit 3, must be shut down. Please justify why lowering the shutoff point would not further

increase the impacts on the lake, as well as downstream by lengthening the period of time of

low-flow from the dam. (DW-0437 11)
Comments Within Scope

 December 2006 3-59 NUREG-1811, Volume II

Response: The physical location of the intake structures for the existing units and the

proposed units are expected to be near 235 feet above mean sea level. The lake level

analyses are based on actual or proposed plant operating practices. The applicant revised its

operating practices to allow operations of Units 1 and 2 down to 242 ft above MSL after the

Draft EIS was released. The calculations in Appendix K and text in Sections 5.3, 5.4, and 5.5

have been revised to reflect this change. The staff’s independent assessment did not show a

significant change in impacts.

Comment: Page 5-8 line 41 states that the Lake level is being managed to maintain a stable

level of 76.2 meters yet the modeling results on Page 5-9 predict a lower level for all four

scenarios mentioned. (DW-0438 139)

Response: The lake is operated with the goal of maintaining stable lake level of 250 feet

(76.2 meters); this is the upper operating height that would not result in submerging docks and

boat ramps that were constructed around the lake nor inundating additional land around the

lake. When water is plentiful and the stable lake level is easily maintained, the lake outflow is

comparable to the lake inflow. Consequently, up to the point that lake outflows (including

natural and induced evaporative losses from Units 1 and 2, forced evaporative losses from

Unit 3, and releases from the dam) begin to exceed lake inflows, the lake is operated at the

stable lake level. Once the lake outflows exceed the lake inflows, the lake level begins to

decline; such scenarios were analyzed as well. These analyses included the normal minimum

flow of 1.1 m3

/s (40 cfs) when the lake level is between 250 and 248 feet (76.2 and 75.6 m). 

When the Lake Level Contingency Plan is implemented (at lake levels below 248 feet [75.6 m]),

the release is limited to 0.57 m3

/s (20 cfs) to reduce further lake declines. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: One or two additional units on Lake Anna would reduce lake levels due to

increased water withdrawals from the lake, especially in the summer and fall when demand for

power and evaporation are higher. This was evidenced during the 2002 drought when the lake

level dropped to a mere 245.1 feet above mean sea level, nearly requiring the NAPS to be shut

down and preventing the use of most boat ramps (DEIS, page 5-44, lines 9-11). (DW-0437 31)

Response: Annual lake water levels are generally lower during the summer and fall months. 

With any additional water use required by one or more additional units, the lake level would be

further reduced. The staff analyzed the environmental effects of a proposed closed-cycle,

combination wet and dry cooling system for Unit 3 and reported the results of its assessment in

Section 5.3 and elsewhere where it affects other resources (for example, recreational uses and

the fishery). Accordingly, no changes were made to this EIS as a result of this comment.

Comment: [Regarding Dominion’s ER] Par[agraph] 5.2.2.1.2 page 3-5-11 Since a quadratic

equation was used to fit the three elevations (240, 250, 260 msl), what was the index of

determinate? (SE-0004 24)
Comments Within Scope

NUREG-1811, Volume II 3-60 December 2006

Response: As stated in Section K.4, the staff independently estimated the lake stage volume

relationship using digital raster bathymetry data and did not rely on the applicant’s approach. 

Accordingly, no changes were made to the EIS based on this comment

Comment: The current operating rules for the power plant allow flows to be reduced from a

required 40 cfs to 20 cfs whenever the lake elevation goes down to 248 feet msl, according to

the Department of Game and Inland Fisheries...While the Department [DGIF] wishes to maintain

the frequency and duration of 20-cfs events...DEQ's Division of Water Resources indicates that

setting the trigger elevation at 247.5 feet msl instead of 248 feet would require changing the

existing Virginia Pollutant Discharge Elimination System (VPDES) permit, and might generate

opposition from lakefront property owners. The Division opposes any change in the trigger

elevation of 248 feet. However, the Division believes that the DGIF recommendation to raise

the lake level three inches in the spring to make more storage available for downstream flows in

the spring deserves additional study. (SW-0017 29)

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the

ESP]...Raising of lake level to retain more water for 3rd unit and resulting in destruction of

adjoining property and also for retention for downstream users. (SE-0022 21)

Comment: [Regarding the cover letter in Dominion’s ESP Application Revision 6] Question 16f

Lake Level -- Can we assume that raising the lake level is a dead issue. It keeps coming up

and Dominions response is that it is no problem, but they are not proposing it at this time. 

When will they propose it? (SE-0004 5)

Response: Consistent with NRC’s role under NEPA, the staff did analyze the impact of raising

the normal pool elevation as a possible mitigation measure. The impacts of this specific

mitigation measure were considered in the EIS based on a request by the Commonwealth of

Virginia to evaluate raising the lake elevation to maintain the current frequency at 20 cfs. Any

decision to change the operating policies for North Anna Dam would be the responsibility of

VDEQ and not NRC. Accordingly, no changes were made to the EIS based on these

comments.

Comment: [T]here's some inconsistencies in the documents. Unit 3 is stated to operate until

the water level drops down to 242 feet, that's 8 feet below normal level....Now the other part of

the document says 243.5 feet instead of the 242 for Unit 3, and 245.2 for the existing units.

(ST-0028 3)

Comment: Unit 3 is stated to operate until the water level drops to 242 feet lake level and

water temperature at the reservoir inlet of 100 F. Why does page 5-39 say 243.5 feet for unit 3

and 245.2 feet for NAPS units 1 and 2? (SE-0027 3)
Comments Within Scope

 December 2006 3-61 NUREG-1811, Volume II

Response: The current intake design forces NAPS Units 1 and 2 to shut down if the lake level

drops below 242 ft. In the ER, Dominion proposes that the Units 3 and 4 intakes would also

have the same limitation. In the staff’s assessment, water level would have never dropped to

242 ft even during the critical water period with the units operating. If the staff had predicted the

water would have dropped below 242, the model would have simulated all the NAPS and new

units shutting down operation. The values of 245.2 ft for Units 1 and 2, and 243.5 ft for Units 1,

2, and 3, respectively, are predicted minimum lake levels. Accordingly, no changes were made

to this EIS as a result of these comments.

Comment: [Regarding the cover letter to Dominion’s ESP Application Revision 6] Since

Dominion has decided not to change the existing lake level, can we assume that the lake levels

will be 7 inches lower than normal with unit 3 running in times of low flow or droughts? 

(SE-0004 4)

Response: The staff’s assessment predicted greater declines in the water level than did

Dominion’s assessment. Based on the staff’s assessment described in Appendix K of this EIS,

the incremental drop in lake elevations caused by Unit 3 would be less than 3 inches for over

69 percent of the time. However, a maximum incremental decline of 1.7 ft was predicted by the

staff’s analysis for the critical period. Accordingly, no changes were made to this EIS based on

this comment.

Comment: The third unit will use some lake water through evaporative loss. ...We request that

simple, obvious steps be taken to manage the available Lake water to maximize the Lake level

during times of low rainfall. (SW-0004 3)

Comment: [T]he state-of-the-art cooling design that Dominion has proposed for Unit 3 would

evaporate significantly less water [then a once-through system]. Plus when lake level is a

concern, a dry cooling tower will be used to maintain lake level and downstream flow. 

(ST-0012 6)

Response: Dominion’s design of a cooling system that shifts the mix of dry and wet cooling as

the lake level declines would reduce the lake level decline compared to a conventional wet

cooling tower design. Accordingly, no changes to the EIS were made based on this comment.

Comment: 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. (SE-0038 6)

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? (SE-0045 25)
Comments Within Scope

NUREG-1811, Volume II 3-62 December 2006

Response: This EIS evaluates the impacts of the proposed Units 3 and 4 and does not

evaluate changes relating to the existing NAPS units that are independent of the proposed

action except inasmuch as those changes would alter the affected environmental conditions. 

The change in the minimum lake level for operation of the NAPS units was a separate action

that was not subject to NRC review. Accordingly, no changes to this EIS were made based on

these comments.

Comment: [T]o improve the management of the available lake water during times of low

rainfall. We request that the release over the dam be changed to limit it to 5 cubic feet per

second for lake levels below 250 feet. ...This limitation will have a minimal effect on downstream

users, because there are other stream flows into the North Anna River about a half a mile below

the Lake Anna Dam. (ST-0004 4)

Comment: We request that the release over the dam be changed to: Lake above 250 - release

not limited Lake below 250 - release limited to 5 cfs (cubic feet per second). This change is to

make a major improvement of the management and conservation of the very limited flow of

water into the Lake. (SW-0004 4)

Response: Reducing the release from the dam to 5 cfs, whenever the lake drops below 250 ft,

would indeed reduce the declines in the lake during times of low rainfall. However, the staff did

not evaluate further reductions in downstream flowrates because concern has already been

expressed by the Commonwealth of Virginia regarding the increased frequency of 20 cfs flows. 

During periods of extended low rainfall, releases from North Anna dam can be the principal

source of flow in the Pamunkey River as flows from the South Anna River and the Little River

may be very low. Reducing the flow to 5 cfs would increase the impacts to downstream users

and would violate the Lake Anna Contingency Plan. The Commonwealth of Virginia is

responsible for determining the releases from North Anna Dam. Accordingly, no changes to the

EIS were made based on these comments.

Comment: Page 5-9, line 30...Dominion did not propose raising the normal operating lake level

above 250 ft msl. The SDEIS should clarify that this was evaluated by Dominion at the request

of the Commonwealth of Virginia, but is not proposed by either at this time. (SE-0050 17)

Response: The text in this EIS has been modified to clarify that Dominion performed this

analysis at the request of VDEQ.

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the

ESP]...Lowering lake level by increased water usage thereby causing increased drought cycles

ranging from weeks to months. (SE-0022 22)
Comments Within Scope

 December 2006 3-63 NUREG-1811, Volume II

Response: In Section 5.3.2 and Appendix K of this EIS, the staff describes its independent

assessment of the impact on lake levels of the proposed Unit 3's consumptive water use. 

Based on current release policies from the North Anna dam, the lake level is projected to

decline less than 3 inches on the average. During periods of drought, these declines would be

more significant and persist longer. Accordingly, no changes were made to this EIS as a result

of this comment.

Comment: DGIF recommends that the normal operating elevation be seasonally increased

(April through November) to 250.25 feet msl in order to minimize the impacts of an increased

frequency and duration of 20-cfs flows on downstream resources. Rules could be in place to

reduce the pool to 250 feet msl elevation prior to predicted storm events such as hurricanes and

tropical depressions. (SW-0017 45)

Response: The Commonwealth of Virginia is responsible for determining the releases from

North Anna Dam including during predicted storm events. The staff evaluated the impact of

raising the lake level in Section 5.3.2. Accordingly, no changes to the EIS were made based on

this comment.

Comment: While the DEIS points out that drought years have not had significant impact in the

past on Lake Anna’s water levels, the potential for global warming should be considered. This

is especially true because the ESP is valid for 20 years with the possibility to renew for 20 more.

Nearly all scientists agree that some effects of climate change will be experienced in the next

20 years. The DEIS has not yet considered what would happen to the lake under the various

conditions that could be caused by global climate change. (DW-0630 4)

Comment: [H]as NRC correctly analyzed...the vulnerability of the North Anna site to...climate

change...i.e. what are the impacts if the lake steadily dries up in a future local climate of

reduced rainfall and higher than average temperatures? ...Analysis of the climate change

scenario seems indicated given the projected 60 year life span of a reactor and the recent spate

of reactor cooling problems triggered by heat and drought conditions in Europe and the

Midwestern U.S. (SE-0040 17)

Comment: While the DEIS points out that drought years have not had significant impact in the

past on Lake Anna’s water levels, the potential for global warming should be considered. This

is especially true because the ESP is valid for 20 years with the possibility to renew for 20 more.

Nearly all scientists agree that some effects of climate change will be experienced in the next

20 years. The DEIS has not yet considered what would happen to the lake under the various

conditions that could be caused by global climate change. (DW-0630 4)

Response: Despite intensive investment in climate change science over the past decade,

numerous gaps remain in the state of understanding of climate change. The staff reviewed the

National Assessment of the Potential Consequences of Climate Variability and Change that was
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NUREG-1811, Volume II 3-64 December 2006

prepared by the United States Global Change Research Program. This assessment states the

following:

"Climate scenarios for the southeastern US provide contrasting results in terms of

temperature and precipitation estimates over the region, so that in some cases conditions

may improve while in others they may degrade. The Canadian model results show little

change until 2030, followed by drier weather in most of the region over the next seventy

years. On the other hand, the Hadley Centre model predicts a slight decrease in the region

during the next 30 years, after which precipitation increases significantly."

Such variability in model climate model predictions is not unusual as a result of the complexity

and uncertainty in climate models and climate processes. The staff concludes that

consideration of climate change predictions does not alter the staff's conclusions regarding

impacts of a proposed Unit 3 on water resources. 

The primary mission of the NRC is to ensure that authorized activities would be conducted in a

manner to provide adequate protection of public health and safety from the effects of the

radiological hazards posed by nuclear reactors, materials, and waste facilities. The NRC will

continue to monitor efforts to reduce the large uncertainties in projecting future climate change

to ensure that the public is adequately protected. Accordingly, no changes were made to this

EIS as a result of these comments.

3.3.2.6 Drought-Related Impacts

Comment: Page 5-4 line 21 seems to infer that during normal years the water level in the Lake

would be acceptable. What about during drought years? (DW-0438 127)

Response: Predicted water levels during drought years and their associated impact levels are

discussed in Section 5.3 and in Appendix K.

Comment: Page 5-4 line 25 refers to the drought as a “climatic anomaly” – droughts are

normal occurrences over time. (DW-0438 128)

Response: Droughts of varying intensity, duration, and extent do occur over time. However,

droughts are, by definition, departures from the norm and are therefore described as anomalies. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Change the word “could” to “would” on Page 5-18 [assumed to be from page 5-38]

line 18. (DW-0438 151)
Comments Within Scope

 December 2006 3-65 NUREG-1811, Volume II

Response: The text in Section 5.5.1.4 has been revised to “Impacts of the Unit 3 cooling

system on the lake’s water level would be more noticeable in time of drought” to reflect this

comment.

Comment: Using elevation 248 as an indicator [of a hydrologic drought], past Dominion

records demonstrate that this level has been observed 3 times in the last 26 years, a

reasonable expectation of the recurrence interval (8.6 years) for a drought. Addition of Unit 3

would increase the drought recurrence interval to every 2.6 years and more than double the

total weeks of flows that are 20 cubic feet per second (cfs) or lower from 67 to 143. Median

duration of drought flows of 20 cfs would be 7 weeks with the proposed Unit 3. Virginia State

Water Control Board Bulletin #58 reviewed flow statistics for the gauge downstream at Doswell. 

Prior to dam construction, flows of 25 cfs or lower would occur once every 10 years for about

10 weeks. Addition of Unit 3 would significantly increase the frequency of drought flows

downstream, and the duration of those droughts. The change to drought flows once every

2.6 years, for median duration of 7 weeks, is a significant change from conditions prior to the

plant/reservoir construction (see item 4(b), below), and demonstrates the need for cumulative

analysis of biological impacts. (DW-0439 10) (SW-0017 18)

Response: Comparisons to the steam flow conditions to those areas below the dam prior to

reservoir construction are outside the scope of this EIS review. NEPA requires an analysis of

the changes to the existing environment; the existing environment for this EIS includes Lake

Anna and NAPS Units 1 and 2. Therefore, the appropriate comparison of the length and

frequency of drought conditions in the context of the comment is between the existing

conditions and the conditions resulting from the operation of the proposed Unit 3 closed-cycle,

combination wet and dry cooling system. Such a comparison is made in Section 5.3. The

characteristics of drought conditions prevalent in the North Anna region predating the

construction of the reservoir are only relevant to the degree that the historic data can be

analyzed in the context of the existing reservoir. The comment is instructive to point out that

droughts are part of the normal climatic variability within any ecosystem. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: During these [drought] periods, the problem [future water supply demand] will be

further compounded by the minimum release of 20 cubic feet per second from the Lake Anna

dam. (DW-1157 8)

Comment: The increased loss from the “once through” cooling process raises the period of

minimum release from the dam of 20 cfs from 5.8 percent to 11.8 percent and the amount of

time of lower lake levels (those below 248 feet above sea level or less) from 5.2 percent to

11.6 percent not only affects recreational use but also future water demands. Furthermore,

according to the findings of staff, severe drought periods could have a temporarily moderate
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impact. In its current form, the draft EIS states that due to the temporary nature of drought

conditions, no mitigation is suggested. PEC strongly believes that the EIS must expansively

define “moderate” in this case, and explain why no mitigation is an option. (DW-1157 10)

Comment: The draft Environmental Impact Statement states that there will be moderate

impacts on the quality of water in Lake Anna during drought years, and small to moderate

impacts during normal years. This is unacceptable to me, a resident of Richmond and

recreational user of Lake Anna. (DW-0617 2)

Response: NRC has established a standard of significance for impacts using Council on

Environmental Quality (CEQ) guidance (40 CFR 1508.27). NRC has defined MODERATE

impacts as “Environmental effects [that] are sufficient to alter noticeably, but not to destabilize,

important attributes of the resource.” The staff concluded that the impact to water use would be

temporarily MODERATE during drought conditions because of the projected decrease in lake

levels and downstream flows associated with the forced evaporative losses of the wet portion of

the proposed Unit 3 closed-cycle, combination wet and dry cooling system. However, the staff

also concluded that because droughts are temporary events for which water supply systems are

designed to compensate, the impact would not destabilize the water resource. The lake level

would be expected to return to normal levels with the return of normal precipitation in a manner

similar to the period after the 2001-2002 drought. During periods when rainfall, streamflow, and

associated lake level are at climatic and hydrologic norms, the proposed Unit 3 would not

noticeably affect the water resources of Lake Anna, and impacts would be SMALL, as described

in Section 5.3 of this EIS.

The Commonwealth of Virginia, which has jurisdiction over managing the water resources of

Lake Anna and the North Anna River downstream of the dam, may mitigate impacts to the water

resources by requiring Dominion to derate or suspend operations of one or more units at North

Anna in periods of severe drought and associated low water levels. The staff did not identify

feasible mitigation alternatives other than derating. Alternative cooling system designs are

discussed in Section 8.2. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: [T]he North Anna watershed is too small to allow large water withdrawals. These

would adversely affect the beneficial uses of the North Anna river. The analysis clearly

indicates that the third unit would increase the drought cycle and cause decreased water flows

during seven months of the year. (ST-0014 5)

Comment: Evaporative cooling towers will siphon off an enormous amount of water,

continuously. ...The withdrawal of huge amounts of water from these relatively small reservoirs

fed by a relatively small watershed will most certainly adversely affect the local environment
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especially the waterfront. During periods of low rainfall, drought, reservoir levels have

dramatically lowered reducing the existing surface acreage for "natural" evaporative cooling. 

(SW-0015 2)

Response: The water use conflicts issue is a principal issue in this environmental review. In a

water budget, as with all other budgets, a finite resource is allocated to serve multiple

objectives. The management of water resources involves balancing objectives among these

multiple conflicting objectives. In the case of the Lake Anna and North Anna River water

resource, these objectives include: providing water for current and likely future downstream

water users, providing water for downstream habitat, maintaining relatively stable lake levels,

and providing a reliable water supply for industrial facilities including the existing NAPS and

proposed Unit 3.

The staff made no attempt to balance these objectives. Rather, the staff simply disclosed the

impacts. Establishing policies that balance water-related objectives is the responsibility of the

Commonwealth of Virginia. Construction and operation of a plant at North Anna is predicated

on obtaining a variety of water related permits and certifications from the Commonwealth of

Virginia that are independent from a decision on this ESP application by the NRC.

The staff acknowledges that water conflicts could increase because of the reduction in the water

supply as result of consumptive water losses from the operation of the proposed new facility. 

These conflicts would be greatest when the available water supply is already limited because of

climatic factors. Drought conditions or increases in future water demands could result in

intervention by the Commonwealth in the apportionment of the water. Such intervention might

include operational restrictions during periods of water use conflict. The staff’s water use

assessment is documented in Section 5.3 and in Appendix K of this EIS. Accordingly, no

changes were made to this EIS as a result of these comments.

3.3.2.7 Flow and Water Budget

Comment: Crucial data for making informed analyses are not known, including, quote, a

reliable water budget of North Anna. What does that mean? That’s how much water is flowing

in and flowing out. This means they don’t really know how much water is flowing in or flowing

out. Nor have measurements been taken on the velocity of the water flow within the lake. Yet

the NRC staff admits in the draft EIS that these data are necessary for both understanding the

hydrodynamics of the lake and to calibrate the models. With such inadequate data about the

lake’s hydrology, how can NRC staff conclude that the impacts of another once through reactor

on the lake will be small? (DT-0019 2)

Comment: The NRC must gather all of the necessary information about the lake and do all of

the necessary analyses before making conclusions about whether there is sufficient water in

Lake Anna to operate another once through reactor. (DT-0019 9)
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Response: It is standard hydrologic engineering practice to approximate or extend the

discharge for a basin by scaling measured discharges from similar local basins. Therefore,

while a water budget was not available directly from the available measured streamflows in the

study basin, it was possible to adequately approximate streamflows by using an adjacent basin;

for this analysis the staff used the adjacent Little River drainage basin adjusted for the

differences in drainage areas.

The staff relied on the conservation of mass (i.e., in this case, the conservation of water)

principle in its independent analyses. The staff’s independent assessment is described in

Appendix K. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: The DEIS completely fails to provide a convincing case for its conclusion that the

impact of those reductions in release will be SMALL. If low flows are not a problem, why did the

DEQ establish those requirements in its NPDES permit? (DW-0589 14)

Response: The staff performed an independent assessment of the impacts that forced

evaporative losses of water would have on the lake and downstream water budget. This

assessment is provided in Appendix K of this EIS. The assessment was based on the current

hydrological conditions and the estimate of the rate of the forced evaporative loss listed in

Appendix I from Dominion’s Plant Parameter Envelope (PPE). The staff determined that the

evaporative losses associated with the operation of a closed-cycle, combination wet and dry

cooling system for Unit 3 (approximately 19 cfs) would result in declines in the lake level and

reductions in downstream flow. Accordingly, the staff concluded that during such drought

conditions, the impacts would be temporarily MODERATE. NRC has established a standard of

significance for impacts using Council on Environmental Quality (CEQ) guidance

(40 CFR 1508.27). NRC has defined MODERATE impacts as “Environmental effects [that] are

sufficient to alter noticeably, but not to destabilize, important attributes of the resource.” 

In determining the impact level, the staff considered the valuation of the water resource by the

Commonwealth of Virginia. The Lake Level Contingency Plan, which sets discharge rate based

on lake level, was considered by the NRC staff in the evaluation of the North Anna water

supply. The Commonwealth of Virginia has jurisdiction over allocating water. Drought

conditions or increases in future water demands could result in intervention by the

Commonwealth on the apportionment of the water, including the lake outflow rate. 

The lake is operated at the stable lake level of 76.2 m (250 ft ); this is the upper operating

height that would not result in submerging docks and boat ramps that were constructed around

the lake nor inundating additional land around the lake. When water is plentiful and the

stable lake level is easily maintained, the lake outflow is comparable to the lake inflow. 

Consequently, up to the point that lake outflows (including natural and induced evaporative

losses from Units 1 and 2, forced evaporative losses from Unit 3, and releases from the

dam) begin to exceed lake inflows, the lake is operated at the stable lake level. Once the
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lake outflows exceed the lake inflows, the lake level begins to decline; such scenarios were

analyzed as well. These analyses included the normal minimum flow of 1.1 m3

/s (40 cfs) when

the lake level is between 250 and 248 feet (76.2 and 75.6 m). When the Lake Level

Contingency Plan is implemented (at lake levels below 248 feet [75.6 m]), the release is limited

to 0.57 m3

/s (20 cfs) to reduce further lake declines.

Comment: The stream gauge data at Partlow, Virginia, was used to estimate outflow from

Lake Anna Dam. [page 5-5, line 7] (DW-0423 28)

Response: This information was used to revise the text in Section 5.3 of the EIS.

Comment: Suggest that this DEIS wording reflect the description in Part 4, Section 1.2.2.3.2 of

Dominion’s ESP application. The site drainage system would be designed to incorporate the

flow currently conveyed by these streams to the lake. By providing alternate drainage facilities

to convey the stream flows, no short-term or long-term adverse hydrologic impacts on site

drainage would result. [page 10-5, line 19, Page 10-6, Table 10-1, line 5] (DW-0423 49)

Response: It would be most effective to address drainage facilities when the station design

alternatives are specified; commenting on a plan without the details to characterize its

effectiveness to mitigate effects would be speculative. Accordingly, no changes were made to

this EIS as a result of this comment.

Comment: DWR [Commonwealth of Virginia, Department of Environmental Quality, Division of

Water Resources] examined pre-gauge records and compared those streamflow records with

projected releases with three reactors operating in a once-through cooling mode. This is not a

true IHA [Indicators of Hydrological Alteration] analysis but it is presented in order to give some

perspective of the magnitude of true pre- and post-project conditions. 1) Prior to the project,

flows at the dam site were less than or equal to 20 cfs only 4.2% of the time; with the third unit,

flows are projected to be 20 cfs 11.8% of the time; 2) Prior to the project, flows at the dam site

were greater than or equal to 156 cfs 52% of the time (pre-dam Doswell gauge); with three

units, flows will be less than or equal to 40 cfs 52% of the time (Draft EIS, page 5-12,

Section 5.4.1.3); 3) Prior to the project, during the driest 14-month period on record (early

May 1931 to early July 1931) streamflow in the North Anna River averaged 90 cfs over the

14 months. With the three units, the driest 14-month period (mid- September 2001 through

mid-January 2003) streamflow in the North Anna River would average only 20 cfs. DWR

disagrees with the conclusion in the Draft EIS that these pre- and post-project flow alterations

and their impact can be described as small or moderate. Instead, DWR would characterize

these types of alterations as large. (DW-0439 16) (SW-0017 23)

Response: In determining the impact level, the staff considers the valuation of the water

resource by the Commonwealth of Virginia. The Lake Level Contingency Plan, which sets

discharge rate based on lake level, was considered by the NRC staff in the evaluation of the
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NUREG-1811, Volume II 3-70 December 2006

North Anna water supply. The Commonwealth of Virginia has jurisdiction over allocating water. 

Drought conditions or increases in future water demands could result in intervention by the

Commonwealth on the apportionment of the water. For the purposes of this NEPA evaluation,

the stream flow conditions prior to reservoir construction are outside the scope of this EIS

review. The characteristics of drought conditions prevalent in the North Anna region predating

the construction of the reservoir are only relevant to the degree that the historic data can be

analyzed in the context of the existing resources. NEPA requires an analysis of the changes to

the existing environment; the existing environment for this EIS includes Lake Anna and NAPS

Units 1 and 2. Therefore, the appropriate comparison of the length and frequency of drought

conditions in the context of the comment is between the existing conditions and the stream flow

conditions resulting from the operation of the Unit 3 closed-cycle, combination wet and dry

cooling system. Such a comparison is made in Section 5.3. Accordingly, no changes were

made to this EIS as a result of this comment.

Comment: [H]ow can we accurately estimate total inflow when (according to the draft EIS)

there is no way to estimate the total inflow from the tributaries that directly flow into the lake? 

(DW-1157 13)

Comment: Water impacts – a defensible water budget is required for any reasonable modeling

to be done and for any results to be meaningful. (DW-0432 4)

Comment: The DEIS does not sufficiently address whether there is an adequate water supply

in Lake Anna for the operation of another once-through reactor. In fact, the necessary in-depth

analyses to determine the impacts on Lake Anna or to mitigate those impacts are put off to the

COL stage or are to be determined by the Commonwealth of Virginia at a later date – after the

NRC has already granted the ESP. For example, according to the DEIS, “because of the limited

inflow data, it is not possible to create a reliable water budget for Lake Anna directly from inflow

and discharge measurements” (page 2-21, line 31). Nor have water velocity measurements

within the lake been recorded. Yet, the DEIS makes it clear that these data are “important for

both understanding the hydrodynamics of the lake and to calibrate numerical models of fluid

and heat transport process in the lake” (page 2-22, line 2). In place of velocity measurements,

NRC Staff estimated the inflow using data from an adjacent drainage basin and outflow based

on the operating rules for the Lake Anna Dam. (DW-0437 5)

Comment: With such inadequate data about the lake’s hydrology, how can NRC Staff

conclude that the hydrological impacts of another once-through reactor on the lake will be

“small” (page 5-7, line 18)? (DW-0437 7)

Comment: Page 2-21 line 31 is very troubling. It states that “it is not possible to create a

reliable water budget for Lake Anna.” How then, can any of the impact forecasts be reliable? 

(DW-0438 36)
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 December 2006 3-71 NUREG-1811, Volume II

Comment: Page 5-4 line 20 references a water budget model yet on page 2-21, the document

states that a reliable water budget model does not exist. (DW-0438 126)

Comment: Page 5-9 line 10 references a water budget model yet on page 2-21, the document

states that a reliable water budget model does not exist. (DW-0438 140)

Response: The complete sentence (page 2-21, line 31) states, “Because of limited inflow data,

it is not possible to directly create a reliable water budget for Lake Anna directly from inflow and

discharge measurements.” It is standard hydrologic engineering practice to approximate or

extend the discharge for a basin by scaling measured discharges from similar local basins. 

Therefore, while a reliable water budget was not available directly from the available measured

streamflows in the study basin, it was possible to adequately approximate streamflows by using

an adjacent basin; for this analysis the staff used the adjacent Little River drainage basin

adjusted for the differences in drainage areas. Accordingly, no changes wee made to this EIS

as a result of these comments. The staff’s independent assessment is described in

Appendix K. 

Comment: ER Sections 5.2.2.1.1 and 5.2.2.1.2 describe the formulation of the water balance

model and the conservative methods used to calculate inflows. The DEIS wording suggests

that inflow data was limited in some manner that adversely impacted the hydrological

assessment. This implication is not accurate. The current hydrological monitoring program is

appropriate and sufficient for its intended purpose. No changes to the hydrological monitoring

program regarding inflow data are necessary. [page 2-21, line 31] (DW-0423 7)

Comment: This DEIS wording is inconsistent with ER Sections 5.2 and 6.3 and suggests that

the absence of velocity measurements adversely impacts the ability of the cooling lake model

developed for North Anna. This is not accurate. The Lake Anna cooling lake model used to

predict lake water temperature was satisfactorily calibrated with field data collected during the

operation of the two existing units. Extension of the model to include additional units was

verified by laboratory experiments conducted by MIT. Also, some limited velocity measurements were made in the 1980s to support development of the MIT model. Velocity monitoring,

especially for the period before the additional units come on line, will not improve the prediction

capability of the Lake Anna cooling lake model. The current hydrological monitoring program is

appropriate, sufficient, and will be continued. No changes to the hydrological monitoring

program regarding velocity flow measurements are necessary. [page 2-21, line 40] 

(DW-0423 8.1)

Response: The Massachusetts Institute of Technology (MIT) model developed in the 1970s,

while innovative at the time it was developed, no longer reflects standard hydrologic engineering

practice. The model was calibrated by MIT specifically for Lake Anna. Two separate and

intensive calibration reports were produced by MIT in 1982 and 1984. Because the model had

been calibrated and verified, the staff concluded that the model adequately characterizes the
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NUREG-1811, Volume II 3-72 December 2006

temperature measurements in the lake for the operation of the existing Units 1 and 2 consistent

with the analytical methods employed (i.e., spatial lumping) by the model. However, for this

assessment the staff needed to consider hydrodynamic conditions that lie outside the zone for

which it was calibrated. Additionally, the spatial lumping involved in the model did not provide

the resolution necessary to resolve the spatial distribution of heat in the lake.

Portions of the MIT model are steady-state and the main lake’s upper 28 ft are assumed to be

homogeneously mixed. The staff concluded that these assumptions in the model and the

spatial lumping employed were not sufficient to assess impacts beyond its calibrated range. 

Therefore, the staff concluded that the model no longer reflects standard hydrologic engineering

practice for use as a predictive tool in determining the impact of the proposed Unit 3

closed-cycle, combination wet and dry cooling system. Use of models of Lake Anna that would

be consistent with current standard engineering hydrologic practice would have the following

attributes: (1) not steady-state in the WHTF and side-arms, (2) fully three-dimensional

non-hydrostatic in zones downstream of Dike 3, (3) dynamically represent thermocline depths,

and (4) compute dynamic lake water surface elevation. Unless a conservative bounding

approach is employed, a model consistent with standard hydrologic engineering practice would

be warranted to assess impacts. Current standard hydrologic engineering practice supported

by models that explicitly represent physical processes and provide for fine spatial resolution,

coupled with calibration and verification of local conditions, would provide the staff with

assurance that the model represents the conditions that could occur with the proposed Unit 3

closed-cycle, combination wet and dry cooling system. The staff used a theoretically based

model in accordance with current standard hydrologic engineering practice to independently

assess the impacts associated with the proposed Unit 3 cooling system. Accordingly, no

changes were made to this EIS as a result of these comments.

Comment: Page 5-5 discusses a very weak methodology for assessing water impacts. 

Line 16 acknowledges that the method has the potential for significant error. Given the

importance of the Lake to the region, a more rigorous analytical method should be used similar

to that used for FERC hydro applications for inflows. (DW-0438 130)

Response: The comment refers to Dominion’s approach, not the staff’s approach. The staff’s

independent water budget analysis was developed to address such concerns. The results are

contained in Appendix K. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: What was the length of the data set from which the data was extracted for the

analysis on Page 5-5 line 33? (DW-0438 131)

Response: Data from the Little River gauge from 1961 to the present were used in the water

budget calculations. No changes were made to this EIS as a result of this comment.
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 December 2006 3-73 NUREG-1811, Volume II

Comment: Were the Section 5.3 methodologies that were developed back-tested against

actual water levels? What was the level of significance of the match between the forecasts and

actual levels? (DW-0438 132)

Response: After developing its independent assessment approach, the staff compared the

predictions with measured outflow data during historic operation of Units 1 and 2. The staff

estimated that the residual error in flow projections would average less than 7 cfs or about

2 percent (when compared to an average inflow of 296 cfs). Accordingly, no changes were

made to this EIS as a result of this comment.

Comment: Why wasn’t actual site meteorological data considered for the analysis mentioned

on page 5-8 line 22? (DW-0438 137)

Comment: What duration of meteorological data was used for the [evaporation and heat loss]

analysis mentioned on page 5-8 line 22? (DW-0438 138)

Comment: PEC [Piedmont Environmental Center] contends that the data being used to

determine the precipitation rates and inflows into the lake is insufficient and therefore cannot

accurately depict the impact of two additional reactors at the Lake Anna site. The precipitation

data is from Richmond (35-40 miles away) and that due to a limited record of tributary flow

measurements the inflow data is from tributaries that do not feed, either directly or indirectly into

the lake. The Richmond data shows average yearly precipitation levels exceed that of

evaporation rates. However, monthly estimates show deficits from June through September by

as much as twenty percent. Even in normal years, deficits will appear during periods of

recreational use and those months where water demands are often at their highest levels. 

(DW-1157 11)

Response: Data from the Richmond airport from January 1978 through January 2003 were

used because it is considered representative of the site area for these purposes. In addition,

the data are collected routinely using the standard meteorological practices of the National

Weather Service and the record spanned a longer period. In its independent assessment, the

staff used daily data that represent the water deficit mentioned by the commenter. Accordingly,

no changes were made to this EIS as a result of these comments.

Comment: On the issue of inflow, does it make sense to review stream flow records from

June of 2000 through April of 2003 as the basis for a worst case scenario? The Draft EIS

clearly states that the period of extreme drought was experienced from October 2001 through

December 2002 resulting in the lowest estimated inflows in Lake Anna’s very short history. By

extending the period of review on either side of the documented extreme drought period, the

possibility of underestimating the impact is increased dramatically. (DW-1157 12)
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NUREG-1811, Volume II 3-74 December 2006

Response: The staff reviewed streamflows and precipitation records over a longer period than

was used in the water budget assessment. A drought with the severity of the 2001 to 2002

drought has occurred only once in the 100-year record. Specifically including the 2001 to 2002

drought in the analysis using a 25-year period would provide a conservative assessment.

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The data presented does not support a SMALL impact rating on page 5-7 line 19. 

The very fact that Unit 4 would be designed to use air coolers indicates that the water impacts

are much larger. (DW-0438 136)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The staff’s analysis demonstrated that Lake Anna can

support one additional reactor cooling system (whether once-through cooling unit or

closed-cycle, combination wet and dry) but not two additional once-through cooling units. The

proposed cooling system has since been changed to a closed-cycle, combination wet and dry

cooling system resulting in some water impacts that are less adverse than previously analyzed. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: [T]he document states that 20 cubic feet per second will increase from 6 percent of

the time to 11 percent of the time, which is like 22 days out of the year, going up to 40 days out

of the year. But the Dominion state in their presentation that the 20 cubic feet per second

discharge would only go from 5.2, maybe to 7 percent. And the difference really isn't explained

in the document why they're different. (ST-0028 8)

Comment: [T]he NRC should explain how its analysis concludes that low flows downstream of

Lake Anna, represented by a release from the dam of 20 cfs, will be present 11% of the time,

compared to Dominion's calculation of 7%, both increased from 5.2% figure for current

operation of Units 1 and 2. (SE-0046 3)

Comment: NRC concludes (page 5-11) that the discharge at 20 cfs will increase from 6% to

11% of the time if unit 3 operates as proposed. ... Dominion stated in their presentation that the

20cfs discharge would go from 5.2 to 7%. Please explain the difference. (SE-0027 9)

Comment: Page K-10, lines 4,20 and 31...ER section 5.2.2.1.2 describes in detailed the

methodology used by Dominion to assess lake levels under various operational scenarios. The

SDEIS could note that bounding assumptions used by the staff lead to a conservative, bounding

analysis. (SE-0050 16)

Comment: The estimates on frequency of 20-cfs flows provided in the applicant's Revision 7

differ significantly from those in the SDEIS. The discrepancy should be fully addressed and

resolved before the Final EIS is completed. (i) Analysis. Prior to construction of the North Anna

Dam, river flows were less than 20 cfs 4.2% of the time. Currently, flows are decreased to
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 December 2006 3-75 NUREG-1811, Volume II

20 cfs an average of 5.2% of the time. With the proposed Unit 3 wet-dry cooling system,

according to the applicant's analysis, the frequency and duration of these 20-cfs events would

increase to 7.3% of the time. However, according to the NRC's analysis (SDEIS, Appendix K,

page K-12 and page 5-11, section 5.3.2), the 20-cfs events would increase to 11.0% (not 7.3%)

with the closed cycle unit 3 instead of the 11.8% of the time for 20-cfs events with a once

through Unit 3. This is a slight improvement from the original proposal, which would have

resulted in reducing flows to 20 cfs 11.8% of the time. With the existing two units, according to

the applicant's analysis, there are two 20-cfs flow events predicted over a 24-year period. The

proposed Unit 3 would increase that to five such events over a 24-year period. With a third unit,

the duration of the first two events is increased by an additional 4 to 5 weeks. The three

additional events have durations of 2 to 13 weeks. According to the NRC analysis, that would

increase to seven events. These predictions need to be re-evaluated in light of the NRC

analysis. (SW-0017 44)

Response: The staff and Dominion performed independent assessments. The staff performed

a bounding evaluation for the information provided in the PPE. Dominion’s analysis reflected

some information not explicitly incorporated in the PPE that tends to reduce the consumptive

water use during low water periods relative to wet periods. The text of Section 5.3.1 has been

modified to describe the source of some of the differences in the two assessments. 

Comment: [Regarding Dominion’s ER] Tables 5.2-3 and 5.2-4 Percentage of time outflow is

20 cfs will increase from 5.2 % to 7.3% with unit 3 in place. This 7.3% equals to an average of

27 days per year. Some years more. Some years less. It should be pointed out that this will

most probably occur during July, August, September months. Please explain why in table 5.2-4

at elevation 248 existing units plus unit 3 is 7.0% and not 7.3%. (SE-0004 25)

Response: It appears that Table 5.2-4 in the ER is incorrect and that the value should be

7.3 percent and not 7.0 percent. In Section 5.3.1 and K.5 of this EIS, the staff reported the

value of 7.3% based on its performance of an independent assessment. Accordingly, no

changes were made to this EIS based on this comment.

Comment: [Concerning 100% load vs 96% average] In the summer months when the lake

levels are lowest, evaporation highest and plant operations are closest to 100%; this value of

100% should be used. In EC mode I see in table 3.1-9 16,700 GPM maximum and not 8707 or

9070 GPM. Explain? (SE-0004 3)

Response: The 96 percent load factor only applies to the annualized average flows. The

maximums reported are instantaneous maximums and, therefore, the 96 percent load factor

does not apply. The value of 16,695 gpm reported in Table 3.1-9 refers to the instantaneous

maximum evaporation rate in EC mode. EC mode only occurs when the lake is at or above
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NUREG-1811, Volume II 3-76 December 2006

250 ft. The 8707 gpm value refers to the annualized average evaporation based on a

96 percent load factor. The text in Section 5.3.1 has been expanded to explain that the staff

considers the 8707 gpm value a bounding annual average value independent of the actual load

factor.

Comment: In light of the National Environmental Policy Act (NEPA) requirement that an EIS

analyze all “reasonably foreseeable” impacts, the NRC analysis clearly falls short, because its

water budget model is not predicated on any credible, forward-looking scientific estimates of

what hydrological conditions within the North Anna-Pamunkey drainage could be like for the

next 40 – 60 years, including population increases, water table levels and recharge rates,

competing uses for surface waters that could limit inflows to the lake, projected climate trends

and attendant effects on evaporation rates, population increases, and so forth. (SE-0040 5)

Response: The staff considered projected future water demands based on county growth

plans. In Section 5.3.2 of the EIS, the text mentioned that one of the four downstream counties,

Hanover, has identified a need for additional water that could be impacted by the consumptive

water use by Unit 3. The staff has acknowledged in the EIS that water conflicts are likely,

particularly in low water years. Additionally, the staff reviewed the National Assessment

performed by the National Assessment Synthesis Team, US Global Change Research Program

(http://www.usgcrp.gov/usgcrp/Library/nationalassessment/overview.htm) in considering the

potential change in water supply associated with climate change. The National Assessment

reports that the observed precipitation changes during the last century are a patchwork of

moderate increases and decreases. While the models used in the National Assessment are

consistent in predicting an increase in temperature, the projected impact on precipitation is less

clear. The Canadian model scenario for the 21st century indicates near neutral trends or

modest increases, while the Hadley model projects increases of near 25% for the region. While

acknowledging the significant uncertainty in these climate change projections, the staff

concludes that climate change would be an additional factor that could change the future

demand for resources including water and power. The staff believes the National Assessment

provides an adequate basis to make an impact determination at this time. However, an

evolution of climatic conditions would likely result in the Commonwealth revisiting water

apportionment priorities. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: [P]age 5-7 line 26 concludes that “relatively small errors in the pool elevation

measurements using this model [the Massachusetts Institute of Technology model used by

Dominion] 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. (SE-0045 23)
Comments Within Scope

 December 2006 3-77 NUREG-1811, Volume II

Response: This comment refers to the staff’s finding regarding Dominion’s water budget

analysis. The staff’s impact conclusion of SMALL was based on a separate assessment that

applied data from an adjacent basin to estimate the inflows into Lake Anna. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: [T]here are numerous and severely debilitating problems with the NRC-Dominion

water budget analysis for Lake Anna. As the NRC staff itself notes, “inherent in this analysis is

the assumption that the 23-year period of record simulated would be representative of future

conditions (e.g. inflows, precipitation, etc.) at the site.” (NUREG-1811, SDEIS, Appendix K-13. 

(SE-0040 4)

Response: The period of October 2001 through December 2002 is included in the 23-year

period considered in the staff’s assessment. Based on the Richmond airport records from

January 1, 1921 to May 31, 2004, the combined precipitation during water years 2001 and 2002

was the driest 2-year period in the precipitation record. The staff concluded that including this

period in the analysis provides confidence that the 23-year period is not unrepresentative of

critical low water conditions. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: [T]he NRC staff estimate of historical inflows to the lake is not based on actual

measurement of flows in the North Anna River drainage area, but estimated from flows in a

smaller nearby (Little River) drainage for which there was historical data, and then scaling the

results to estimate inflows to Lake Anna. Local precipitation is estimated based on rain gauges

at the Richmond Airport, some 40 miles away. This methodology, and its historical bias,

suggests that the model results are at best a gross approximation, and heightens the

importance of a sensitivity analysis of the results. (SE-0040 6)

Response: Long-term inflow measurements for each of the tributaries that contribute water to

Lake Anna are not available. The staff employed an accepted practice of scaling streamflow

measurements from an nearby watershed to estimate flows at other locations. Data from the

Richmond Airport provided an independent long-term meteorological record. Accordingly, no

changes were made to this EIS as a result of this comment. 

Comment: [T]here is no evidence that the NRC performed an analysis to test the sensitivity of

its historical model results to plausible variances in the input data. For example, what is the

effect on lake temperatures, on natural and induced evaporation rates, and coolant intake

requirements if one assumes a small but steady increase in average surface temperatures over

the next 60 years, punctuated by periods of that combine reduced precipitation with

above-average summer temperatures? (SE-0040 7)
Comments Within Scope

NUREG-1811, Volume II 3-78 December 2006

Response: Each year of the staff’s analysis represents a unique plausible scenario with unique

inflows and temperatures. The time series of predictions is the extent of any input sensitivity

analysis considered by the staff. The example in this comment appears to be referring to

climate change as an element of sensitivity. The staff did review the National Assessment

performed by the National Assessment Synthesis Team, US Global Change Research Program

(http://www.usgcrp.gov/usgcrp/Library/nationalassessment/overview.htm) in considering the

potential change in climate on water conditions. The National Assessment reports that the

observed precipitation changes during the last century are a patchwork of moderate increases

and decreases. While the models used in the National assessment are consistent in predicting

an increase in temperature, the projected impact on precipitation is less clear. The Canadian

model scenario for the 21st century indicates near neutral trends or modest increases, while the

Hadley model projects increases of near 25 percent for the region. While acknowledging the

significant uncertainty in these climate change projections, the staff believes that climate

change would be an additional factor that could change the future demand for resources

including water and power in the future. The staff believes the National Assessment provides

an adequate basis to make an impact determination at this time. However, an evolution of

climatic conditions would likely result in the Commonwealth revisiting water apportionment

priorities. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: One can envision the formation of a damaging negative feedback loop, in which

increased natural heating of cooling intake water increases the evaporation rate of both the

wet-dry and existing once-through cooling systems, leading to higher discharge temperatures

and/or increased net withdrawals from the lake, leading to reduced lake volume via increased

lake-surface and/or coolant tower evaporation (the heat has to be dissipated somewhere),

leading to further heating of the reduced volume of intake water, and the cycle repeats itself. 

(SE-0040 8)

Response: The staff presumes that the comment was meant to say “damaging positive

feedback loop” and not “damaging negative feedback loop”. Both positive and negative

feedbacks are possible in a system such as Lake Anna. The comment suggests a positive

feedback. Negative feedbacks include the increase in heat loss other than evaporation with

increased surface temperature from longwave back radiation. The staff identified a specific 

concern of a possible positive feedback from the increased temperature attributable to the

reduced lake volume caused by the consumptive water loss from the proposed Unit 3 cooling

system. The staff requested Dominion to estimate the increase in temperature from the

reduced water in Lake Anna. Dominion estimated and the staff confirmed a value of 0.1(F

increase. The staff determined that this value was low enough that it did not represent a

significant feedback issue. Accordingly, no changes were made to this EIS as a result of this

comment.
Comments Within Scope

 December 2006 3-79 NUREG-1811, Volume II

Comment: DEQ's Division of Water Resources indicates that the Indicators of Hydrologic

Alteration (IHA) analysis performed by Dominion shows a highly altered flow regime below the

North Anna Dam, especially in the spring and fall. September is a possible exception to this

alteration because it is typically the month of lowest flow; in September, the North Anna River

actually retains some semblance of normal flow due to the minimum release from the dam. The

cumulative effects of Unit 3 on downstream ecosystems could be reduced by using the air

cooling system in spring and fall. (SW-0017 27)

Comment: The SDEIS prepared by the NRC Staff Fails to Analyze a Reasonable Range of

Reasonably Foreseeable Impacts from Operating Unit 3. ...the induced evaporation rate from

operation of the wet-dry cooling system is still 71 percent of the environmentally unacceptable

once-through system. The additional lake level drawdown under simulated drought conditions

is still almost half that of the once-through system, and there are major uncertainties associated

with this calculation that the NRC and Dominion have not bounded with a sensitivity analysis. 

(This analysis should be based on plausible excursions from and negative feedback interactions

between their model’s input parameters over the projected period in which the three reactors

will be withdrawing water from Lake Anna.) (SE-0040 3)

Response: The staff did not conclude that a once-through cooling system for Unit 3 would be

environmentally unacceptable. The staff has concluded that the temperature changes to the

lake would be significantly reduced with the revised design, whereas the impacts to water use

would be slightly reduced as a result of the reduced consumptive water demand. Accordingly,

no changes were made to this EIS as a result of this comment.

Comment: The SDEIS stated flowrate of 3340 gpm would only occur if potable water,

demineralized water and fire protection water maximum demands occurred simultaneously, not

just fire protection. Table 3.3-1 lists maximum supply rates for potable water (120 gpm),

demineralized water (720 gpm) and fire protection (2500 gpm). (SE-0050 1)

Response: The text in Section 3.2.2 of this EIS has been modified to clarify this statement.

Comment: The SDEIS could note [in Section 5.3.1] that the difference [between NRC staff's

analysis and Dominion's (ER) numbers] is caused by a difference in Dominion’s approach of

performing a detailed analysis, whereas the NRC staff performed a conservative, bounding

analysis. For example, the staff assumed the average evaporative loss from Unit 3 was a

constant value of 8707 gpm which is conservative and bounding and which leads to an

overestimation of Unit 3’s impact on lake level and dam outflow during times when the lake falls

below 250 ft msl. (SE-0050 10)
Comments Within Scope

NUREG-1811, Volume II 3-80 December 2006

Comment: The SDEIS could note [in Section 5.3.2] that the difference [between NRC staff's

analysis and Dominion's (ER) numbers regarding lake elevations] is caused by a difference in

Dominion’s approach of performing a detailed analysis, whereas the NRC staff performed a

conservative, bounding analysis. (SE-0050 11)

Comment: The SDEIS reflects the NRC confirmatory analysis and, while the results do not

exactly match those stated in the ER, the conclusion of SMALL IMPACT is unaffected by the

difference. The SDEIS could note [in Section 5.4.2.6] that the difference is caused by a

difference in Dominion’s approach of performing a detailed analysis, whereas the NRC staff

performed a conservative, bounding analysis. (SE-0050 12)

Comment: The SDEIS reflects the NRC confirmatory analysis [for water level] and, while the

results do not exactly match those stated in the ER, the conclusion of SMALL IMPACT is

unaffected by the difference. The SDEIS could note [in Section 5.5.1.4] that the difference is

caused by a difference in Dominion’s approach of performing a detailed analysis, whereas the

NRC staff performed a conservative, bounding analysis. (SE-0050 13)

Response: The text in Section 5.3 has been expanded to explain the differences between

Dominion’s and the staff’s independent analyses. 

Comment: The SDEIS on page 2-10 Section 2.6 Water, states “the historical pre-dam

minimum flows [usually less than 5cfs during dry summer months]” is in conflict the Department

of Game and Inland Fisheries (DGIF) where they state in their letter dated July 7, 2006 that

“pre-lake during dry conditions in late summer is a minimum of 12cfs flow. ... This is a large

difference and the effects are important relative to the amount of water flow into the watershed. 

The difference needs to be resolved. (SE-0027 1)

Response: The USGS stream gauge at Doswell (USGS 01671000) downstream of the North

Anna Dam records 4 distinct periods of daily flows below 5 cfs, 8 periods below 10 cfs, and

15 periods below 20 cfs. Based on this comment, this EIS has been revised to clarify the

frequency of low flow conditions.

Comment: While the hybrid cooling tower will address thermal impacts from the new reactors,

it will equal or increase the overall amount of water lost to evaporation. ...NRC asserts the

evaporation rates will be lower than 37.2 cubic feet per second for most of the year... and

25.7 cfs in drought conditions, but the reasons for this are unexplained and the analysis

questionable. (SE-0034 3)
Comments Within Scope

 December 2006 3-81 NUREG-1811, Volume II

Response: The values of 37.2 and 25.7 cfs refer to the instantaneous maximum water use in

the EC and MWC modes, respectively. The annual average consumptive water use is 19.4 cfs. 

The plant would be operated well below these instantaneous maximum values for much of the

time to stay within the annual average. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: [Page K-4, line 10] In Dominion letter to NRC, Serial No. 06-273, Response to

NRC Questions/ESP Application Rev. 6 (Item 10b response), Dominion noted that, in order to

account for the evaporation rate contribution of 404 gpm from the Service Water System cooling

tower, the average evaporation rate from all normal plant cooling wet towers is revised from

8303 gpm to 8707 gpm. The 8707 gpm (19.4 cfs) value was included in the ESP Application

Rev. 6 and later submittals. (SE-0050 26)

Response: The text throughout this EIS has been revised to reflect the 8707 gpm value.

Comment: The SDEIS could note that despite the potential negative inflow estimate in the

reversed routing method that Dominion used in the water budget model, any potential

uncertainties would be cancelled out in the model prediction for the new Unit 3 based on the

methodology adopted by Dominion. (SE-0050 9)

Response: While the reversed routing would compensate for errors in the historical case, it

could result in biases in the estimated induced evaporation estimates. These biases could

propogate when they are corrected for a baseline condition that assumes continuous operation

of the NAPS units. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: [Regarding Dominion’s ER] Figures 2.3-4 and 2.3-5 show the discharge [and] show

the spillway curves. Can you explain how you set 40 and 20 cfs from the curves which show a

minimum setting of about 2500 cfs for 250 msl for a 2 foot gate opening. (SE-0004 10)

Response: The 40 and 20 cfs flows are regulated by small skimmer gates that are

independent from the larger spillway gates. The spillway gates are used to control large

inflows. Accordingly, no changes were made to this EIS as a result of this comment. 

Comment: [H]ow much water (measured in cft) is delivered into the reservoirs by the

watershed? ...how much water (in cft) is currently evaporated from the surface waters of each

reservoir, separately...Is there consistently enough inflow to meet the demands of additional

evaporative cooling? ... We need a local environmentally neutral (read upstream here) baseline

body of water with which to compare the effects of the station. (SW-0015 3)

Response: The inflow and evaporation rates vary continuously during and between years. In

typical years, there is not enough inflow during late summer and early fall months to offset

natural evaporation. This would result in some decline in the lake, even in the absence of the
Comments Within Scope

NUREG-1811, Volume II 3-82 December 2006

existing NAPS induced evaporative demand. The NAPS units’ operation result in further

decline and the proposed Unit 3 would add to this decline. The magnitude and frequency of the

decline is discussed in Appendix K of the EIS. Accordingly, no changes were made to this EIS

as a result of this comment. 

Comment: NRC staff could clarify [page K-3, line 10] that the statement only applies when

water level in Lake Anna is greater than or equal to 250ft MSL. Below this level the net

discharge would be the same as pre-Unit 3 as the discharge is a controlled flow. When Lake

level elevation is below 250 ft MSL, but at or above 248 ft MSL, discharge from the Lake is

typically controlled to 40 cfs. Below 248 ft MSL, discharge from the Lake is controlled to 20 cfs. 

Depending on net inflow to the lake, the addition of Unit 3 could cause more frequent reduction

of net outflow to 20 cfs from 40 cfs. (SE-0050 25)

Response: The text in Appendix K has been modified to clarify that consumptive water loss is

only attributable to the wet cooling portion of the hybrid cooling system.

Comment: The SDEIS...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? (SE-0045 22)

Response: In the EIS, the staff concluded that the impact to water use occasionally would be

MODERATE during droughts. The Commonwealth of Virginia would regulate the water use of a

new facility operated at North Anna. Accordingly, no changes were made to this EIS as a result

of this comment. 

Comment: [Regarding Dominion’s ER] Table 3.1-9 Flow rates and evaporation rates should

be based on 100% power levels and not 96% as shown. For units 1 and 2, the units run at

100% during the summer hottest months and this 100% should be used for maximum

calculations when they effect water temperature, flow rates, evaporation, and lake height. 

(SE-0004 18)

Response: The instantaneous maximum flow rates are based on a 100 percent load factor. 

Dominion states that the 8707 gpm annual average evaporation is based on a 96 percent load

factor. However, the 8707 gpm value is a bounding value independent of the 96 percent load

factor qualifier. Accordingly, no changes were made to this EIS as a result of this comment.
Comments Within Scope

 December 2006 3-83 NUREG-1811, Volume II

3.3.2.8 Heat Dissipation System

Comments Received from Draft EIS Relating to Proposed Once-Through Cooling System

for Unit 3

Comment: The ER and DEIS discuss various alternatives for cooling proposed Units 3 and 4,

including: 1) Use of wet cooling towers might reduce thermal impacts on Lake Anna but would

increase the amount of water loss if the Lake is the source of the cooling water withdrawals,

2) 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, 3) Providing an alternative source of water for wet cooling

towers would eliminate the water problem, but the source of such water is not identified. It

seems likely that an alternative water supply, if any, would not be available nearby in the critical

summer months or drought periods without constructing an additional large reservoir to store

the water that might be available during wet periods, and 4) If dry cooling is feasible for Unit 4,

why is it not equally feasible for Unit 3? It thus appears that construction of even one new unit

at Lake Anna is likely to result in serious deficits in releases of water to the North Anna River,

contrary to the terms of the NPDES permit. (DW-0589 12)

Comment: Since there is less precipitation in July, August, and September, the low-flow period

is likely to occur during these months. According the NRC Staff, the reduction in water available

to be released from the dam will be another “unavoidable adverse impact” (DEIS, page 10-7,

Table 10-2), but it would be avoidable if the proposed third reactor was required to have a dry

cooling tower. This option should be evaluated in the Final EIS. (DW-0437 20)

Comment: Has an analysis been performed to consider the difference in impact if both of the

potential plants utilized dry cooling towers? Is there a non-trivial difference in the impact on the

lake between these two scenarios? Even if the difference is not significant, it may still be

recommended to Dominion to pursue dry cooling towers for both reactors in order to appease

public concern. (DW-1148 5)

Comment: We are pleased to learn that Dominion has proposed dry cooling for unit four, but

question why this method of cooling was not extended to unit three. (DW-1157 9)

Comment: [I]f you see fit to grant this permit, we would suggest the following recommendations would be needed in order to ensure this facility does not threaten the region[‘]s water

supply. 1) Require dry cooling at both proposed units - The increase in water use from the once

through cooling of Unit three threatens existing and future uses of the lake and the North Anna

River. The loss of efficiency by using dry cooling for both additional units would be offset by

water availability for lake and downstream users and fishery maintenance. (DW-1157 17)
Comments Within Scope

NUREG-1811, Volume II 3-84 December 2006

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. Subsequently, Dominion revised the heat dissipation

system for Unit 3 to a closed-cycle, combination wet and dry system. This response addresses

those elements of the comments still relevant after this revision. The existing units are required

to meet the conditions of the NPDES permit, and the proposed new units would have to meet

any conditions imposed by the Commonwealth of Virginia in its NPDES permit as well. The

staff analysis concludes that Lake Anna can support a third unit using closed-cycle, combination

wet and dry cooling with SMALL to temporarily MODERATE impacts, as stated in Section 5.3.2

of the EIS. However, the staff did consider dry cooling for Unit 3 as an alternative in

Section 8.2.3 of this EIS. Nevertheless, the use of dry cooling towers was not proposed by the

applicant for Unit 3. Changes were made to Section 8.2.2 of the EIS to expand the discussion

of dry cooling as a result of these comments.

Comment: Consider designs, techniques, and technologies that will facilitate the re-circulation

and re-use of waters used for cooling and steam generation. These techniques can save

money by minimizing intake and treatment needs. (DW-0439 51)

Response: The comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. Several technologies were considered in the analysis

of alternative cooling systems including wet cooling towers, which operate with re-circulating

water. These are discussed in Section 8.2. The evaporative losses of solely wet-cooling towers

precluded its selection as the preferred cooling system for the proposed Unit 3. The proposed

change to a closed-cycle, combination wet and dry cooling system makes use of the

re-circulation benefits to minimize water intake and thermal releases. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: Page 1-6 line 3 states that the proposed fourth plant would use dry coolers. Is

there an operating nuclear plant in the U.S. that has demonstrated this technology is

appropriate and safe for such a large thermal load? If not the technology risks should be

assessed and discussed herein. (DW-0438 10)

Response: No U.S. nuclear plant uses dry cooling. However, dry-cooling technology is mature

and is used in other large industrial facilities. It has been used in a variety of thermo-electric

generating facilities in the United States and internationally. Operational safety of a dry-cooling

system is a design factor that the staff has identified as a COL action item in its SER; a COL

applicant would address the COL action items. Accordingly, no changes were made to this EIS

as a result of this comment.

Comment: What solution will work with the ESP and not effect current Environmental System? 

Several possible solutions are proposed. Obviously decommissioning either one or both

existing units 1 and 2 will keep the “status quo.” Next, a Dry Cooling tower can be built for each

Unit 3 and 4 or a larger one for both Units 3 and 4. Since there is a penalty for dry cooling of
Comments Within Scope

 December 2006 3-85 NUREG-1811, Volume II

8.5 to 11%, it would only be used when the WHTF reaches a temperature of 96 degrees F or

other prescribed conditions. Otherwise the once pass through cooling would be used. 

A second option would be to shut down one of the three units when the WHTF reaches a

temperature of 96 degrees F or other prescribed conditions. Any of the above solutions would

be generally acceptable to residents of the lake. A fourth option would be to introduce

supplemental cooling water other than from the reservoir. (DW-0806 12)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. Subsequently, Dominion revised the heat dissipation

system for Unit 3 to a closed-cycle, combination wet and dry system. Alternative cooling

systems are discussed in Section 8.2 of the EIS. The staff concluded that importing

supplemental cooling water was not a viable alternative and was not considered in the EIS. 

Decommissioning one or both of the existing units in order to build one new unit that would use

the lake as a cooling source is not an alternative proposed by Dominion and evaluated by the

staff. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Page 2-11 mentions that the summers are hot and humid. What is the suitability of

dry coolers (for the proposed Unit 4) to this climate? This could be problematic given the

statement on Page 2-13, line 15 that relative humidity is not measured at the site. 

(DW-0438 22)

Response: Humidity is not a major issue with dry cooling because the system does not rely on

evaporation but rather conductive heat transfer to the atmosphere. Dry cooling systems are

being used in the vicinity. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: Page 2-24 line 33 states that the proposed unit 4 is “expected” to use dry cooling

towers. Since this is the basis for the entire DEIS, Dominion should be required to stipulate to

this approach. (DW-0438 41)

Response: The staff has proposed a permit condition in the North Anna ESP Final Safety

Evaluation Report that Unit 4 use dry cooling. The text was modified in Section 2.6.3.1 to state

that Unit 4 would use dry cooling towers.

Comment: Chapter 3, Section 3.2.1.2 - If Unit 4 will be a dry cooling tower, then it will require

some combination of water treatments, which should be relatively straightforward based on the

draft designs. There should exist enough information for this analysis to be included in the

DEIS/SDEIS. (DW-1272 4) (SE-0030 18)

Response: Dominion has not selected a design for the dry cooling towers. Regardless of the

system selected, it would be a closed system without a significant discharge to the Lake Anna

reservoir. Accordingly, no changes were made to this EIS as a result of this comment.
Comments Within Scope

NUREG-1811, Volume II 3-86 December 2006

Comment: Can you answer the informal questions about the comparative cost for a dry cooling

tower for Unit 3 versus the once pass through cooling proposed? Have any studies been done

on sprayers in the WHTF? What about the cost versus cooling, evaporation, and aeration for

these sprayers? (DW-0806 14)

Response: In general, the capital and operating costs of dry-cooling systems are greater than

wet-cooling systems. Sprayers could be used to cool water by increasing evaporation;

however, increased evaporation would increase water loss and cause the level of Lake Anna to

decrease more than the dry cooling scenario. Sprayers are bounded by the wet cooling tower

alternative discussed in Section 8.2.1. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: ER Revision 3 does not address the water use impact due to the use of a new wet

cooling tower unit. [page 5-9, line 26] (DW-0423 32)

Comment: The DEIS conclusions are consistent with ER Section 9. However, the DEIS

comparison of two alternative heat dissipation systems (wet and dry cooling towers) with the

base case once-through cooling system is inconsistent with ER Section 9.4.2, which evaluates

alternative intake locations, discharge systems, discharge locations, water supplies, and water

treatment processes. The ER evaluation addresses land use requirements, aesthetics,

operating experience, generating efficiency, and capital and operating costs. [page 8-2] 

(DW-0423 47)

Response: These comments were received from Dominion based on the evaluation in the

Draft EIS of a once-through cooling system for Unit 3. The staff assessed the closed-cycle,

combination wet and dry cooling system for Unit 3; the alternative cooling system of solely wet

cooling towers is discussed in Section 8.2.1 of the EIS because the use of wet cooling towers is

a reasonable alternative to mitigate the thermal impacts on the lake. This evaluation is

consistent with NRC’s NEPA responsibility to consider alternatives to the proposed action. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: [Virginia] Division of Water Resources prefers the once-through cooling process

proposed for Unit 3 to a cooling tower because the once-through process results in less

consumptive use of water than the cooling tower. This preference would result in larger

impingement and entrainment losses . . . and a larger heat load to the Lake than the cooling

tower. DEQ’s Division of Water Resources recognizes that the cooling tower is not proposed in

the Draft EIS, but some commenters may propose it as a solution to thermal loading and

impingement and entrainment concerns. In any case, DEQ’s Division of Water Resources

would defer to DEQ’s Division of Water Quality in regard to thermal impacts of any water-cooled

units that might be proposed. The once-through cooling process would also entail larger
Comments Within Scope

 December 2006 3-87 NUREG-1811, Volume II

impingement and entrainment losses. DEQ’s Division of Water Resources defers to the

Department of Game and Inland Fisheries with regard to impingement and entrainment

estimates. (Note: the SDEIS evaluates a closed-cycle hybrid wet-dry cooling tower.) 

(DW-0439 17) (SW-0017 24)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, thermal impacts are negligible but evaporative losses

remain an impact. This comment describes the opinions of two agencies within the government

of the Commonwealth of Virginia regarding cooling options. One agency is responsible for

physical characteristics of water and one is responsible for oversight of the aquatic biota. 

Before the NRC may grant a CP or COL application that references an ESP for the North Anna

ESP site, the CP or COL applicant would be required to obtain a Clean Water Act, Section 401

certification from the Commonwealth of Virginia that the operation of the plant is not inconsistent

with the Commonwealth’s water goals. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: Has NRC or Dominion looked into the possibility of using water from the New

James River Pipeline that is currently under construction for supplemental water for cooling? 

(DW-0806 13)

Response: Importing water from another basin was not considered a reasonable alternative by

the staff because the assessment of the environmental impacts (land use, cultural resources,

terrestrial ecology, aquatic ecology, wetland, etc.) associated with building a large pipeline from

an undesignated location would be speculative. Accordingly, no changes were made to this EIS

as a result of this comment.

Comments Received from SDEIS Relating to Proposed Close-Cycle, Combination Wet

and Dry System for Unit 3

Use Dry Cooling

Comment: Dominion should if it's serious about wanting to protect this community's water,

about protecting the people on the lake so that they can use their boats and they can fish and

they can really enjoy that environment and doing what's best for Virginia, they really should get

a dry cooling tower if they want to even put this proposal forward. (ST-0005 8)

Comment: [W]e feel strongly that because Dominion obviously is considering a dry cooling

tower for the fourth tower, the third tower should be dry cooling tower as well. (ST-0005 4)
Comments Within Scope

NUREG-1811, Volume II 3-88 December 2006

Comment: Relative to Unit 4, I don't think enough attention has been given to Unit 4, and its

dry cooling. ...I think Dominion should explain this new technology, and state why it would or

would not work for Unit 3. (ST-0028 9)

Comment: DEQ should require Dominion to use a dry cooling tower for the third reactor. A dry

cooling tower system...would eliminate both thermal and evaporative impacts from the project,

and would not be an unreasonable burden on Dominion. (SE-0034 4)

Comment: DGIF recommends use of dry cooling for Unit 3 as a solution to lake level problems

and downstream flow reductions. (SW-0017 25)

Comment: Not enough attention has been given to unit 4 and its dry cooling. ... Since the ESP

is good for 20 years, why not include unit 3 with this same technology...Please explain this new

technology and state why it will not be available for unit 3. (SE-0027 11)

Comment: [W]hy can't Dominion use a completely air-cooled tower for Unit 3, as well as what

they talk about for Unit 4. (ST-0028 7)

Comment: Why can’t Dominion use this method [dry cooling] for unit 3 as well as unit 4? 

(SE-0027 7)

Comment: It appears from the SDEIS and the comments by DEQ that use of a dry cooling

tower for reactor unit #3 would alleviate many of these issues and should therefore be

considered further as an alternative design. (SE-0047 6)

Comment: Dominion Power could resolve these issues [caused by increased water

evaporation] by building a dry cooling tower for the new reactors. (SE-0035 4)

Comment: Use of a dry cooling tower, discussed only for Unit 4, would eliminate the water

consumption problem for that unit. If dry cooling is feasible for Unit 4, why is it not equally

feasible for Unit 3? That alternative is not evaluated. (SE-0038 3)

Comment: One alternative discussed, but not proposed in the SDEIS is to exclusively use dry

Air Cooling for the 3rd unit, which would then negate any further water withdrawals from the

small watershed...The dry-air cooling appears to be a feasible option, since this is same

technology that Dominion has proposed for Unit 4 and is used by many overseas countries that

do not have a local water source. (SE-0022 15) (ST-0014 7)

Comment: Are there any other cooling designs been contemplated? Is that it? And if not, if

Number 4, the dry tower's obvious conclusion to cooling number 4, why are we not using it in

Number 3? (ST-0035 1)
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 December 2006 3-89 NUREG-1811, Volume II

Comment: We request that alternative analysis for the 3rd unit cooling method be

accomplished to fully consider dry air cooling for the 3rd unit as used by many overseas

countries to eliminate the consumptive water loss associated with using wet cooling towers. 

(SE-0022 35) (ST-0014 22)

Comment: [I]f it's [dry cooling] good enough for Unit 4, why isn't it good enough for Unit 3? 

(ST-0030 4)

Comment: The technology currently exists to mitigate the adverse conditions [of increased

water use and changing water levels] using dry cooling, albeit not quite as economically

rewarding as a proposed cooling tower. Additionally dry cooling can be used regardless of lake

levels, if we suffer an extended drought with water levels falling 10 or more feet at least the

2 new dry cooled units could continue to operate safely. (SW-0015 6)

Comment: [I]f wet/dry cooling is better than once-through cooling, and your fourth reactor is

planned for dry cooling, why don't we have dry cooling for the third reactor? (ST-0032 1)

Comment: [W]ouldn't the dry cooling be an even bigger improvement to eliminate even that

problem? And I guess I'd like to know why Dominion isn't considering it, and why the Nuclear

Regulatory Commission isn't requiring it. (ST-0007 3)

Comment: In their comments on the DEIS and the SDEIS, reviewers recommended using dry

cooling for Unit 3, as proposed for Unit 4, stating that they would have no concerns about this

project if both the third and fourth reactors proposed at North Anna were air cooled. According

to the DEIS, Unit 4 operating as an air-cooled system would use a maximum of 1 gpm of water

and would have negligible water-related impacts on Lake Anna, the cooling lagoons, or the

North Anna River. Environmental concerns raised during our review of the Draft EIS and SDEIS

are water-related. The SDEIS fails to analyze an air-cooled Unit 3 alternative despite

recommendations by several reviewers. (SW-0017 1)

Comment: Dominion itself has recognized that Lake Anna would not support once-through,

wet-cooling, or even a combination wet and dry cooling system for a fourth unit, and is therefore

proposing an exclusively dry cooling system for this unit, construction of which is purely

speculative at this point. Of course, this fact begs the question of why dry-cooling could not

also be employed for the proposed Unit 3. ...the SDEIS fails to identify the dry-cooling option as

an” environmentally preferable” alternative deserving of further analysis. As justification, it

merely states that “dry cooling systems are more expensive to build and are not as efficient as

wet cooling systems.” ...coincident with its judgment that a parasitic load of 150 MW(e)—if

indeed it is that large—would be too burdensome on the Unit 3 project, Dominion and the NRC

staff revised the ESP permit to increase the thermal output of Unit 3 by 200 MW(t), thereby
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NUREG-1811, Volume II 3-90 December 2006

allowing them to recover almost half of the electric output that would be “lost” to operation of the

dry-cooling system. ... Whatever the real motives at work, the SDEIS analysis of the dry-cooling

alternative for Unit 3 is clearly inadequate. (SE-0040 12)

Comment: An air-cooled Unit 3 would eliminate, [or further reduce concerns related to water

supply and quality, smallmouth bass abundance downstream, potential impingement and

entrainment losses, water-related recreation, and the need for an analysis of cumulative

impacts on downstream hydrology and biology.] (SW-0017 5)

Comment: If you are a regulated industry, and your charges are based on your cost to some

great extent, your costs are more, your rates are greater, you still make money, everybody's

happy, so why don't we go with dry cooling for three and four? (ST-0032 2)

Response: These comments recommend that Unit 3 use a dry-cooling system. The applicant

proposed a closed-cycle, combination wet and dry cooling system, which the staff, after an

extensive analysis, found acceptable. The staff acknowledges that a dry cooling system would

effectively eliminate the consumptive use of water and thereby eliminate the impact to lake

levels in Lake Anna and flows in the North Anna River downstream of Lake Anna. However, a

dry cooling system comes with both an energy generation efficiency cost and direct economic

cost. In this ESP review, the staff did not consider the incremental capital cost of installing a dry

cooling system or the cost of operating such a system. However, the staff did consider the

environmental costs of the impact of reduced power generation with replacement fuel cycle

costs (increased spent nuclear fuel). The reduced efficiency associated with dry cooling would

increase nuclear fuel cycle impacts relative to the energy output. Accordingly, no changes were

made to this EIS as a result of these comments.

Comment: [T]he construction of a dry cooling tower appears to defeat the very purpose for

which the Early Site Permit is being sought because of the high utilization of electricity. 

(SW-0021 5)

Comment: My question is could you quantify the "high price in energy efficiency" please? 

(ST-0004 1)

Comment: [W]as it eight to 11 percent, you were calling it an inefficiency that would be added

by doing the dry cooling tower instead of a hybrid cooling tower, by efficiency or inefficiency,

you mean it is going to need eight to 11 percent more electricity to run the dry system? And my

question was is that correct? And also, what would be the cost? What kind of cost is that to

Dominion?...how much electricity are we talking about? ...How much this would cost Dominion

to make the third reactor completely dry like the fourth one would be. (ST-0005 1)
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 December 2006 3-91 NUREG-1811, Volume II

Response: In Dominion’s ER, the estimate of the inefficiency of dry cooling is stated as 8.5 to

11 percent of the plant output. Because costs are deferred to the review of a COL application,

the staff did not consider costs in this ESP review; therefore, no effort was made to estimate the

cost of a dry cooling system. Accordingly, no changes were made to this EIS as a result of

these comments.

Hybrid Cooling Technology

Comment: 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. (SE-0045 15)

Response: The ESP review described in this EIS is limited to an assessment of the impacts on

the site’s environment. In this review, the design of the plant was only bounded by the

applicant’s PPE. Therefore, the staff did not review a detailed hybrid cooling system design. 

However, based on the existence and operation of both wet and dry systems for large scale

thermoelectric power generation, the staff concluded that a hybrid cooling design is not

unreasonable for a nuclear facility bounded by Dominion’s PPE. The issue of the safety of plant

components is deferred to the safety review at the COL stage, if Dominion receives an ESP and

that ESP is subsequently referenced in a COL application. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: I am familiar with the hybrid cooling system proposed by Dominion in its modified

early site permit, and it seems to me that it's a responsive approach by Dominion that mitigates

the thermal impacts of the plants, when those impacts are critical, and allows for the maximum

efficiency of those plants under normal conditions. (ST-0033 1)

Response: This comment is acknowledged but provides no additional information. 

Accordingly, no changes were made to this EIS as a result of this comment.

Water Use/evaporation

Comment: NRC, we feel has done an inadequate analysis of the newly proposed hybrid

cooling tower system, particularly around the issue of water evaporation. ...NRC again has

given the impression that water evaporation will be significantly decreased by the new cooling

system. This, however, is incorrect. (ST-0005 2)

Response: The staff’s review was based on the PPE provided in Dominion’s ER. The annual

average induced evaporation stated in Revision 3 of the ER for a once-through cooling system

is 10,500 gpm, whereas the annual average forced evaporation stated in Revision 6 of the PPE

for a closed-cycle, combination wet and dry cooling system is 8707 gpm. While this reduction is
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NUREG-1811, Volume II 3-92 December 2006

not insignificant, the staff still concluded that the water use impacts would be MODERATE in

low water years. Accordingly, no changes were made to this EIS as a result of this comment.

EC/MWC Modes

Comment: [T]he Department of Game and Inland Fisheries (DGIF) recommends against the

7-day waiting period after lake levels reach trigger levels to initiate air cooling (Maximum Water

Conservation (MWC) mode). DEQ's Division of Water Resources endorses the DGIF

recommendation, which is that implementation of the MWC mode should take place when

downstream flows have a three-day rolling average at trigger points described [by the DGIF].

...According to DEQ's Division of Water Resources, the applicant endeavored to justify the

7-day waiting period by stating that the electricity needed to operate the air cooling system

might already be sold by the time the decision is taken to implement the MWC mode. However,

given the number of generation assets controlled by the applicant, and the interconnectivity of

the electric transmission system, this reasoning does not appear compelling to the Division. 

(SW-0017 28)

Response: This comment was provided by the Commonwealth of Virginia (VDEQ) as part of a

summary of comments received from various Virginia organizations. The policies for triggering

a change between EC mode and MWC would be set by the VDEQ through its permitting

processes. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Several reviewers indicated that the proposed reactors will further increase water

evaporation from Lake Anna, and the claim that the closed-cycle cooling tower is an

improvement with respect to evaporative loss over the once-through reactor is unsubstantiated. 

According to the SDEIS, the maximum instantaneous evaporation rate for the proposed

closed-cycle reactor will be 37.2 cfs in the Energy Conservation mode (most of the year) and

25.7 cfs in drought conditions (Maximum Water Conservation mode). In the Energy

Conservation mode, the rate is 11.2 cfs higher than the 26 cfs estimated for the once-through

reactor proposed in the Draft EIS. In the Maximum Water Conservation (MWC) mode, the rate

is only 0.3 cfs less than the once-through. (SW-0017 15)

Response: The values mentioned in this comment are instantaneous maximums for the EC

and MWC mode. A third bounding value was also listed in the PPE that constrains the annual

average evaporation to no more than 8707 gpm (19.4 cfs). The 19.4 cfs value should be

compared with the estimate for the annual average once-through cooling induced evaporative

losses and not instantaneous maximums. Therefore, on an annual average basis the

closed-cycle design is predicted to consume less water than the once-through design. 

Accordingly, no changes were made to this EIS as a result of this comment.
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 December 2006 3-93 NUREG-1811, Volume II

Comment: [NRDC notes that there may be some confusion about the environmental impacts

of the proposed "wet-dry" cooling system.] “During periods of favorable [but unspecified]

atmospheric conditions, more than one-third (and possibly as much as 100 percent) of the

rejected heat may be dissipated through the dry towers.” SDEIS, at K-4...[but that] although the

MWC [Maximum Waster Conservation Mode] mode uses less water than the EC mode, it is

possible that up to two-thirds of the total heat load would be dissipated by wet cooling.” [SDEIS

at 3-11] Not only possible, but probable. It’s clear to us that this is the only binding commitment

the applicant is making. After all, operating the dry cooling tower increases the parasitic load

and would cost Dominion money, so one would expect that like any profit-seeking entity,

Dominion will at all times and in all places seek to minimize its costs while complying with its

minimum commitment to dissipate “at least one-third” of the Unit 3 reject heat through dry

cooling. (SE-0040 2)

Response: To achieve an average evaporation rate of 8707 gpm, the plant would have to

reject more than one-third of the waste heat using dry cooling during some portion of the year. 

While Dominion may reasonably be expected to operate the cooling system in a manner to

maximize revenues, any ESP would include the PPE values for consumptive water uses,

including the instantaneous maximums and the annual average as a part of Appendix J. An

ESP does not allow operation of a nuclear power plant. An applicant would have to submit a

COL application to be allowed to operate a nuclear power plant. If the COL application

referenced this EIS, then the applicant would have to demonstrate that the design falls within

design parameters, which may be PPE values, in the permit. Appendix I of this EIS presents

the PPE values for consumptive water use. Accordingly, no changes were made to this EIS as

a result of this comment.

Comment: [Regarding Dominion’s ER] Table 3.3-1 It is not clear who has the final decision as

to when the unit #3 will change from Energy Conservation (EC) mode to Maximum Water

Conservation (MWC) mode. I understand that after seven days of 250 msl a switch would be

made. What if a rain storm is predicted? Would the change still be made? How would the

public know the MWC mode is in effect. How fast can the plant change to EC mode? Does the

level have to be above 250 msl for seven days to convert back to EC mode? (SE-0004 20)

Response: The authority for deciding the operating policies for the Unit 3 cooling system and

the operation of the Lake Anna Dam resides with the Commonwealth of Virginia. Dominion

proposes that the shift from EC to MWC mode would take no more than seven days. The staff

based its review on Dominion’s proposal. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: During Maximum Water Conservation (MWC), a minimum of one-third of the heat

would be removed by the dry towers. The remainder would be removed, as required, by the wet

towers. The SDEIS statement could be qualified to add the term “minimum” in describing the
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NUREG-1811, Volume II 3-94 December 2006

percentage of cooling which is proposed to be achieved by the dry cooling towers in the MWC

mode. As site dry bulb ambient temperature decreases from the design maximum ambient

condition, the dry cooling towers will transfer increasing percentages of the condenser heat to

the atmosphere. (SE-0050 2)

Response: Based on this comment, the text in Section 3.2.2 has been clarified.

Comment: [Regarding Dominion’s ER] For the IHA study referenced on page 3-5-17, does the

cooling towers for unit 3 take into account the EC and MWC modes[?] (SE-0004 27)

Response: The IHA analysis is based on Dominion’s simulation of downstream flows. The

simulation assumed the operation of Unit 3 shifts between EC and MWC modes based on lake

elevation. Accordingly, no changes were made to this EIS as a result of this comment.

Comment:3.3.2.8-S. DEQ's Division of Water Resources agrees with the applicant that air

cooling (i.e., the MWC mode) should be implemented when the lake level falls below 250 feet

msl at a minimum. However, the Division agrees with the Department of Game and Inland

Fisheries (DGIF) that the MWC mode should be implemented at other times as well, when the

lake is not necessarily below a full condition; (SW-0017 26)

Response: The Commonwealth of Virginia has authority to regulate the policies governing both

the water used by a new facility and the releases from the Lake Anna Dam. Accordingly, no

changes were made to this EIS as a result of this comment.

Intake Structure

Comment: As the water supply required for the closed loop cooling system proposed for Unit 3

is significantly lower than required for a once through cooling system which the existing intake

channel was designed, Dominion may only remove a portion of the full cofferdam expanse

through tunneling or dam removal. (SE-0050 3)

Comment: No statement is made in the ER that a separate discharge structure would be

constructed. It is possible that the partially completed discharge structure for Units 3 and 4

would be utilized as the “new outfall structure”. (SE-0050 4)

Comment: It would be more appropriate to state, “No separate intake structure is required for

Unit 4”. Although the Unit 4 normal plant cooling towers would require little to no make-up from

Lake Anna, a water supply from the lake would be required for UHS make-up (if required by the

COL-selected reactor technology), fire protection, and demineralized water make-up. The

Unit 4 water supply demands would be significantly less than for Unit 3 and would therefore be

accommodated in the Unit 3 intake structure. See ER Section 3.4.2.1. This is acknowledged in
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 December 2006 3-95 NUREG-1811, Volume II

SDEIS Section 3.2.2.2, Component Descriptions-Intake System, which states, “Any makeup

water required for Unit 4 could be obtained from the Unit 3 intakes.” (SE-0050 5)

Comment: ER Section 3.4.2.1 states that to bring water from the reservoir to the new intake

structure via the approach channel, the cofferdam, or a portion of it, would be removed. 

Because of the limited quantity of water to be supplied from the North Anna Reservoir, no major

modification to the existing shoreline or dredging in the approach channel would be necessary. 

(SE-0050 6)

Response: Based on these comments, the text in the Sections 3.2.2.2 and 4.3.1 of this EIS

was clarified.

Comment: The original intake was 150 feet long and 200 feet wide and required dredging and

shoreline reshaping. The current intake will be significantly smaller. ... What is the cost

differential for this smaller intake versus the increased cost for cooling towers? (SE-0027 8)

Response: Consideration of costs is deferred to the COL stage and is not considered part of

the ESP review process. Therefore, the staff did not consider costs in this ESP review. 

Accordingly, no changes were made to this EIS as a result of this comment.

Operating Parameters

Comment: [Regarding Dominion’s ER] It is also designated that the water cooling towers will

create a discharge of “blowdown” water into the existing discharge canal, but it does not

designate any limiting temperature of the water. It also does not designate how the flow rate

when combined with the existing 2 million gallons per minute currently discharged may impact

the private residence boat houses, piers, etc. in the cooling lagoons. It is unclear on exactly

how many inches/feet the entire lake will drop at what times of the year as a result of the

increased water usage for the cooling towers. (SE-0003 10)

Response: In its ER, Dominion provides a PPE bounding maximum blowdown water

temperature of 100(F and a maximum blowdown flowrate of 5565 gpm. The maximum

blowdown temperature is less than the maximum discharge temperature from existing NAPS

Units 1 and 2. The flowrate of the Unit 3 blowdown is an insignificant fraction of the existing

combined discharges for NAPS Units 1 and 2. Therefore, the staff concludes that the

temperature and flow impact of a hybrid cooling system’s blowdown would be negligible. 

However, the staff acknowledges that the lake level would drop as a result of the consumptive

water use from Unit 3. This impact is described in detail in Appendix K of this EIS. Accordingly,

no changes to this EIS were made as a result of this comment.
Comments Within Scope

NUREG-1811, Volume II 3-96 December 2006

Comment: [Regarding Dominion’s ER] Par[agraph] 9.4.1 page 3-9-13 Heat Dissipation

Systems. The screening of Unit 3 Alternative Heat Dissipation Systems by Dominion for Spray

Ponds (Alternative 5) is flawed. ... Spray ponds could be used as a supplemental peak load

solution (not a stand-alone system for all the heat dissipation) to the heat problem in the hot

summer months. These sprayers could be located in the discharge canal and would not affect

the open area of the cooling lagoons or in the Ultimate Heat Sink (UHS) location or new ponds

on site. (SE-0007 10)

Response: The staff concluded that the incremental thermal impact of a closed-cycle,

combination wet and dry cooling system for Unit 3 would be negligible. Therefore, the staff

found no need for supplemental cooling. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: The SDEIS indicates that the additional drawdown would be 3.4 ft, while the North

Anna Closed Cooling Evaluation indicates that the additional drawdown would be 2.5 ft. The

SDEIS reflects the NRC confirmatory analysis and, while the results do not exactly match those

stated in the Anna Closed Cooling Evaluation, the conclusion of SMALL IMPACT is unaffected

by the difference. (SE-0050 14)

Comment: The SDEIS indicates that the additional drawdown would be 1.6 ft, while the ER

indicates that the additional drawdown would be 0.9 ft. The SDEIS reflects the NRC

confirmatory analysis and, while the results do not exactly match those stated in the ER, the

conclusion of SMALL IMPACT is unaffected by the difference. (SE-0050 15)

Response: The text in Section 5.3.2 of this EIS has been clarified to explain the differences

between the staff’s analysis and Dominion’s analysis.

Supportive of Wet/Dry Cooling

Comment: I really appreciate Harry Ruth's remarks [representing Friends of North Anna], in

particular, because what I heard him say is that they are all in favor of new nuclear, as long as

the cooling towers are invisible, make no noise, cause no evaporation, and don't increase any of

the temperatures in the lake. (ST-0025 1)

Comment: Dominion also is an excellent environmental steward and has demonstrated that it

is a good neighbor by agreeing to spend $200 million on a cooling tower system to cool a

potential third reactor at the North Anna site. Dominion made this commitment to satisfy

concerns expressed by state regulatory agencies and local citizens about the potential thermal

impacts on Lake Anna and the Waste Heat Treatment Facility from using the lake for

once-through cooling. (SW-0007 3) (SW-0013 3)
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 December 2006 3-97 NUREG-1811, Volume II

Comment: Dominion has...agree[d] to spend $200 million on a cooling tower system to cool a

potential third reactor at the North Anna site: Dominion made this commitment to satisfy

concerns expressed by state regulatory agencies and local citizens about the potential thermal

impacts on Lake Anna and the Waste Heat Treatment Facility from using the lake for

once-through cooling. (SW-0002 3)

Comment: [I]n response to concerns voiced by Lake Anna residents regarding the thermal

impact on the lake of the "once-through" cooling method of the existing reactors, Dominion has

agreed to spend $200 million on a cooling tower system for any potential third reactor at the

North Anna site, thereby obviating the need for using lake water for cooling, despite the lack of

any scientific evidence of any adverse public health or environmental impact of the existing

Waste Heat Treatment Facility. (SW-0012 3)

Comment: [T]he construction of a dry cooling tower appears to defeat the very purpose for

which the Early Site Permit is being sought because of the high utilization of electricity. 

(SW-0021 5)

Response: These comments are supportive of Dominion’s proposed closed-cycle, combination

wet and dry cooling system design. Accordingly, no changes were made to this EIS as a result

of these comments.

3.3.2.9 Downstream Impacts

Comment: Section 5.3 does not fully address downstream impacts of the proposed project. 

(DW-0438 125)

Comment: The North Anna River is a spectacularly scenic and remote canoeing river with

excellent fishing, according to the Department of Conservation and Recreation. Between State

Route 601 and U.S. Route 301, the River is heavily used because it presents some of the most

beautiful and remote paddling opportunities in the mid-Atlantic region. During periods of low

rainfall, releases from the Lake Anna Dam are less than what is needed to support recreational

boating on the River. Accordingly, discharge rates from the Lake Anna Dam should be

adequate to meet minimum in-stream flows needed for recreational boating from State Route

601 to U.S. Route 301. The Department of Conservation and Recreation recommended, in its

earlier comments on the Draft EIS, that a minimum in-stream flow recreation study be

conducted to determine what this discharge rate should be. (DW-0439 48) (SW-0017 10,

SW-0017 16)

Comment: The Tennant method [for analysis of flows] is a common desktop method and

summer flows in the 20-30% mean annual flow (MAF) range are beneficial for sustainable

fisheries. Because it has been called the Montana Method, it has been deemed as only

applicable in Western streams. That is a misconception, as it was developed “over the past
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NUREG-1811, Volume II 3-98 December 2006

17 years from work on hundreds of streams in the states north of the Mason-Dixon Line

between the Atlantic Ocean and the Rocky Mountains” (Fisheries 1(4): 6-10). Summer flows

below the desired level of 68 cubic feet per second (cfs), or 20% of MAF, are the norm under

current conditions and will worsen under future conditions. The Department of Game and

Inland Fisheries recommended that an Instream Flow Incremental Methodology (IFIM) Study be

conducted to properly evaluate this project on the stream fauna. The expected increased

frequency of drought flows to a common occurrence (2.6 years) is expected to have significant

impacts. Conclusions need to be based upon sound scientific modeling. DGIF states that if

Dominion can offer a better approach to modeling flow impacts, that Department would be

happy to consider any alternative. (DW-0439 45) (SW-0017 52)

Comment: The lowest flow rate at the North Anna dam, which releases only 5.4% of the

natural flow, is considered as “severe degradation” according to the Tennant method for flow

recommendations. This evaluation should be acknowledged in the Final EIS. (DW-0437 19)

Response: Based on discussions with the VDEQ, Dominion included an analysis using the

Indicators of Hydrologic Alteration (IHA) methodology described in Section 5.2.2.2 of the ER. 

The NRC staff based its review on the release rule codified by the VDEQ in the Lake Level

Contingency Plan. The Commonwealth of Virginia may require an Instream Flow Incremental

Methodology study as part of its licensing activities under the Clean Water Act and Coastal

Zone Management Act for any facility for which a CP or COL application is filed that references

an ESP for the North Anna ESP site. Additional analysis on downstream impacts was included

in Section 5.4.2.6 and Appendix K of this EIS.

Comment: [I]t's estimated that the percentage of time when the flow has to be reduced from

the normal minimum of 40 cubic feet per second down to 20 cubic feet per second, that

increases from about 6 percent to 11 percent with the addition of Unit 3. And that is really kind

of the nub of the problem. [assumed to mean "for downstream uses"] (ST-0030 2)

Comment: It's identified in the SDEIS as historical pre-dam minimum flows of 5 cubic feet per

second, or less. And in a letter from the Department of Fish and Gaming Inland Fisheries, they

state in their July 7th letter that the pre-lake dry conditions is 12 cubic feet per second, so

there's some disconnects here that I think we should straighten out in the documents. 

(ST-0028 1)

Comment: Bear Island appreciates that Dominion has modified its original plan for the reactor

unit #3 cooling system iin response to earlier comments by DEQ, but Bear Island believes that

such modifications do not fully address the negative consequences on downstream flows and

the increased risk to downstream users of the North Anna River. (SE-0047 4)
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 December 2006 3-99 NUREG-1811, Volume II

Comment: [T]he flow rates in the North Anna River [before the plant] varied from a barely

trickled creek to a flooded river before the dam started regulating the flow. Now the

downstream flows are regulated. (ST-0020 4)

Comment: Bear Island is very concerned that [increased low-flow conditions] will put at some

risk the ability of the combined wastewater flows from Bear Island's facility and the County of

Hanover's Doswell wastewater treatment plant...to function as designed based on current

permit requirements and water quality standards. ...ensuring adequate instream flows based on

sufficient releases from Lake Anna is quite critical to Bear Island. (SE-0047 3)

Comment: Bear Island respectfully disagrees with the NRC that the impacts associated with

the proposed ESP and related plans for the Station expansion would be small or moderate at

most and not arise to the level of significant environmental impact. ...The SDEIS itself makes

quite clear that the downstream effects would be significant and adverse to the downstream

portions of the River. ...Bear Island requests that the NRC reconsider and change its

characterization of these effects to reflect more accurately their expected and stated adverse

nature and degree of harm and amend its conclusion to recognize that, as currently proposed,

the expansion would cause a significant adverse environmental impact that cannot be

redressed. At minimum, the NRC should require further assessment by Dominion or conduct its

own further assessments to more completely evaluate the effects on downstream users and

appropriate alternative designs and potential mitigation opportunities. (SE-0047 5)

Comment: [I]ncreased low-flow conditions will make it more difficult for Bear Island to withdraw

water from the River as needed and as permitted by law. Bear Island's water intake structures

currently include the nominal capacity to withdraw up to 12 cfs. ...the increased frequency and

length of low-flow conditions expected to result from the planned expansion based on more

frequent and longer releases of ony 20 cfs would pose serious risks to Bear Island and others

relying on water withdrawls from the River below the Lake Anna Dam. Bear Island has existing

limited water storage capacity to address short-term interruptions of suspensions of its

withdrawals,...however, given the increased frequency and length of periods of such low flows

as described in the SDEIS, it will be more difficult, if not impractical at certain times, to recharge

the on-site water storage, thus diminishing the usefulness of this storage. (SE-0047 1)

Comment: Bear Island obtains water from the County of Hanover water system, which is

served by a withdrawal intake upstream from the Bear Island facility. If the increased low-flow

conditions expected as the result of the planned Station expansion come to pass, then it also

seems reasonable to expect that the County will have a more difficult time in withdrawing water,

...Consequently, the ability of the County to meet the needs of its residents and businesses in

the area will be compromised. (SE-0047 2)
Comments Within Scope

NUREG-1811, Volume II 3-100 December 2006

Comment: The impacts on decreased water releases to the South Anna River have not

adequately been mitigated by the proposed changes in the project. ...this watershed is already

overtaxed by the existing reactor operations and cannot accommodate additional water

consumption by even one new reactor that results in water consumption for cooling. ...What is

difficult to assess is the frequency with which high water consumption levels will coincide with

relative drought conditions resulting in low releases of water to the North Anna River. ...what

criteria would govern operations? (SE-0038 1)

Comment: The SDEIS concludes that the frequency of water releases at the level of 20 cfs will

increase from 5% to 11%. That is not acceptable in terms of impacts to the North Anna River

and downstream areas. (SE-0038 2)

Comment: The [Hanover] County remains concerned with the increased frequency of the low

flow conditions and the impact on downstream users, which the draft SEIS classifies as

moderate during drought conditions and small during normal conditions. Any reduction in flow

will have an adverse impact on the County and Bear Island Paper due to the unique nature of

the Doswell Wastewater Treatment Plant VPDES Discharge Permit, which is tied to flow in the

North Anna River. (SE-0048 1)

Comment: The modifications to the cooling system design for Unit 3 reflected in the

Supplemental Draft EIS substantially address concerns dealing with release or discharge of

heated water to Lake Anna. However, evaporative loss of cooling water from the cooling towers

remains a significant concern, especially in the North Anna and Pamunkey Rivers downstream

from the Lake during periods of drought. (SE-0046 1)

Comment: One set of the North Anna River users should not benefit at the expense of another

set of users. (ST-0014 26)

Comment: [T]he consequence [of proposing combination wet and dry cooling towers] is that

we've gone to a system that could potentially have even greater impacts downstream in terms

of releases. ...In the normal so-called EC mode, the water use increases to 22,298 gallons per

minute. That's approximately 90 percent greater than with the once-through cooling. ...We've

increased the total water use substantially in order to be able to get the benefits of reducing the

immediate lake impact. ...basically, they [VDEQ] and we - and the Sierra Club both raise the

issue of whether Lake Anna has sufficient water resources to support cooling, consumptive

cooling use for a third nuclear reactor. (ST-0030 1)

Comment: We've got the lowered lake levels in the lake downstream. (ST-0024 3)

Response: The water use conflicts issue is a principal issue in this environmental review. In a

water budget, as with all other budgets, a finite resource is allocated to serve multiple

objectives. The management of water resources involves balancing tradeoffs among these
Comments Within Scope

 December 2006 3-101 NUREG-1811, Volume II

multiple conflicting objectives. In the case of the Lake Anna and North Anna River water

resource, these objectives include: providing water for current and likely future downstream

water users, providing water for downstream habitat, maintaining relatively stable lake levels,

and providing a reliable water supply for industrial facilities including the existing NAPS and

proposed Unit 3.

The staff made no attempt to balance these objectives. Rather, the staff simply disclosed the

impacts. Establishing policies that balance water-related objectives is the responsibility of the

Commonwealth of Virginia. Construction and operation of a plant at North Anna is predicated

on obtaining a variety of water related permits and certifications from the Commonwealth of

Virginia that are independent of a decision on this ESP application by the NRC.

In order to estimate impacts, the staff must rely on available information and past and existing

policies. The Lake Level Contingency Plan was considered by the NRC staff in the evaluation

of the North Anna water supply. Low flow releases from the dam are prescribed by the VDEQ in

the Plan. The policy of decreasing the release from 40 cfs to 20 cfs as the lake level drops

below 248 feet above mean sea level (MSL) is prescribed by VDEQ. The staff acknowledges

that water conflicts could increase due to the reduction in the water supply as a result of

consumptive water losses from the operation of proposed Unit 3. These impacts would be

greatest when the available water supply is already limited because of climatic factors. Drought

conditions or increases in future water demands could result in intervention by the

Commonwealth in the apportionment of the water. Such intervention might include operational

restrictions during periods of water use conflict.

The forced evaporation from proposed Unit 3 would reduce the volume of water released from

North Anna Dam, thereby impacting downstream water users. To characterize this impact, the

staff estimated the change in the reliability of a hypothetical off-stream storage reservoir used to

service a steady water demand. The capacity of a reservoir adequate to provide releases of a

steady flow of 20 cfs from the North Anna Dam from the operation of NAPS Units 1 and 2 was

calculated to provide 95 percent reliability. The staff estimated that the reliability of the same

hypothetical reservoir would decrease from 95 to 90 percent with the addition of Unit 3's

additional consumptive water loss. The staff’s assessment related to water-related impacts is

documented in Section 5.3 and in Appendix K of this EIS. Changes were made to Section 5.3

of this EIS as a result of these comments.

3.3.2.10 Applicant’s Comments and Corrections

Comment: None of the three counties upstream of Lake Anna (Louisa, Spotsylvania, Orange)

is relying on the North Anna River to satisfy their water demands. [page 2-23, line 2] 

(DW-0423 9)
Comments Within Scope

NUREG-1811, Volume II 3-102 December 2006

Response: The sentence in Section 2.6.2.1 has been changed to reflect that none of the

counties upstream of Lake Anna is relying on the North Anna River to satisfy its current water

demands.

Comment: (1) Not all reactor types require an ultimate heat sink [UHS]. (2) The size, storage

volume, flow rates, heat rejection rates, blowdown rates, etc. identified in the SSAR and ER are

maximum values. In the event that the selected reactor design requires an UHS, the UHS

would be appropriately sized for the unit as part of detailed engineering and described in the

COL application. [page 3-6 through 3-8, lines 2, 16, 28] (DW-0423 17)

Response: While some reactor designs may not require an ultimate heat sink, other designs

do. The staff analyzed the impacts based on the PPE, which included an ultimate heat sink. 

Accordingly, no changes were made to this EIS as a result of this comment.

3.3.2.11 Other Comments

Comment: Where data is referenced from another document like in Page 3-5 line 31 [induced

evaporation presented in Section 5.2.2 of the ER], a summary should be included in the DEIS. 

(DW-0438 84)

Comment: Page 2-20 line 9 states that units 1 & 2 have “likely” added to evapotranspiration. 

Since a DEIS is intended to be a public document, data of this type should be summarized and

included in the DEIS along with the staff conclusions derived therefrom. If actual data is not

available then the formulae or methodology for prediction should be included. (DW-0438 35)

Response: A more detailed discussion of the staff’s approach and results is presented in

Appendix K of this EIS. Further summarization of Dominion’s analysis was not provided where

the staff relied upon its own independent analysis as the basis for its conclusions.

Comment: Page 2-34 line 6 discusses clams in Lake Anna. What chemical and mechanical

control measures against clams and other aquatic organisms are used by Dominion to protect

the cooling water intakes and outflows? What assurances are there that these organisms will

not interrupt the flow of necessary cooling waters? The discussion on page 2-39 line 28 is too

cursory to be evaluated. (DW-0438 49)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, the size of the intake structure would be substantially

reduced because of the significant reduction in intake water requirements. Interruption of

normal cooling water is not an environmental issue, but rather a safety issue. Control of
Comments Within Scope

 December 2006 3-103 NUREG-1811, Volume II

freshwater clams and biofouling in cooling water systems is well understood by the industry,

and fouling of cooling water systems represents a minimal risk to the safe operation of the

facility. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The Draft EIS/SEIS does not provide information on the linear feet of streams

impacted by the construction and operation of the proposed facility, nor does it include any

mitigation for the loss. (DW-0422 6) (SE-0030 7)

Response: Subsequent to the publication of the DEIS, Dominion received a wetlands

jurisdictional determination from the Corps of Engineers based on wetlands delineation

performed by Dominion and reviewed by the Corps. No mitigation has been proposed in this

EIS, but the Corps of Engineers may require Dominion to provide compensatory mitigation as

part of the Corps’ Clean Water Act, Section 404 permitting process. Updated information is

provided in Section 4.4.1 of this EIS.

Comment: Page 2-22 line 41 states that there is “limited projected development in the three

upstream counties” which includes Spotsylvania. This statement, and therefore, any

conclusions drawn from it, is false. The February 23, 2005 Free Lance Star reported that

Spotsylvania is one of the 20 fastest growing counties in the United States! (DW-0438 39)

Comment: The text indicates that due to the use of policies promoting storm-water

management practices that limit the impact of impervious surfaces, upstream land use changes

are not expected to appreciably alter the patterns of inflow into Lake Anna. PEC is alarmed by

these underlying assumptions, given the fact that Spotsylvania County is listed in the top

100 fastest growing counties with an annual growth rate of 19 percent. (DW-1157 4)

Response: The watershed upstream of Lake Anna encompasses Louisa, Spotsylvania, and

Orange Counties. The upstream area is 57 percent forest, 38 percent cropland and pasture,

and 3 percent developed residential area. The staff acknowledges that Spotsylvania County is

a rapidly developing area. However, within the region the greatest projected growth is around

Fredericksburg, which lies outside Lake Anna’s watershed. Assuming Spotsylvania County’s

recent growth rate of 4.5 percent was to continue for the entire watershed, it would take

15 years for the watershed’s residential land use to double to 6 percent. Assuming that land

use “best management practices” are applied, the impact of increases in impervious surface

area that are associated with residential use is expected to be SMALL. Therefore, the staff

concluded that this future growth would not adversely change the water supply feeding Lake

Anna. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: What would be the impacts to the project and the Lake Anna area if the Virginia

State Water Control Board designates it as a surface water management area (Page 2-23,

line 25)? (DW-0438 40)
Comments Within Scope

NUREG-1811, Volume II 3-104 December 2006

Response: Should this change occur prior to NRC’s issuance of an ESP or COL, the NRC

would evaluate the impacts of this designation on the project. However, this has not yet

occurred. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: I might add that the original application from Dominion included 50 pages of thermal

and water level mitigation options that were not contained in the EIS. These options, if

executed, would further reduce the impacts discussed previously. (DT-0011 6)

Comment: Dominion Power should propose some thermal mitigating actions when the

temperature at Dike 1 exceeds 95(F (e.g., spray fountains such as used in the discharge canals

at other generating facilities, a mechanical draft cooling tower that would process part of the

1,140,00 gal/min discharge, etc.) (DT-0029 9)

Comment: Information and analyses on “operational practices and procedures” for mitigating

hydrological impacts (page 5-7, line 10) is crucial for determining whether the impacts can be

minimized and should be an integral part of the Final EIS. (DW-0437 12)

Comment: Given a MODERATE impact rating on Page 5-10 line 10, how can the statement

that no mitigation is warranted be correct? The proposed facility, if permitted, should be

required to have design and operational mitigation to minimize the water impacts. These

mitigation measures should be spelled out in the DEIS. (DW-0438 141)

Comment: Page 2-25 line 15 [and line 35] states that “many of the same monitoring activities

would be continued.” The applicant should stipulate now that monitoring activities will be

continued and expanded. Preferably, monitoring activities should be detailed as one of the

mitigation measures in a DEIS. (DW-0438 43) (DW-0438 44)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, thermal impacts would be negligible. The NRC’s

evaluation of cooling water alternatives is in Appendix K of the EIS. The WHTF facility was

licensed by the Commonwealth of Virginia as an industrial waste heat treatment facility; as a

result of that designation, the Commonwealth does not require that Dominion meet water quality

standards within the WHTF but rather from the water return to Lake Anna at Dike 3.

The staff did conclude that the impact to water use would be MODERATE temporarily during

drought conditions because of the projected decrease in lake levels and downstream flows

associated with the forced evaporative losses of the wet portion of the proposed closed-cycle,

combination wet and dry cooling system. However, the staff also concluded that because

droughts are natural temporary events for which water supply systems are designed to

compensate, the impact would not destabilize the water resource. During periods when rainfall,

streamflow, and associated lake level are at climatic and hydrologic norms, the Unit 3 cooling
Comments Within Scope

 December 2006 3-105 NUREG-1811, Volume II

system would not noticeably affect the water resources of Lake Anna, and impacts would be

SMALL, as described in Section 5.3 of this EIS.

The EPA has the responsibility for mitigating water quality impacts associated with the cooling

system under the Clean Water Act; EPA delegated that authority to the Commonwealth of

Virginia. The NRC cannot specify water quality standards or monitoring programs to mitigate

impacts associated with the cooling water system. The staff acknowledges that the

Commonwealth of Virginia, with its jurisdiction over managing the water resources of Lake

Anna, may mitigate impacts to the water resources by requiring the proposed Unit 3 to derate or

close operations in periods of severe low water. The staff identified no feasible mitigation other

than derating or closing operations based on the proposed design. Alternative cooling system

designs are discussed in Section 8.2. 

Comment: Can you explain the UHS (Ultimate Heat Sink)? Why is it there? What does it do? 

(SE-0004 21)

Response: The UHS is described in Section 3.2.1 of this EIS. The UHS is a safety-related

component that provides adequate cooling to safely shutdown the plant in case of an

emergency. Dominion proposes to use a separate mechanical draft cooling tower with an

engineered underground basin containing a water supply for the UHS. Accordingly, no changes

were made to this EIS as a result of this comment.

3.3.2.12 Regulations

Comment: A VPDES permit would not be required for site preparation activities. [page 4-6,

line 37] (DW-0423 22)

Response: VDEQ advised the NRC that a NPDES stormwater construction permit would be

required for site preparation activities. Administration of Virginia’s construction stormwater

NPDES permit was recently transferred from VDEQ to the Virginia Department of Conservation

and Recreation. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: What is the current status of Dominion’s VDEQ certification as discussed on

Page 2-8, line 16? (DW-0438 17)

Response: Dominion submitted a request for a Federal Consistency Certification under the

Coastal Zone Management Act (CZMA) to VDEQ for the North Anna ESP action on March 21,

2005. On November 22, 2006, Dominion submitted a letter stating that they had received

concurrence from the Commonwealth of Virginia on Dominion’s request for a Federal

Consistency Certification under the CZMA (Dominion 2006b). Reference to this letter has been

added to this EIS.
Comments Within Scope

NUREG-1811, Volume II 3-106 December 2006

Challenging Consistency with CZMA 

Comment: We believe that the North Anna project as currently proposed is inconsistent with

the Va. Coastal Zone Management Program as approved under the U.S. Coastal Zone

Management Act. We support the concept of a 3rd and 4th reactors, but the above

environmental items must be resolved prior to the issuance of either a Federal Consistency

Certification. We request that a Federal Consistency Certification or an Early Site Permit not be

issued until the above issues are satisfactorily resolved. (SE-0022 31) (ST-0014 19)

Comment: Dominion's proposal is not consistent with the Coastal Zone Management Act

(CZMA) and would have serious negative impacts on already stressed local and regional water

resources. (SE-0034 1)

Response: On November 22, 2006, Dominion submitted a letter stating that they had received

concurrence, with conditions, from the Commonwealth of Virginia on Dominion’s request for a

Federal Consistency Certification under the CZMA with respect to the ESP application

(Dominion 2006b). The staff is including a recommended permit condition for the ESP should

one be issued (see Appendix J). Accordingly, no changes were made to this EIS as a result of

these comments.

Requesting Regulation of the WHTF

Comment: [Regarding Dominion’s ER] Par[agraph] 5.2.2.5 page 3-5-20 “The discharge of

heated water to the North Anna Reservoir via the (cooling lagoons) would be subject to CWA

(Clean Water Act) Section 316(a) regulations which require that the thermal discharges assure

the maintenance of a balanced, indigenous population of shellfish, fish, and wildlife in and on

the receiving body of water. The withdrawal of cooling water from the North Anna Reservoir

would meet Section 316 (b) of the CWA and the implementing regulations, as applicable.” This

is not in agreement with a recent ruling of the U. S. Supreme Court decision (No 04-1527 S.D.

Warren Company, Petitioner, v. Maine Board of Environmental Protection et al). As described

in the decision, Congress passed the Clean Water Act to “restore and maintain the chemical,

physical, and biological integrity of the Nation’s waters, with the national goal being to achieve

water quality which provides for (1) the protection and propagation of fish, shellfish, and wildlife

and (2) provides for recreation in and on the water”. Dominion can not get the same variance

as it currently has for existing units as well as the new unit 3 in their VPDES with this ruling.

Recreational use of the discharged water must be addressed. In the June 28, 2005 letter from

Dominion to VDEQ requesting “Reissuance of VPDES Permit No. VA0052451”, Dominion

requested “Continued 316(a) Variance for water temperature discharge.” This is because they

discharge water over the allowed 32 degree C maximum. Why did Dominion request eight (8)

other new waivers from VDEQ. What are they and why were they requested? Would these

new waivers be requested for unit 3 also? Quid-Pro-Quo, the public should receive some
Comments Within Scope

 December 2006 3-107 NUREG-1811, Volume II

compensation if VDEQ and the State Water Control Board give these waivers to Dominion. 

Such a concession would be limiting temperatures at the discharge canal to no more than

104 degrees F. (SE-0004 28)

Comment: The Agencies of the State of Virginia apply a number of regulations to public water

bodies. There are regulations which relate to the health, safety, and welfare of the citizens

living around and recreationally using public water. We request that the State Agencies be

legally required to apply these health and safety regulations to the Cooling Lagoons. 

(SW-0004 7)

Comment: Changing the "Point of compliance" from Dike 3 to the End of the Discharge Canal

and re-designating the cooling lagoons as "quasi public waters". ...The "quasi public water"

designation would recognize that Lake Anna is unique for thermal cooling, unlike other power

plants that discharge heated waters into ocean's or major free flowing rivers. It would also

permit the state to treat the cooling lagoons as public waters and be afforded all the same

protections as other public waters unless there is a nuclear disaster. ...It is requested that the

point of compliance be changed to the end of the discharge canal so that any future discharge

permit renewals for the North Anna power plant will be waived from compliance with the U.S.

Clean Water Act with a maximum temperature of 104 degrees F, together with Dominion being

required to take real-time corrective action if the water temperature approaches 104 degrees F

and thereby in agreement with the recent U.S. Supreme Court Decision. (SE-0002 3)

Comment: Limiting the Water Temperatures at the end of the Dominion Discharge Canal to no

more then 104 degrees F. The U.S. Consumer Product Safety Commission and the Virginia

State Health Commission (Dr. Robert Stroube), and Hot Tub Manufacturers have identified that

water in excess of 104 degrees F is dangerous to human health. Dominion has stated that they

have never exceeded 103.6 degrees F at the end of the discharge canal for the past 35 years. 

There are many options (spray in the discharge canal, design of cooling towers, location of

cooling towers, design of 3rd reactor complex, reducing thermal heat discharge with current

reactors) that Dominion can use to maintain the 104 degrees F limit (if and when it would

become necessary, which it has not for past 35 years, even in extreme drought conditions). 

Since Dominion has designated in the ESP that they are running their current reactors (units 1

& 2) at 93% capacity, maintaining the less then 104 degrees F temperature at the end of the

discharge canal in the future should not be a problem. As described in the Supreme Court

decision, Congress passed the Clean Water Act to "restore and maintain the chemical, physical,

and biological integrity of the Nation's waters, with the national goal being to achieve "water

quality which provides for (1) the protection and propagation of fish, shellfish, and wildlife and

(2) provides for recreation in and on the water." In order to comply with the U.S. Clean Water

Act of providing for recreation in and on the water and the recent Supreme Court decision, it is

requested that any federal or state permits issued to Dominion limits the water at the end of the

1⁄2 mile discharge canal (before it enters the cooling lagoons) to no more then 104 degrees

Fahrenheit. (SE-0002 2)
Comments Within Scope

NUREG-1811, Volume II 3-108 December 2006

Comment: [W]e request that the VPDES Point of compliance be changed from Dike 3 to the

end of the Discharge Canal and the Cooling Lagoons start to be treated by all state agencies as

quasi-public waters so the health, welfare and safety of those who use the cooling lagoons is

protected. The quasi-public water designation would recognize that Lake Anna is unique for

thermal cooling (unlike other power plants that discharge heated waters into oceans or major

free flowing rivers). It would also permit the state to treat the cooling lagoons as public waters

and afford them the same protection as other public waters unless there is a nuclear disaster. 

This would also adhere to the recent Supreme Court Decision (S. D. Warren vs. Maine Board of

Environmental Protection) to be adhered to which did not permit the privatization of public

waters. (SE-0022 34) (ST-0014 21)

Comment: A point of compliance for all U.S. water permits should be changed from dike 3 to

the end of the discharge canal to provide for Clean Water Act protections for all the cooling

lagoons users. ...We need to enforce the U.S. Clean Water Act for recreating in and on the

water on both the main reservoir and the cooling lagoons. ... Currently the cooling lagoon and

main reservoir waters exceed hot tub temperatures on many occasions. ...Currently, it's only

enforced only on the main reservoir.... The cooling lagoon users have no protections at all. 

(ST-0014 8) (SE-0022 17) (SE-0022 23)

Comment: [W]e also have concerns about the hot side of the lake. We don't think it should be

treated as private property or as a waste treatment center. We think it should be fully regulated

under the law just like the rest of the lake is and should be subject to the Clean Water Act. 

(ST-0005 3)

Comment: We request that the state agencies be legally required to apply these health and

safety regulations [which relate to the health, safety, and welfare of citizens living around and

recreationally using public water] to the cooling lagoons. (ST-0004 5)

Comment: I would very much support anything that moved toward regulating that side and

dropping the temperatures on that side, but the warm water is good. (ST-0001 4)

Comment: A cap needs to be placed on the temperature in the cooling lagoons and enforced

with penalties when it is exceeded. (SE-0008 2)

Comment: Limit water temperatures to no greater than 104 degrees F at the end of the

discharge canal to comply with U.S. Safety Commission and Virginia Department of Health. 

(SE-0015 2)
Comments Within Scope

 December 2006 3-109 NUREG-1811, Volume II

Comment: Keeping in mind that hot tub manufacturers warn that customers should not use

their product if the water temperature is above 104 degrees, at what temperature does the Lake

Anna water become unsafe for human activity? Who is responsible for monitoring this

temperature and what means is in place to inform the public when the water becomes unsafe

for human activity? (SE-0019 1)

Comment: To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the ESP...Water

temperatures should be limited to no more then 104 degrees F at the end of the discharge

canal. (SE-0022 16)

Comment: 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? (SE-0045 17)

Comment: We request that the water temperature at the end of the discharge canal be limited

to 104 degrees F. Limit on heat transfer to the Main Lake could remain at Dike 3. There needs

to be an effective means of prompt enforcement. ...The temperature issue is a matter of public

safety for people swimming in the first Lagoon. As is well documented in hot tub literature,

swimming in water temperatures above 104 degrees is life threatening. Thus the temperature

should be limited at 104 degrees. (SW-0004 2) (ST-0004 3)

Response: Dominion’s proposed design for Unit 3 limits maximum blowdown temperature of

water discharged into the WHTF to 100(F. These comments refer to temperatures in the WHTF

as opposed to temperatures in Lake Anna. The temperature increase in the WHTF is the result

of operation of existing NAPS Units 1 and 2. Units 1 and 2 have a VPDES permit that is

undergoing renewal by the Commonwealth of Virginia. The VPDES permit governs the heat

discharge for Units 1 and 2. Proposed Unit 3 would have a negligible heat discharge to the

WHTF, and proposed Unit 4 would have no heat discharge to the WHTF. The Clean Water Act

assigns the authority and responsibility for setting water quality requirements to the EPA. In

Virginia the EPA has delegated this responsibility to VDEQ. Therefore, any restriction on the

discharge temperature to the WHTF or Lake Anna is the responsibility of EPA and the VDEQ. 

The NRC has no authority to set standards for nonradiological pollutant discharges into

receiving waters. See Section 5.8 for a discussion on health impacts of water temperature. 

Similarly, the designation of the WHTF as an industrial waste heat treatment facility was made

by the Commonwealth of Virginia and is not subject to review or comment by the NRC. 

Accordingly, no changes were made to the EIS as a result of these comments. 
Comments Within Scope

NUREG-1811, Volume II 3-110 December 2006

Temperature/Variance

Comment: It [the SDEIS] also states those units 1 and 2 can operate up to an inlet

temperature of 95 F. These temperatures far exceed the variance granted in the VPDES

permit. Controls on this temperature need to be delineated in the permit. (SE-0027 4)

Comment: [T]hese temperatures of 95 and 100 degrees far exceed the variances that have

been granted to Dominion in their VPDES discharge permit. We need to put some controls on

the temperatures to delineate the exact values instead of just heat transfer numbers. 

(ST-0028 5)

Comment: Both Louisa and Spotsylvania are in the top 100 fastest growing counties in the

USA. It is reasonable to project an increase in recreational activity around the lake. We do not

agree that the temperature discharge from the cooling lagoons at 100 degrees F would not

affect current or future recreational uses of the lake. (SE-004 23b)

Comment: We request that the U.S. Clean Water Act be enforced so the entire lake is not a

hot tub with temperatures throughout the lake in the 90’s that we have experienced in recent

weeks and the waters at the end of discharge canal be no greater then 104 degrees F. 

(SE-0022 32)

Comment: Since the entire lake is 17 miles long and includes 13,000 acres of water (with

depths of 50- 75 feet in many parts), and water temperatures exceed 90 degrees F throughout

the lake, it would seem that Dominion is routinely in violation of the U.S. Clean Water Act and

the VPDES variance that they have. (SE-0022 13) (ST-0014 25)

Comment: From what I understand, Lake Anna is subject to the Clean Water Act with several

waivers. It should be pointed out that the Clean Water Act clearly specifies that the discharge of

heated water will assure the maintenance of a balanced, indigenous population of shellfish, fish,

and wildlife in and on the receiving body of water. If one of these variances pertains to

discharging heated water that substantially raises the water temperature to a point that it is

considered unhealthy for both human and indigenous wildlife, then the responsible party for

issuing this variance should seriously reconsider their position. (SE-0019 2)

Response: The Clean Water Act assigns the authority and responsibility for setting water

quality requirements to the EPA. In Virginia the EPA has delegated this responsibility to VDEQ. 

The NRC has no authority to set discharge standards of nonradiological discharges. Similarly,

the designation of the WHTF as an industrial waste heat treatment facility was made by the

Commonwealth of Virginia and is not subject to review or comment by the NRC. 
Comments Within Scope

 December 2006 3-111 NUREG-1811, Volume II

Comment: The SDEIS should include further discussion into the thermal variance issued

under the existing NPDES permit for Units 1 and 2. As discussed in the SDEIS the most

significant surface water quality concern with the existing units is the localized elevated

temperatures. Elevated temperatures can place stresses on the aquatic communities due to

reduction in dissolved oxygen. This condition has been compounded in Lake Anna by the

tributaries being impaired by low dissolved oxygen (DO)'levels. The DO impairment to the

tributaries is significant enough for the Commonwealth of Virginia to designate them under

Section 303(d) of the Clean Water Act. EPA has concern that the proposed project may not beaccounted-for under the-existing-thermal variance for units-l-and 2. (SE-0030 3)

Response: The operation of Unit 3 would result in a reduction in the releases at the North

Anna Dam, which could result in reduced flushing, possibly increasing biological oxygen

demand (BOD) and thereby reduce the dissolved oxygen (DO). However, the staff believes that

continued operation of NAPS with its high flow rate would offset any DO depression resulting

from the operation of Unit 3. Low DO conditions have been observed in the summer below the

thermocline in Lake Anna. Such conditions are typical of stratified reservoirs in this region. 

However, above the thermocline, which is the majority of the lake volume, DO is not considered

a limiting factor in the lake ecology. The staff has estimated that the incremental temperature

increase resulting from operation of new Unit 3 would be minimal and unlikely to adversely

affect aquatic communities throughout the lake. Accordingly, no changes were made to this EIS

as a result of this comment.

Mitigation

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 ESP? Just because “modifications to

the water release regime from the Lake Anna Dam to mitigate impacts would be under the

jurisdiction of VDEQ, does not absolve the operator or the NRC from adopting reasonable

mitigation measures which could be subject to VDEQ approval. (SE-0045 24)

Response: The staff has considered the possible mitigative benefits of changes in dam

release policies. For instance, the staff describe in Appendix K, Section K.8 of the EIS an

analysis of a change in elevation at which dam releases are dropped to 40 cfs. This alternative

would change the frequency of 20 cfs flows, in addition to the lake elevation. The staff also

considered that dam releases could be managed to create a more normative flow regime

downstream or to increase downstream flows in low flow seasons. Each of these modifications

to the water release policy would trade off impacts among various water management

objectives. Based on discussions with VDEQ and VDIGF, the staff concluded that the

continuation of the existing dam release policies and an increase in the elevation threshold for
Comments Within Scope

NUREG-1811, Volume II 3-112 December 2006

40 cfs release represent the types of release options that VDEQ was considering. 

Nevertheless, the Commonwealth of Virginia has the sole authority to regulate reservoir

releases from North Anna Dam. Accordingly, no changes to this EIS were made based on this

comment.

3.4 Ecology

This section reviews comments related to terrestrial ecology, aquatic ecology, and issues

related to wetlands.

3.4.1 Terrestrial Ecology

Comment: The wording in Table 10-1 and Page 10-6 appear to be inconsistent regarding

terrestrial ecology impacts. [page 10-5, line 19;page 10-6, Table 10-1, line 5] (DW-0423 50)

Response: The text in Table 10-1 and page 10-6 of Volume I are consistent. Table 10-1

indicates that there is an unavoidable impact of construction (i.e., loss of habitat) and provides

methods for mitigation. The text on page 10-6 explains the magnitude of this impact and

provides more details regarding the specific amount and quality of habitat that is subject to

disturbance. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The Department of Forestry indicates that activities contemplated under the Early

Site Permit will not give rise to significant impacts upon Virginia's forest lands. However, the

Department reserves the right to comment further should the project proceed [and provided

specific guidance]. (SW-0017 76)

Response: This comment references the Department of Forestry’s comment related to future

activities. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Page 2-31 line 30 mentions that Dominion has cooperated with Ducks Unlimited

and the Audubon Society to allow informal monitoring. Has the NRC consulted directly with

these groups? (DW-0438 47)

Response: These organizations were not contacted directly by the NRC staff. However, data

collected near the NAPS site as part of the Audubon Society-sponsored Christmas bird count

were examined by the staff as part of the evaluation of the terrestrial environment. The text in

Section 2.7.1.3 was changed to better reflect the relationship between Dominion and these

organizations.

Comment: What is the basis for the statement on Page 5-11 line 32 that collisions would be

rare. (DW-0438 143)
Comments Within Scope

 December 2006 3-113 NUREG-1811, Volume II

Response: The general issue of avian collisions with structures associated with nuclear power

plants was evaluated in the Generic Environmental Impact Statement for License Renewal of

Nuclear Power Plants (NUREG-1437) (NRC 1996). In that document, the staff found that avian

collisions with structures were not a significant issue at any of the operating nuclear power

plants throughout the United States. This conclusion was based on extensive literature reviews

and the operating histories of more than 100 nuclear reactors at more than 50 sites around the

U.S. including the North Anna site. The staff is not aware of any data or reviews published

since the license renewal GEIS was prepared that would change those generic conclusions. 

Avian collisions with existing structures at NAPS have not been observed to any significant

degree, and the NAPS site is not in an area with unusually high levels of bird migration. There

would be no new facilities at the North Anna ESP site, including the wet and dry cooling towers,

that would significantly increase the number of avian collisions at the site. Most of the notable

cases of avian collisions have occurred at sites that have a tall, narrow tower (such as a radio

tower) with guy wires that are not visible at night or during periods of reduced visibility. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: According to the Department of Forestry, the activities pursuant to the Early Site

Permit will not significantly affect the forests of the Commonwealth. (DW-0439 57)

Response: The comment is consistent with the staff’s analysis of the potential impacts to

terrestrial systems. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Page 2-31 line 31 states that the “NRC expects Dominion to work with the State on

development and implementation of any required monitoring programs.” The applicant should

stipulate now which monitoring activities will be implemented. Preferably, monitoring activities

should be detailed as one of the mitigation measures in a DEIS. (DW-0438 48)

Response: As part of this ESP application, no specific power plant design or site layout has

been submitted; consequently, it would not be possible to specify the environmental monitoring

that would be performed during construction or operation to protect terrestrial resources. The

staff may identify an appropriate terrestrial ecology monitoring program at the time of the COL

application review and approval process. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: Page 2-29 lists some of the birds in the areas. Dry coolers may emit high-pitched

sounds. What are the impacts on avian and terrestrial species? (DW-0438 46)

Comment: Dry coolers may emit high-pitched sounds which could affect certain wildlife. The

frequency characteristics of the noise should be assessed in addition to the sound pressure

levels in Section 5.4.4. (DW-0438 142)
Comments Within Scope

NUREG-1811, Volume II 3-114 December 2006

Response: Dry cooling towers have mechanical components that produce noise. The staff is

not aware of any reason why an unusual level of high-pitched sound would be produced by 

cooling towers. Based on the information provided by Dominion regarding the noise levels

associated with dry cooling towers, the overall decibel level at the point where natural habitats

would exist adjacent to the site would be below the levels known to cause adverse effects in

birds and other wildlife. Furthermore, high-frequency sound attenuates more rapidly than sound

at the lower end of the audible noise spectrum. Should high frequency sounds from cooling

towers be generated, they are not likely to affect wildlife. Accordingly, no changes were made

to this EIS as a result of these comments.

Comment: Page 4-8 line 15 discusses possible third-party permit conditions that “may” restrict

the timing of certain construction activities. What if these permits are not imposed by the other

agency? The applicant should stipulate here the mitigation measures to be applied. 

(DW-0438 94)

Response: If the State agency with regulatory jurisdiction over the wildlife at the site does not

choose to impose any permit conditions, then the staff would assume that there are no

restrictions required. While the NRC would consider mitigation for the actual construction

activities specified in a COL application for a specific design and plant layout, it is outside the

mandate of the NRC to impose restrictions or mitigation measures in areas that are specifically 

under the jurisdiction of other State or Federal agencies. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: [The] analysis [of transmission line adequacy] should be done for the Final EIS, and

the impacts on terrestrial resources (Section 5.4.1.4) and threatened species (Section 5.4.3) of

building one or more additional transmission lines should be fully considered. (DW-0437 62)

Response: Dominion performed a preliminary analysis of the adequacy of its existing

transmission system to handle the additional load produced by up to two additional generation

units at the North Anna ESP site. Based on this analysis, Dominion believes that the

transmission system is adequate and has stated that no changes to the system are needed or

anticipated. The NAPS site was initially planned to contain four nuclear power units, and as

such, much of the infrastructure necessary to support an additional two units is already present. 

If a subsequent analysis at the time of a COL application reveals that changes to the

transmission system would be needed to transmit the additional electrical load from one or more

new units at the North Anna ESP site, such modifications to the transmission system would be

subject to Virginia State Corporation Commission and Federal Energy Regulatory Commission

oversight. The NRC would evaluate and disclose the impacts of these modifications, if known,

in a separate NEPA analysis during the review of a COL application. Accordingly, no changes

were made to this EIS as a result of this comment.
Comments Within Scope

 December 2006 3-115 NUREG-1811, Volume II

Comment: Delete the phrase “if additional power from Units 3 and 4 is transmitted through this

system” from the end of Section 5.4.1.4. (DW-0438 145)

Response: The subject phrase was included to indicate that the conclusion given at the end of

Section 5.4.1.4 is still applicable if the system is also used to transmit power generated by any

new units at NAPS. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: Under a memorandum of agreement between DCR [Commonwealth of Virginia,

Department of Conservation and Recreation] and the [Virginia] Department of Agriculture and

Consumer Services (VDACS), DCR represents VDACS in commenting on potential project

impacts on state-listed threatened and endangered plant and insect species. VDACS has

regulatory authority to conserve rare and endangered plant and insect species. The proposed

project will not adversely affect such species, according to DCR. VDACS confirms this

statement. (DW-0439 2) (SW-0017 71)

Comment: According to the [Virginia] Department of Conservation and Recreation, natural

heritage resources have been documented in the project area. However, due to the scope of

project activity and the distance to the resources, the Department of Conservation and

Recreation does not anticipate that the activities pursuant to the Early Site Permit would

adversely affect these natural heritage resources. (DW-0439 1)

Comment: Because new and updated information is continually added to the Biotics Data

System, NRC or the applicant should contact the [Virginia] Department of Conservation and

Recreation’s Division of Natural Heritage ...for updated information if a significant amount of

time passes before the foregoing information on natural heritage resources is used. 

(DW-0439 3)

Response: If the North Anna ESP is issued and an applicant applies for a COL referencing

that ESP, then the staff would contact appropriate State and Federal agencies at the COL

review stage, and any updated information would be obtained and evaluated at that time. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the

ESP]...Impact to wildlife...endangered species (bald eagles) as a result of increased water

temperatures, reduced water flow, increased drought cycles and possible loss of food supply for

endangered species due to fish kills as a result of high water temperatures in the cooling

lagoons, reduced water flow. (SE-0022 20) (ST-0014 11)
Comments Within Scope

NUREG-1811, Volume II 3-116 December 2006

Comment: On April 27, 2006 FOLA [Friends of Lake Anna] representatives met with Fish and

Game’s predatory bird expert.... A bald eagle’s nest [has been reported] ... in a northern red

oak tree ... within 3 miles of the NAP]. Also on May 18, 2006 the Section 312 Evaluation,

Federal Consistency team had a tour of the Lake Anna “Cooling Lagoons” as hosted by FOLA. 

In attendance were the NOAA Evaluation Team, DEQ, DGIF, LACA [Lake Anna Civic

Association], and Dominion. During the tour of the cooling lagoons adjacent to the discharge

canal location, a bald eagle was seen with a fish in it claws flying just overhead. This was proof

positive that the bald eagles are within three miles of the NAP. (SE-0004 7)

Comment: According to the Department of Game and Inland Fisheries, the existing power

plant does not appear to be within the primary or secondary management zones of any of the

confirmed bald eagle nests. It is possible that a new or unconfirmed nest might be found closer

to the project site, in which case, the applicant should coordinate with DGIF and the U.S. Fish

and Wildlife Service. (SW-0017 82)

Comment: Does the feeding range of bald eagles or loggerhead strikes extend to the North

Anna vicinity? (SE-0045 13)

Comment: [B]ald 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? (SE-0045 18)

Response: It has been established that bald eagles pass through the area and nest within the

region, so bald eagles can be expected to fish from the lake when they are in the area. On

May 17, 2006, the staff informed FWS that it had become aware of two new eagle’s nests

located approximately 2.5 and 5 mi, respectively, from the North Anna ESP site. The staff

concluded that because no ESP activities are proposed within the normal restriction buffer

distances of 0.25 to 0.5 mi used for bald eagle management and protection, the proposed

actions at the North Anna ESP site are not likely to adversely affect the bald eagle (2006b). On

May 20, 2005, the FWS concurred with the staff’s biological assessment that the proposed

action is not likely to adversely affect the bald eagle (FWS 2005).

Because there should not be a significant impact on fish species as a result of the proposed

action, there would not be a significant effect on the availability of this food source for the

eagles. A buffer zone exists between the known nests and the plant site. Should a new nest be

found within the buffer zone near the project site, the applicant would coordinate with the

U.S. Fish and Wildlife Service to ensure proper protection of the eagles. Regarding the

reported bald eagle nest mentioned above, aerial and ground-truthing surveys of the areas

based on the coordinates provided established that the nest belonged to a red-tailed hawk

(documented in Enclosure 1, response 17 in the April 13, 2006 cover letter to Dominion’s ER

Revision 6). Accordingly, no changes were made to this EIS as a result of these comments.
Comments Within Scope

 December 2006 3-117 NUREG-1811, Volume II

Comment: The Department of the Interior has reviewed the Draft Environmental Impact

Statement (DEIS) for an Early Site Permit at the North Anna ESP Site, in North Anna, Virginia.

With the exception of the issue discussed in the paragraph below, the DEIS adequately

addresses issues of concern to the Department, including those regarding fish and wildlife

resources, as well as species protected by the Endangered Species Act.

The U.S. Fish and Wildlife Service (Service) has determined that there is at least one nest of

the bald eagle (Haliaeetus leucocephalus), federally listed threatened at Lake Anna. The

Virginia Department of Game and Inland Fisheries (VDGIF) believes there are additional nests,

but the Lake Anna area is not part of the annual aerial survey, so confirmation of nests would

require additional ground truthing. We recommend the U.S. Nuclear Regulatory Commission

(USNRC) develop an eagle management plan to protect eagle habitat along sections of the lake

shore while allowing development in others. Both land clearing and boat traffic impact eagles. 

We understand that Virginia Dominion Power regulates piers on the Lake. The Service is

interested in pursuing a Memorandum of Agreement with USNRC, Virginia Dominion Power,

and VDGIF to address eagle management at Lake Anna. (SE-0024 1)

Response: In its letter of November 3, 2006, to the U.S. Department of the Interior, the NRC

stated that it does consult with the FWS on the bald eagle under the Endangered Species Act;

however, the NRC does not have the regulatory authority to develop or enforce an eagle

management plan. Therefore, there is no reason for the NRC to develop such a plan or enter

into a memorandum of agreement regarding one.

The FWS confirmed that consultation was completed and that this request was not being made

as part of the consultation process. The concern FWS expressed was that with the potential

de-listing of the bald eagle, it would no longer be protected under the Endangered Species Act

and that protection of the bald eagle may be more difficult under the Bald and Golden Eagle

Protection Act; therefore, implementing an eagle management plan at lake Anna would make

protection easier. Dominion suggested that FWS may want to consider working with Louisa

County on its shoreline management guidelines as a possible means to address eagle

management around the lake. VDGIF expressed concern that there may not be funding for

VDGIF to work on eagle management once the eagle is de-listed because VDGIF is funded for

the protection of endangered species.

3.4.2 Aquatic Ecology

3.4.2.1 Construction Impacts

Comment: Construction and operation of the new facilities will disrupt fish stocks and

wetlands. (DW-0640 2)
Comments Within Scope

NUREG-1811, Volume II 3-118 December 2006

Response: The comment is general and does not specifically identify any species that could

be affected, or any specific impacts on wetlands. Potential impacts to fish are discussed in

Section 4.4.2, and the staff concluded that construction activities would have a small impact on

aquatic ecological resources. Typically, construction impacts to aquatic systems are temporary,

easily mitigated, and can be timed to minimize impacts. Impacts to wetlands are discussed in

Section 4.4.1. The few small wetlands on the ESP site would be avoided to the extent

practicable during construction, and the work would be performed in accordance with

appropriate laws and permits. Disturbance of any areas determined to be wetlands would be

avoided or mitigated, as appropriate. Operational impacts on fish stocks are discussed in

Section 5.4.2. Accordingly, no changes were made to this EIS as a result of this comment.

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. (SE-0045 28)

Response: Although it is possible that the entire station could shut down, it is extremely

unlikely this would happen. The most likely scenario is a shutdown of only one unit at any given

time, which would reduce the potential for cold shock. Accordingly, no changes were made to

this EIS as a result of this comment.

Comment: [Regarding Dominion’s ER] Par[agraph] 5.3.2.2.2 page 3-5-60 Under [Aquatic

Ecosystem Impacts] a. Physical effects, we [Friends of Lake Anna] do not agree that as stated

by Dominion the “1,905,565 gpm (units 1, 2 and 3) would have no impact at the Dike 3

discharge, the current VPDES point of compliance.” “Impacts to aquatic organisms would be

negligible. Mitigation would not be warranted”. The recent Supreme Court decision

(No 04-1527 S.D. Warren Company, Petitioner, v. Maine Board of Environmental Protection et

al) makes “Mitigation warranted”. It includes protections for not only limitations on aquatic but

also recreational uses of the water also. (SE-0007 2)

Response: The staff recognizes the Dike 3 discharge as point of compliance for plant-related

discharges because this is the location identified in the NPDES permit. NRC’s analysis of

impact is based on this location. The Commonwealth of Virginia has the authority to issue the

VPDES permit in accordance with the Clean Water Act. The staff determined in Chapter 5 that

mitigation was not warranted for protection of aquatic organisms or recreational areas. 

Furthermore, the Court in the Warren case, 126 S.Ct 1843 (2006) made that limited holding that

operating a dam to produce hydroelectricity raises a potential for a discharge and, thus requires

State approval pursuant to Section 401 of the Clean Water Act. The case does not stand for

the proposition proffered by the commenter. However, the Commonwealth is free to impose

mitigation measures in connection with its VPDES permit, in accordance with Virginia law. 

Accordingly, no changes were made to this EIS as a result of this comment.
Comments Within Scope

 December 2006 3-119 NUREG-1811, Volume II

3.4.2.2 Operational Impacts–General

Comment: Lake Anna cannot physically support the addition of new reactors. Dominion’s

Early Site Permit application does not adequately address the increased water use associated

with new reactors, which will cause the lake level to drop significantly and will raise water

temperatures harming game fish. (DW-MM3 2)

Comment: There are a number of other issues that I consider to be problematic at Lake Anna;

such as the impact on the water levels, the temperature, the fish population, wetlands and other

aquatic ecosystems, and safety concerns relative to recreational usage of the Lake. 

(DW-0407 3)

Comment: Recreational fishing use on Lake Anna could also be damaged if the health of fish

populations is diminished by the thermal impacts on the lake, as well as increased impingement

and entrainment, from additional reactors at the site. These problems, combined with the

adverse effects of a reduced river flow downstream from the plant caused by additional

reactors, must receive a more thorough consideration in the NRC’s final EIS on the North Anna

ESP. (DW-0437 32)

Comment: Page 2-36 line 42 states that striped bass are already subject to environmental

stress from the existing two units but the later discussion about the impacts of increased

thermal loading from additional nuclear units is cursory. (DW-0438 52)

Response: Some of the above comments relate to the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a proposed closed-cycle,

combination wet and dry cooling system, the quantity of water withdrawn from the lake is

substantially reduced, and heating of the lake would be negligible. Sections 4.3, 5.3, and

5.4.2.7 of the EIS (and Sections 4.3.2 in the ER) describe the physical effects of additional units

at the North Anna ESP site. Sections 5.4.1.3, 5.4.1.4, and 5.4.2.4 in the EIS (and

Sections 2.3.1, 2.4.1.8, 2.4.2.2, 3.4.2, and 5.2 in the ER) describe the effects of additional units

on water levels, temperatures, wetlands, and striped bass. 

The staff has concluded that sufficient water is available for the proposal, i.e., one unit that uses

closed-cycle, combination wet and dry cooling and one unit that uses dry cooling towers. 

Additionally, the proposed units would contribute minimally to the thermal impacts on the lake

and would have a SMALL impact on recreational fishing and the striped bass fishery. 

Impingement and entrainment would be SMALL. Section 5.4.2.6 in the EIS has been added to

discuss the potential effects on the aquatic environment downstream of the dam. 

Comment: If the approval is granted, water levels will undoubtedly decrease in the lake and in

the North Anna river. This will harm fish and underwater vegetation. Because the North Anna

river is a part of the Chesapeake Bay watershed, any problems in this river will result in
Comments Within Scope

NUREG-1811, Volume II 3-120 December 2006

problems in the Bay. Secondly, Lake Anna will experience an increase in temperature, as its

water would be used to cool the new plant. This will have an adverse affect on fish populations. 

(DW-0623 2)

Response: The above comment relates in part to the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which produces minimal thermal

impacts on Lake Anna vegetation and fish populations. The majority of species inhabiting Lake

Anna are pre-adapted to lake level fluctuations and high water temperature and should not be

adversely affected by conditions expected from additional units. Fish and other mobile

organisms actively seek out optimal conditions and avoid potentially harmful ones. Lake

vegetation would not be affected by the construction and operation of additional units at the

North Anna ESP site. Lake Anna is a large reservoir with a well-developed shoreline that offers

a variety of habitats and environmental conditions.

The estimated monthly mean inflow into Chesapeake Bay from 1951 to the present is about

2200 m3

/s (78,000 cfs) (USGS 2005). The changes in the flow in the North Anna River as a

result of the proposed closed-cycle, combination wet and dry cooling system for Unit 3 would be

less than 40 cfs. The staff concludes that this 0.06 percent change in annual average inflow

rate to the Chesapeake Bay would be insignificant.

The potential impacts of lake level changes are discussed in the EIS (Sections 5.3.2 and

5.4.1.3) (and Section 5.2.2.2 of the ER). The results presented quantify the impact on lake

levels that could result from the operation of Unit 3 with a closed-cycle, combination wet and dry

cooling system. The maximum annual drawdown in most years would not differ greatly from the

current operation of the existing units. The results show that the minimum lake levels occur in

the latter half of the calendar year. The data are again summarized here. During the 25 years

(1978 to 2003) evaluated by the staff in its water balance, differences in water levels were less

than 3 in. between the base case and the ESP case for 69 percent of the time based on the

bounding simulation. The timing of predicted differences is expected during the times of the

year when fish are less likely to be impacted by lower lake levels. Fish populations in Lake

Anna and the North Anna River are most vulnerable to low flow conditions during and

immediately after spawning, which generally occurs in spring and early summer. This coincides

with the highest water flows in the watershed.

Reduction in lake water levels would impact submerged aquatic vegetation along the margins of

the reservoir, particularly during drought conditions; however, aquatic vegetation is fast growing

and would quickly be re-established at the new lake levels. Submerged vegetation is not an

important component of small rivers, such as the North Anna River downstream of the dam,

because of turbidity, turbulence, and varying flow rates, and therefore, reduced flows during the

summer is likely to have little effect on submerged vegetation. Accordingly, no changes were

made to this EIS as a result of this comment.
Comments Within Scope

 December 2006 3-121 NUREG-1811, Volume II

Comment: Among my concerns are: increased water temperatures which will negatively affect

game fish. Increased lake temperatures will also affect waters downstream--a “ripple effect,” if

you will. (DW-0998 2)

Comment: The application also fails to sufficiently examine the increase in the lake

temperature, which will negatively affect the striped bass population, a popular gaming fish, and

other marine organisms. Waters downstream will be affected similarly. (DW-MM4 5)

Comment: It would significantly increase the temperature of the lake and downstream, which

would, again, affect the aquatic life, in particularly the habitat of the popular striped bass. It

would also reduce the water flow downstream, which would again affect aquatic life in the river

and increase further conflicts over water use by downstream counties. And finally, it would

more than double the number of aquatic life killed in the intake pipe. (DT-0019 6)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have minimal thermal

impacts on Lake Anna or North Anna River aquatic life. Operation of the proposed

closed-cycle, combination wet and dry cooling system would increase the water temperature in

Lake Anna by approximately 0.1(F and increase impingement and entrainment currently

occurring from the operation of Units 1 and 2 by less than 3 percent. These increases would

have a negligible environmental impact on Lake Anna and the North Anna River. Staff analysis

regarding downstream impacts was added to Section 5.4.2.6.

Comment: This utilization of water already has a damaging effect on the lake, ... and the

aquatic life in the lake. ... The additional nuclear reactors will undoubtedly have serious adverse

effects on the aquatic life in the lake. (DW-0653 4)

Response: The comment is not specific. The hydrological and aquatic impacts assessed with

additional units at the ESP site are discussed in Sections 7.3 and 7.5 of Volume I. Accordingly,

no changes were made to this EIS as a result of this comment. 

Comment: These possible negative impacts will ... affect the biota of the lake and its

ecosystems. (DW-0817 3)

Response: This comment is not specific. The impacts to the biota assessed with additional

units at the ESP site are discussed in Section 5.4.2 of Volume I. Accordingly, no changes were

made to this EIS as a result of this comment.

Comment: Lake temperature will be affected, probably killing the lifeforms that inhabit it [if the

permit is issued]. (DW-MM1 6), (DW-0057 2)
Comments Within Scope

NUREG-1811, Volume II 3-122 December 2006

Comment: And at present when you raise that another four degrees, you’re talking about

100 degrees, and according to most ecologists that I know, when you get above 100 degrees

that’s pretty much lethal for many of the species of fish. (DT-0029 5)

Comment: [T]he potential rise in water temperature could be worse for local ecosystems than

currently predicted. (DW-0415 2)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and its elevated discharge temperatures relative to the

existing discharge from Units 1 and 2 or the proposed Unit 3. With the change in the proposed

cooling system to a closed-cycle, combination wet and dry cooling system, the thermal

discharge of Unit 3 operation to the lake would be negligible as would associated impacts on

the local ecosystem. In general, the majority of species inhabiting Lake Anna are pre-adapted

to high water temperature. Fish and other mobile organisms actively seek out optimal

temperatures and avoid potentially harmful conditions. Lake Anna is a large reservoir with a

well-developed shoreline that offers a variety of habitats and environmental conditions. The

staff has concluded that the operation of the proposed Unit 3 cooling system would raise the

temperature of Lake Anna by only 0.1(F, a negligible amount, and considers this a SMALL

impact. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Page 2-34 line 6 discusses clams in Lake Anna. How will the increased lake

temperature from the proposed units effect the clam populations? (DW-0438 50)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling for Unit 3 system. With the change in the proposed cooling system to a

closed-cycle, combination wet and dry cooling system, thermal discharges to the lake would be

negligible. The principal clam species inhabiting the reservoir is Corbicula sp. or the Asiatic

clam. Other mollusc genera are reported for collections from Lake Anna (VEPCO 1986) but they

account for only a minor portion of the benthic organisms. Asiatic clams, an invasive species

native to Asia, were introduced in Lake Anna. They are generally considered a nuisance

species. Their numbers increased from 1979 (when first discovered) to the late 1980s. The

clam population densities declined in the 1990s. With two units, maximum mean monthly Lake

Anna surface temperatures approach 90(F during July and August. It is not expected that the

addition of the proposed Unit 3 cooling system would cause any significant change in Asiatic

clam habitat nor destabilize the populations that are established in the lake. Asiatic clams would

remain an important component of the benthos and the most common mollusk in Lake Anna. 

Impacts would be small. Accordingly, no changes were made to this EIS as a result of this

comment. 

Comment: Another reactor of the size that Dominion is proposing would reduce the lake level

affecting fish habitat. (DT-0019 4)
Comments Within Scope

 December 2006 3-123 NUREG-1811, Volume II

Comment: Lower water levels will impact the lake ecosystems...This could kill many of the life

forms that inhabit it. (DW-0772 4)

Comment: I am worried that the use of the water would affect the fish and other wildlife, disrupt

the ecosystem. (DW-1151 3)

Response: These comments are general in nature and were received based on the evaluation

in the Draft EIS of a once-through cooling system for Unit 3. The proposed cooling system has

since been changed to a closed-cycle, combination wet and dry cooling system. Potential

impacts of lake level changes are discussed in the EIS (Sections 5.3.2 and 5.4.1.3) and the ER

(Section 5.2.2.2). In non-drought years, the projected incremental decline of the lake level

attributable to the proposed Unit 3 is not expected to affect fish and wildlife in the reservoir or

the North Anna River. The timing of drawdown is expected during the times of the year when

fish are less likely to be impacted by lower lake levels. Impacts are more likely to occur when

fish are spawning (i.e., in the spring). An expected impact from extended lake level changes

would likely slightly reduce available fish habitat, but it is unlikely to destabilize fish populations

and other aquatic organisms. This is discussed in Section 5.4.2.8 of this EIS. In general, fish

species inhabiting Lake Anna are pre-adapted to tolerate the large fluctuations in lake level that

occur frequently in natural watercourses. Accordingly, no changes were made to this EIS as a

result of these comments.

Comment: [N]uclear power would disrupt marine ecosystems. In addition to the power plant’s

drawing water from Lake Anna, the power plants would also discharge water back into the lake. 

The discharged water can be 25 degrees higher than the rest of the lake and contain chemicals,

heavy metals, cleaning solvents, biocides, and radioactive contamination. (DT-0008 5)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling for Unit 3 system. With the change to a closed-cycle, combination wet

and dry cooling system, thermal impacts on the lake would be negligible. Lake Anna is not a

marine environment. It is a freshwater reservoir that was primarily constructed as a source of

cooling water for the North Anna nuclear power facilities. The proposed wet and dry cooling

system for Unit 3 would increase the temperature of Lake Anna by approximately 0.1(F, a

negligible amount that would not result in additional thermal impacts to Lake Anna or the North

Anna River. Overall, the staff determined in Sections 5.3.1 and 5.4.2.4 that the impacts of the

thermal discharge from Unit 3 to the WHTF would be negligible and would not destabilize the

native fish populations. During the summer when lake temperatures are naturally warmer,

species sensitive to temperature increases would still be able to find refuge in cooler, deeper

parts of the lake. Additionally, the fish found in the lake most frequently are prolific, exhibit a

high reproductive potential, and compensate to offset losses.

With regard to water quality, the impact on water quality of Lake Anna from the effluents from

NAPS Units 1 and 2 is regulated by an NPDES permit administered by the Commonwealth of
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NUREG-1811, Volume II 3-124 December 2006

Virginia. A NPDES permit would also be required for Units 3 and 4. The maximum levels of

chemical contaminants allowed under such a permit would be protective of aquatic species. 

Radioactive contamination is discussed in Section 5.7 of this EIS. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: For temperatures at or above 100 degrees F, the DO [dissolved oxygen] of the

WHTF will be in the 5 ppm where fish cannot survive. Table 5-21 of the ESP, for the Aquatic

Ecosystems should have an impact level of MODERATE and not SMALL as represented by the

ESP. (DW-0806 9)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. With the change to a closed-cycle, combination wet

and dry cooling system, thermal impacts on the lake, and therefore dissolved oxygen, would be

negligible. Regarding the dissolved oxygen comment, the commenter is not correct. Known

fish species in Lake Anna can survive and thrive at dissolved oxygen concentrations of 5 ppm. 

Even cold water species can survive in waters with dissolved oxygen level of 5 ppm

(Swingle 1969). Fish would actively avoid areas with high temperatures or low dissolved

oxygen. Accordingly, no changes were made to this EIS as a result of this comment.

3.4.2.3 Entrainment and Impingement Impacts

Comment: The Department of Game and Inland Fisheries made an earlier recommendation for

a 1 mm mesh size screen and an intake velocity of 0.25 fps. During several meetings with NRC

and Dominion, there was discussion regarding the lack of sweeping velocity in a reservoir

situation. As a result of further review of scientific literature, DGIF arrived at a recommendation

of a 2 mm mesh size and an intake velocity of 0.5 fps for the intakes for proposed Units 3 and 4. 

The 9.5 mm screen proposed by the applicant (SDEIS, pages 5-19, 5-26) will only exclude fish

larger than 3.4 inches from the intake. The 2 mm mesh size and 0.5 fps intake velocity will

make for more effective resource protection, according to DGIF. (SW-0017 57)

Response: The statement that a 9.5-mm screen would only exclude fish longer than 3.4 in.

rests on the assumption that the fish enter the screen in a perpendicular orientation (i.e.,

head-first). It is highly unlikely that this would consistently happen; thus the actual size of the

fish commonly excluded (impinged) could be less than 3.4 in. Additionally, EPA has determined

that 0.5 ft/sec or less intake velocity is sufficiently protective for aquatic life. A discussion of this

issue is presented in Section 5.4.2.1 of this EIS.

Comment: The potential amount of fish loss resulting from impingement and entrainment has

been reduced by using the closed-cycle, wet-dry cooling method instead of the once-through

system originally proposed. (SW-0017 9)
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 December 2006 3-125 NUREG-1811, Volume II

Response: This statement by VDEQ is in agreement with the staff’s analysis. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: [E]ntire sections on impingement and entrainment are virtually identical to the ER. 

Please indicate whether (and if so, how) NRC Staff did its own independent assessment of the

information that Dominion supplied in its ER. (DW-0437 25)

Response: Much of the historic information presented in Dominion’s ER was extracted from

NRC’s supplemental EIS for renewal of the North Anna Units 1 and 2 operating licenses

(NRC 2001). Dominion’s ER was submitted under oath or affirmation as part of the application

for an ESP. Therefore, the staff relied on the supplemental license renewal EIS and the ER as

sources of basic information about the plant parameters, the site, the region, and the

environment. In addition, the staff visited the site, consulted with local, State and Federal

agencies, and conducted its own independent review.

With regard to the summary of the impingement and entrainment data collected at NAPS since

the initial operation of Units 1 and 2 as presented in the Draft EIS, the NRC review team

members contacted the U.S. Fish and Wildlife Service (FWS) and staff of the Virginia

Department of Game and Inland Fisheries regarding information relevant to the aquatic ecology

of Lake Anna and the North Anna River. The thermal impact assessments used in the aquatic

evaluations were conducted by NRC review team members. The team members concluded

that the data and presentation in the ER accurately represent entrainment and impingement of

aquatic organisms at NAPS Units 1 and 2. As a result, portions of the presentation in the ER

were extracted directly to lessen the possibility of misrepresenting the data. However, the

omission of the reference to the Dominion ER was unintentional and has been corrected.

The North Anna ESP EIS is the result of the staff’s review and properly includes material from

the other sources. Section 5.4 of the EIS has been reviewed and revised to ensure that

sources of information are clearly identified and properly attributed. Because the proposed

cooling system has since been changed to a closed-cycle, combination wet and dry cooling

system and would have a significantly lower intake flow rate, the entrainment and impingement

losses were reevaluated. This reevaluation showed that the operation of Unit 3 with a

closed-cycle, combination wet and dry cooling system would increase current impingement and

entrainment rates associated with the operation of Units 1 and 2 by less than 3 percent because

of their reduced water needs for Unit 3.

Comment: Tables 5-4 through 5-6 (pages 5-22 through 5-24) reflect seasonal losses from

March through July, so the “Yearly Totals” column is not appropriately named. To properly

reflect yearly totals, losses for the remaining seven months need to be added to the table. If

summer, fall, and winter data were not collected, that data may have to be extrapolated by the

best fitting of a non-linear function to the available data. Only then can the full impacts of

entrainment on important fish species begin to be addressed. (DW-0439 33) (SW-0017 34)
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Comment: The Department of Game and Inland Fisheries recommends that the entrainment

tables be corrected to reflect an actual annual loss. The discrepancies should be corrected and

a much more rigorous spatial and temporal evaluation conducted before any conclusion can be

reached that the effects of impingement and entrainment are “small.” (DW-0439 39)

(SW-0017 40)

Response: “Yearly Totals” are estimated based on the months in which larval fish were

present in the entrainment samples. The tables were appropriately changed to make the

estimate clear to the reader. Eggs and larvae are typically not present in any significant

numbers in the water column in summer, fall, and winter. Clarification of the staff’s methodology

was added to the table. The conclusions reached in the Draft EIS are not affected.

Comment: The Department points out that the conclusions regarding entrainment losses in the

Draft EIS are not based on scientifically sound evidence. This is exemplified by the statement: 

“Because the fish entrained most frequently are prolific, exhibit a high reproductive potential,

and compensatory responses of the fish population occur to offset losses, the staff concludes

that the impacts of entrainment would be SMALL [emphasis in the original]. (See Draft EIS,

page 5-25, end of Section 5.4.2.3.) (DW-0439 38) (SW-0017 39)

Response: This comment was received based on the evaluation in the Draft EIS on a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a significantly

lower intake flow rate, which would substantially reduce the entrainment and impingement

losses. The staff determined that the operation of the proposed Unit 3 cooling system would

increase the entrainment losses by approximately 2 percent from currently occurring losses

from the operation of Units 1 and 2.

The NRC staff has described the methods used to evaluate potential impacts to fish in Lake

Anna. For potential construction impacts, this discussion is provided in Section 4.4.2 and, for

potential operational impacts, in Section 5.4.2.3 of the EIS. The staff reviewed the numbers and

species of fish in samples collected at the intake during entrainment studies. The staff stated its

assumptions about fish distribution in Lake Anna, entrainment rates and survival for fish that are

entrained based on the entrainment data. The evaluation of the revised intake system and the

associated impingement and entrainment impacts based on the proposed closed-cycle,

combination wet and dry cooling system are provided in Section 5.4.2. Because the operation

of the proposed Unit 3 cooling system would increase overall impingement and entrainment by

less than 3 percent, the staff concluded the environmental impact of impingement and

entrainment is SMALL. Accordingly, no changes were made to this EIS as a result of this

comment.
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 December 2006 3-127 NUREG-1811, Volume II

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? (SE-0045 27)

Response: There are numerous difficulties associated with environmental sampling to estimate

larval abundances in large reservoirs. Generally, spatial and temporal variability makes it

difficult to accurately assess larval trends in large bodies of water, and such variability leads to

highly variable results. The most efficient sampler in these large systems is the plant cooling

system, because it operates continuously and provides opportunities for sample collection that

can be related to plant flow. Numerical models are used to estimate larval abundance based on

plant characteristics and to integrate the results through time. There are inherent uncertainties

in all models, and entrainment models are no exception, but the methods employed at North

Anna represent a reasonable approach to assessing entrainment impacts. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: Impingement and entrainment calculations for Unit 3 were based on intake flows of

27,309 gpm or 60.8 cfs; NRC staff used correct flow rates in the entrainment section 5.4.2.3 of

the Draft EIS, but referenced lower flows in the impingements section. (SE-0050 19)

Response: Impingement and entrainment losses were based on a maximum flow rate of

27,309 gpm or 60.8 cfs. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: The Virginia Department of Environmental Quality -- Game and Inland Fisheries

(Appendix F-50) have raised issues related to fish impingement and entrainment as well as

increase[d] water temperature and circulation flow patterns associated with the water demand of

the proposed units during EIS application review. It is unclear under the Draft EIS [and SDEIS]

what was modeled, what were the results of the modeling and what was the mitigation, if any

being proposed. (DW-0422 8) (SE-0030 8)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a significantly

lower intake flow rate and would substantially reduce the entrainment and impingement losses. 

It also would result in a substantially reduced discharge temperature that would be similar to

those of Units 1 and 2.

Fish impingement and entrainment were not modeled but were projected based on the

assumptions as stated in Sections 5.4.2.2 and 5.4.2.3 of the EIS. To determine the potential

impingement and entrainment associated with the proposed Unit 3 cooling system, Dominion

assumed the current fish and larval distributions and compositions were similar to those

observed during the study required by Section 316(b) of the Clean Water Act, that the proposed
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NUREG-1811, Volume II 3-128 December 2006

cooling system would operate at 100 percent pumping capacity, and would use a maximum flow

rate of 60.8 cfs to determine impingement and entrainment losses. The staff agreed with this

approach and compared the estimated impingement and entrainment losses associated with the

Unit 3 cooling system to the losses currently occurring from operation of Units 1 and 2. 

Because the additional losses associated with the proposed Unit 3 cooling system represent

less than a 3 percent increase above the losses currently occurring, the staff concluded that the

potential impacts related to impingement and entrainment would be SMALL, and no mitigation is

expected to be needed. This statement regarding mitigation has been included in the Final EIS.

Comment: New reactor units may also have a negative impact on recreational fishing in

North Anna through the effects of increased water temperature and impingement/entrainment,

where fish and fish larvae are sucked into the water intake apparatus required to cool reactors

at the NAPS. (DW-0437 30)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a significantly

lower intake flow rate and would substantially reduce the entrainment and impingement losses. 

Additionally, thermal discharges to the waste heat treatment facility would be substantially

reduced from the original proposal, and heating of the lake would be negligible. The comment

is not specific. Potential entrainment impacts are discussed in Section 5.4.2.3 of the EIS. The

recreational fishery for striped bass is discussed in Section 5.4.2.5, and potential recreation

impacts are discussed in Section 5.5.3.4. The staff concluded that the impacts of impingement

and entrainment were SMALL. Accordingly, no changes were made to this EIS as a result of

this comment.

Comment: How can a 300% increase in the number of fish impinged (422,000 per year from

182,000) be considered a SMALL impact in Section 5.4.2.2? (DW-0438 146) 

Comment: The Final EIS should acknowledge that more than doubling the number of

entrained larvae would violate the Clean Water Act, which requires the use of best available

technology. (DW-0437 23)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a significantly

lower intake flow rate and would substantially reduce entrainment and impingement losses. 

NRC’s significance levels for impact of SMALL, MODERATE, or LARGE refers not to some

quantitative standard of change but rather the effect of the impact category on the resource. 

Even a doubling or tripling of losses may not necessarily result in destabilizing the important

attributes of the resource.
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 December 2006 3-129 NUREG-1811, Volume II

Based on the assumption that the current fish and larval distributions and compositions in Lake

Anna were similar to those observed during the study required by Section 316(b) of the Clean

Water Act, Dominion estimated impingement and entrainment losses that would occur during

the operation of the proposed Unit 3 cooling system. The staff agreed with this approach and

compared the estimated losses associated with the Unit 3 cooling system to the losses currently

occurring from operation of Units 1 and 2, which are not considered to adversely impact the fish

and larval populations of Lake Anna. The staff determined that the operation of the proposed

Unit 3 cooling system would increase the overall impingement and entrainment losses by less

than 3 percent. Because this constituted an undetectable impact on the fish and larvae of Lake

Anna, the staff concluded that the impact of the proposed Unit 3 cooling system would be

SMALL. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: [I]t is crucial to consider the size and age distributions of the impinged fish in order

to understand the impact on the structure and viability of the population. This information

should be included in the Final EIS. (DW-0437 24)

Response: Potential impingement impacts are discussed in Section 5.4.2.2 of the EIS. 

Comparison of the estimated impingement losses for the proposed Unit 3 cooling system to

existing losses from the operation of Units 1 and 2 indicate that the operation of Unit 3 could

increase overall impingement and entrainment losses by less than 3 percent. Because this

represents a SMALL impact, the staff does not believe the additional data related to the size

and age distribution of impinged fish are necessary to reach a conclusion on the level of impact. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Tables 5-2 (page 5-18) and 5-5 (page 5-23) may have significant errors, or the

reasons for the differences are not fully explained. For example, in Table 5-2, for Unit 3,

January striped bass and bluegill numbers impinged are greater than in Units 1 and 2

(Table 5-1, page 5-17), but black crappie, gizzard shad, white perch, and yellow perch numbers

are less than in Units 1 and 2. Similar discrepancies exist for other rows in the table, and for the

cumulative Tables 5-3 and 5-6. These discrepancies should be explained further. (DW-0439

34) (SW-0017 35)

Comment: Section 5.4.2.2 estimates the impingement loss to the fish population as a

percentage of the estimated total lake population as derived from cove rotenone. We applied

this same technique to entrainment numbers and calculate that 6.8% of the gizzard shad and

87% of the black crappie are lost due to entrainment. When combined with impingement 7.7%

of the gizzard shad and 93.9% of the black crappie numbers are killed by the intake structure. 

We do not consider losing almost 8 and 94% of these populations from an intake a small

impact. (DW-0439 36) (SW-0017 37)

Response: These comments were received based on the evaluation in the Draft EIS on a

once-through cooling system for Unit 3. The proposed cooling system has since been changed
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NUREG-1811, Volume II 3-130 December 2006

to a closed-cycle, combination wet and dry cooling system, which would have a significantly

lower intake flow rate and would substantially reduce the entrainment and impingement losses. 

Impingement impacts for representative fish species as the biomass lost to impingement ranged

from 0.02 percent for bluegill to 3.8 percent for the black crappie. Section 5.4.2.2 has been

revised to reflect the lower rates of predicted impingement and entrainment. 

Comment: The Department of Game and Inland Fisheries (DGIF) applauds the applicant’s use

of “worst case” scenarios for estimating impingement and entrainment, and acknowledges the

estimate of a 131% increase in the impingement rate for Unit 3 (Draft EIS, pages 5-13 through

5-18, Sections 5.4.2.1 and 5.4.2.2). In developing the total estimate, data derived from 1979

through 1983 was added to worst-case Unit 3 operation.

However, it is not clear whether the 1979-1983 values for Units 1 and 2 reflect current operating

conditions and are valid. The Final EIS should indicate whether water volume pumped for these

units has increased or decreased since the 1979-1983 study period, in light of the facts that

plant operating time, efficiency, and volume of water pumped have all increased. In such case,

the table reflecting the impacts of Units 1 and 2 (Table 5-1, page 5-17) needs to be revised to

reflect current operating conditions. (DW-0439 30) (SW-0017 56)

Response: The commenter expressed concern that the NAPS water volumes pumped through

the intake structure during the impingement and entrainment sampling from 1979 to 1983 were

not representative of the volume of water currently pumped through the facility, resulting in an

underestimate of impingement and entrainment. Because the potential entrainment and

impingement losses for proposed Unit 3 were derived by scaling the losses associated with the

1979-1983 study, the comment expresses concern that the potential underestimates in the

original study were applied to the predictions for Unit 3. Because the original predictions

expressed entrainment as a function of water volume, it is appropriate to apply a scaling factor

to develop entrainment estimates for Unit 3. For impingement, the explanation is slightly

different. Impingement, unlike entrainment, is a function of the approach velocity to the intake

screen, and intake velocity is related to the flow rate through the intake and can be influenced

by reservoir water levels. The relationship between impingement losses, approach velocity, and

reservoir level is not linear. Additionally, the size of the intake structure also affects the rate of

impingement. Thus small intake structures typically used for closed-cycle cooling systems have

relatively low levels of impingement when compared to once-through systems. Because the

estimates of impingement derived for Unit 3 were based on the 1979-1983 study of the

once-through system for NAPS Units 1 an 2 and normalized by volume, it probably represents

an overestimate of the impingement losses that would occur at Unit 3. Accordingly, no changes

were made to this EIS as a result of this comment.
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 December 2006 3-131 NUREG-1811, Volume II

Comment: The Department of Game and Inland Fisheries recommends the use of state-of-theart intake screens, as encouraged by the U.S. Environmental Protection Agency in recent

screen recommendations. Specifically, the Department of Game and Inland Fisheries

recommends openings of 1 millimeter (mm), and an intake velocity of 0.25 feet per second (fps)

to protect aquatic life. This would greatly alleviate the impingement and entrainment issue, as

would the use of a dry cooling tower. (DW-0439 31)

Response: The recommendations noted in this comment are in a 1999 report prepared for the

Virginia Department of Game and Inland Fisheries (VDGIF) entitled Design Criteria for Fish

Screens in Virginia: Recommendations Based on a Review of the Literature by C. Gowan,

G. Garman, and W. Shuart. Gowan et al. (1999) focused only on the mechanics of physically

screening out organisms of a certain size and not on analyzing the impact of a particular mesh

size on the population dynamics of target species. The report did not address debris loading,

lack of sweeping currents, or the size of the screened area needed for a large plant. Therefore,

the NRC staff has concluded that the study is not directly applicable to large central station

power generators.

In a letter to FWS dated 18 June 2003 (ML031700052), the NRC staff stated that unless

(1) there is a demonstrated impact, (2) the reduced mesh size would mitigate the impact, and

(3) the technology is feasible, the NRC did not plan to consider the 1-mm mesh size as a

mitigation. Furthermore, the use of fine mesh screens is of little value in lakes or reservoirs that

lack a sweeping current to continually wash impinged organisms from the surface of the screen.

Before any additional units operate at the ESP site, a COL applicant would have to obtain an

NPDES permit from the VDEQ. As part of the review for that permit, a COL applicant would be

required to comply with the new EPA Clean Water Act Section 316(b) regulations related to

intake structures performance standards for steam electric facilities. As part of the NPDES

permitting process, the Commonwealth of Virginia could require additional mitigation. Such

mitigation could include modifications to reduce impingement to the intake structure. A

discussion of screen mesh size was added to Section 5.4.2.3 of this EIS as a result of this

comment.

3.4.2.4 Impacts on Fisheries–General

Comment: Lake Anna was created specifically to support nuclear power plants. Some of the

fish that they [opponents of the ESP] are so worried about are not indigenous to this area and

have been stocked in the lake. Furthermore, the existence of the power plant actually serves to

sustain many fish populations. Try reading an excellent summary of the Lake Anna ecosystem

written by expert anglers at the McCotter's (PH) Lake Anna Guide Service website. (ST-0012 7)
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NUREG-1811, Volume II 3-132 December 2006

Comment: We will agree that this new system will address the flow impacts to a great extent,

will also take in less water from the lake which is good in terms of what they're talking about is

taking in fish, but the water evaporation impacts remain. (ST-0005 9)

Response: These comments are acknowledged and do not provide any additional information. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: The Department of Game and Inland Fisheries disagrees with the assessment that

the impact of Unit 3 upon gizzard shad, the most prevalent species, would be a “small” impact

(page 5-21, end of Section 5.4.2.2). As DGIF states in its comments on the Draft EIS: Gizzard

shad are indeed a “prolific forage fish,” but their abundance has been low in VDGIF samples in

two recent years. This species is the primary forage for stocked predators (striped bass and

walleye) and also supplements largemouth bass diet. Further declines in striped bass habitat

(another contested issue) combined with potential reductions in the forage base could

significantly impact this recreationally and economically important fishery. (DW-0439 35)

(SW-0017 36)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a significantly

lower intake flow rate and would substantially reduce the entrainment and impingement losses,

including those of the gizzard shad. The staff determined the operation of the proposed Unit 3

cooling system could increase impingement and entrainment of gizzard shad by less than 3

percent relative to the current losses associated with the operation of Units 1 and 2. This was

considered a SMALL impact by the staff. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: This wording is inconsistent with DEIS Section 2.7.2.1 and ER Section 2.4.2.2. 

Grass carp were stocked in the WHTF in 1994 to control hydrilla. [page 2-40, line 10] 

(DW-0423 11)

Response: The following two statements are from the Draft EIS, Section 2.7.2.1: “Sterile

triploid herbivorous grass carp (Ctenopharyngodon idella) was stocked by Virginia Power,” and

“During 1994, grass carp were stocked by Virginia Power (with the approval of the VDGIF) in

the WHTF to control the growth of the nuisance submerged aquatic plant hydrilla (Hydrilla

verticillata).”

The following statement is from the ER, Section 2.4.2.2. “In 1994, a fifth non-native species, the

herbivorous grass carp, was stocked by Virginia Power (with the approval of the VDGIF) in the

WHTF to control the growth of the nuisance submersed aquatic plant hydrilla.” The wording is

not inconsistent, and accordingly, no changes were made to this EIS as a result of this

comment.
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 December 2006 3-133 NUREG-1811, Volume II

Comment: The balance of a major argument within the document centers on subjective

speculation on whether the installation of Units 3 and/or 4 would present complications for fish

populations. DGIF believes that such complications would occur. More likely at issue is not if

complications would occur, for they almost certainly would; but the extent of such complications

and the population level impacts. Without extensive modeling, it is impossible to argue either

point successfully. We recommend the application of sound scientific modeling to the decision

process and that appropriate corrections based on model outcomes be incorporated in the

Final EIS. (DW-0439 47) (SW-0017 54)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a significantly

lower intake flow rate and would substantially reduce the entrainment and impingement losses

and minimize effects on fish populations. The EIS describes the methods used to assess

potential impacts to fish in Lake Anna. For potential construction impacts, see the discussion in

Section 4.4.2, and for potential operational impacts, see the discussion in Section 5.4.2 of the

EIS. These methods are scientifically accepted and provide a reasonable assessment of

impact. The losses resulting from impingement and entrainment on Lake Anna from additional

units would be undetectable because of their small numbers, the large year-to-year variability in

population size of the species impinged or entrained, and the inability to accurately sample

populations even in reservoirs without having a significant impact on the population. Modeling

population changes, even in a relatively closed system such as Lake Anna would add little to

the impact assessment. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: According to DGIF, the Draft EIS makes the following statement: “... long-term

monitoring of the North Anna River has documented improvements in the abundance and

diversity of aquatic biota since impoundment.” DGIF is unaware of any intensive data analysis

to support such an assertion. DGIF’s analysis of the Dominion data set documented changes

that are reflective of drought conditions. Placing the population of aquatic species under

frequent drought stress will shift the community substantially. This analysis was previously

provided to Dominion. Recent DGIF surveys of the North Anna River have suggested that the

primary sportfish, smallmouth bass, has much lower abundances than in other rivers in the

region. Other fish populations were present in relatively low levels. It is the opinion of

DGIF biologists that the low abundance and biomass of predator and forage species in the

North Anna River is related to higher than naturally occurring incidences of drought conditions. 

There also is the possibility that drought flow conditions could adversely impact downstream

anadromous nursery areas. This potential impact should be evaluated. Increasing the drought

frequency to the proposed extent would have an unacceptable negative impact on this fishery. 

(DW-0439 46) (SW-0017 8) (SW-0017 53)
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NUREG-1811, Volume II 3-134 December 2006

Response: The quoted statement identified in the comment could not be found in the Draft

EIS. The staff has included additional information on the North Anna River fishery downstream

of the dam in Section 5.2.4.6 of the EIS in response to this comment. Clearly, the fishery in the

North Anna River has improved since creation of Lake Anna. Prior to the construction of the

dam, flows in the vicinity occasionally were as low as 5 cfs, and water quality was severely

degraded for many miles downstream in the North Anna River because of drainage from

Contrary Creek. Pre-impoundment surveys conducted by Reed and Simmons (1972) found

depressed fish diversity and standing crop estimates in the North Anna River over 20 river miles

downstream of the mouth of Contrary Creek. Based on the reestablishment of mussel beds,

Reed and Simmons (1972) concluded that the river had recovered at the confluence of the

North and South Anna Rivers. The release from the dam of less than 40 cfs in most years

would not differ greatly from the current flow regime with two units operating. The results show

the discharge of less than 20 cfs would occur in the latter half of the calendar years in those

years experiencing drought conditions. Impacts to the river fishery are more likely to occur

when fish are spawning (i.e., in the spring and early summer). While the staff recognizes that

fish abundance in a river can vary from year to year, expected impacts from instream flow of

less than 20 cfs would not be destabilizing to fish habitat. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: The NRC, in section 5.3.2 of the SDEIS, concludes that the impact on the resource

is small during most years and moderate during drought years. Extensive hydrologic analysis

has been conducted which demonstrates significant changes in the flow patterns. Earlier DGIF

recommendations included a similar analysis of incremental habitat changes as impacted by

changes in flow. Without that analysis, any conclusion of "small to moderate impacts" is not

substantiated. (SW-0017 55)

Response: The staff assumes the commenter is expressing concern about the flow regime in

the North Anna River that may be adversely affected by Unit 3 operation. The results of the

staff simulations indicate that flow less than 40 cfs but more than 20 cfs would occur in the latter

half of the calendar year. Many fish species typically found in downstream locations spawn

during the spring and early summer when low flows are unlikely. Thus flow reductions are likely

only at times that such reductions would have only minimal impacts on fish habitat. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Several problems exist with this approach [in estimating fish loss] and these need

to be addressed. Lakes undergo eutrophication with age and that is occurring at Lake Anna as

the watershed becomes more fully developed. As that occurs, the biomass of fish increases. 

The current biomass is undoubtedly higher than twenty years ago when the original

entrainment/impingement analysis was conducted. The report uses cove rotenone data but

does not account for spatial and temporal variation within that data. Within large reservoirs,

biomass typically declines downstream through a trophic gradient. That is apparent from our

routine sampling as well as historic rotenone data. The impacts of entrainment and
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impingement may be even more spatially and numerically significant in the lower lake where the

numbers of fish are less than above the Rt. 208 bridge. (DW-0439 37) (SW-0017 38)

Response: The NRC staff recognizes that fish biomass in reservoirs can change over time. In

the case of Lake Anna, the reservoir was filled by December 1972. Impingement and

entrainment studies were conducted from 1978 to 1983 (VEPCo 1986). The staff included the

methods used to describe potential impacts to fish in Lake Anna in the EIS. The potential

operational impacts are discussed in Section 5.4.2. The methods used to describe potential

impacts to fish in Lake Anna from construction and operation of the proposed new units are

discussed in Sections 4.4.2 and 5.4.2, respectively. These methods are accepted as

scientifically sound and provide a reasonable assessment of impact. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: Suggest that this DEIS statement reflect that Virginia Power biologists have

gathered additional data on the abundance and distribution of black bass species in the lower

North Anna River via direct observation techniques. [page 2-41, line 31] (DW-0423 12)

Response: In response to this comment, the staff has included additional information on the

Virginia Power studies of the bass species in the North Anna River. This information appears in

Section 5.4.2.6 of the EIS.

Comment: We have concerns with fishery management. The Department of Game and Inland

Fisheries (DGIF) has found that the fish will continue to be adversely affected even after the

changes to the 3rd reactor have been made. (ST-0014 4) (SE-0022 8)

Comment: The SDEIS should investigate the existing and potential impacts of the proposed

project to the trophic condition of Lake Anna. High temperature and low DO along with high

nutrients can cause algal blooms in the lake. Algal blooms are known to accelerate lake

eutrophication and can cause human and animal health effects. (SE-0030 4)

Response: The proposed wet and dry cooling system for Unit 3 would not detectably raise the

average temperature of Lake Anna. NAPS Units 1 and 2 do not now contribute to nutrient

loading that is commonly associated with eutrophication of lakes. Nonpoint pollution associated

with urban development is the most likely contributor to nutrient loading. Accordingly, no

changes were made to this EIS as a result of these comments.

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the

ESP]...Impact to wildlife, fish, and endangered species...as a result of increased water

temperatures, reduced water flow, increased drought cycles and possible loss of food supply. 

(ST-0014 10) (SE-0022 19)
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NUREG-1811, Volume II 3-136 December 2006

Response: The impacts to wildlife, fish, and endangered species from the construction and

operation of the propose Units 3 and 4 are evaluated in Sections 4.4 and 5.4 of this EIS. The

use of a closed-cycle, combination wet and dry cooling system would substantially reduce

impingement and entrainment losses. Accordingly, no changes were made to this EIS as a

result of this comment.

3.4.2.5 Impacts on Striped Bass

Comment: I learned that the Department of Game and Inland Fisheries introduced striped bass

to Lake Anna, and they have to restock 100 to 2000 striped bass every year at considerable

expense because the creeks and river that feed the lake just aren’t deep enough or fast enough

for spawning runs. You see, without spawning runs, a self-sustained striped bass population

just isn’t possible regardless of lake temperature. What’s interesting though is that Public

Citizen, a government watchdog group, isn’t blowing the whistle on the state government for

supporting an artificial striped bass population. Instead they filed a legal contention that

Dominion will make the lake less comfortable for the striped bass that the state dumps into the

lake every year. (DT-0031 1)

Comment: I agree with your conclusions pertaining to the impact upon the striped-bass in the

lake. This is a stocked fish that cannot currently procreate in Lake Anna. If it is discovered that

there is an impact upon their population, more may be stocked. Currently, approximately

200,000 fish are stocked in the lake each year; however, in the past that number has at times

been almost 700,000 in one year so there is definite wiggle room in that area. And if there is

still an impact after that, recreational fishermen still have several species of fish to choose from

that won’t be impacted by the change in water temperature. The recreational fishing industry on

the lake will only be minimally impacted, if at all. (DW-1148 6)

Comment: What troubles me is that the NRC is even allowing the Striped Bass contention.

Simply put: Dominion built and sized Lake Anna as a waste heat treatment facility for four

nuclear units. In 1973, the Virginia Department of Game and Inland Fisheries decided to bring

Striped Bass to Lake Anna. This decision had long-term implications for the state, since the

river and streams that feed Lake Anna are not deep enough, long enough, and fast enough for

spawning runs. Without spawning runs, a self-sustaining Striped Bass population is not

possible in Lake Anna. The Virginia Department of Game and Inland Fisheries (VDGIF) must

stock 100,000 - 200,000 Striped Bass annually to support a “put, grow, and take” strategy. 

(DW-1149 2)

Response: These comments were received based on the evaluation in the Draft EIS on a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a substantially

lower discharge temperature and be expected to have a negligible effect on striped bass. 

Accordingly, no changes were made to this EIS as a result of these comments.
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 December 2006 3-137 NUREG-1811, Volume II

Comment: Experience has also shown that even extreme circumstances (e.g., an extended

drought) do not eliminate striped bass habitat in the upper lake and mid-lake areas. No striped

bass die-offs have been observed in any portion of Lake Anna. Striped bass restricted to a

narrow layer of water around the thermocline or to thermal refuges may not be able to move

freely and feed normally; thus they may be forced to live on stored energy reserves. As a

consequence, they may lose weight or show a decline in condition. This phenomenon has been

observed at a number of southeastern reservoirs where striped bass experience a late-summer

habitat “squeeze.” When surface waters cool in September and October, striped bass are able

to move freely in the water column again and resume normal feeding. Weight gain and an

improvement in their condition generally follow. (DW-1149 9)

Response: The commenter is quoting from the Draft EIS (page 5-30). Although dead striped

bass have been observed in Lake Anna in late summer, large-scale die-offs have not been

reported by VDGIF. Accordingly, no changes were made to this EIS as a result of these

comments.

Comment: By admitting the striped bass contention, the NRC is allowing the comfort of fish in

the state’s “striped bass experiment” to take priority over Dominion’s plans to use Lake Anna in

the manner for which it was originally built. The future of nuclear power in the U.S. energy mix

and the resultant reductions in greenhouse gas production is far more important than the

comfort of non-native striped bass in Lake Anna. (DW-1149 10)

Response: Pursuant to the Atomic Energy Act, the Atomic Safety and Licensing Board (ASLB)

is charged with resolving issues admitted as contentions as part of the hearing process. The

ASLB is established by the NRC as an independent review board. The ASLB dismissed the

contention on October 24, 2006 (NRC 2006).

Comment: Considerable discussion of striped bass is included in the assessment. Lake Anna

was created by Dominion as a cooling water source for power plants. Bass are not a native

species and are artificially introduced into the lake each year by state employees. Temperature

effects on the bass population is not a proper subject for consideration in an EIS, since the

artificial introduction of this species by a government agency is in fact a disturbance of the

natural environment. Any incompatibility of such an artificially introduced species with the

primary purpose of the body of water must be accounted for and managed by the agency

introducing the species, and cannot properly be considered as an impact of the power plant. 

(DW-0645 3)

Response: This comment on the striped bass fishery relates to the species as a non-native,

stocked fish. The staff disagrees with the statement that the striped bass is not a proper subject

for consideration in the EIS. Through the efforts of the Commonwealth of Virginia, the striped

bass has become part of the Lake Anna environment. NEPA requires the evaluation of the

action on the existing environment regardless of whether the species is native or introduced. 
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NUREG-1811, Volume II 3-138 December 2006

Nonetheless, because Dominion has changed its proposal for cooling Unit 3 to a closed-cycle,

combination wet and dry system; effects on the lake temperature and, consequently, on the

striped bass fishery are projected to be negligible. Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: The nomenclature of the Draft EIS on native vs. non-native species appears to

minimize the value of the striped bass fishery (Draft EIS, Section 2.7.2.1, pages 2-33 through

2-40) [and as stated in DGIF's February 15, 2005 comments on this subject]. Striped bass and

other anadromous fish are native to the York River drainage and the North Anna River, while

largemouth bass, bluegill, black crappie, walleye, and channel catfish are not. Nevertheless, all

of these species are important to the recreational fishery in the lake. (DW-0439 29)

(SW-0017 6)

Comment: The Department of Game and Inland Fisheries agrees with the descriptive

statements in the Draft EIS (page 5-30, lines 24-33). However, line 37 incorrectly states that

striped bass are not native to this watershed. The use of nomenclature surrounding native vs.

nonnative species appears to minimize the value of the striped bass fishery. This is incorrect.

Striped bass are, in fact, native to the York River drainage and downstream reaches of the

North Anna can be seasonally important for spawning and juvenile rearing. The lake population

is correctly acknowledged as being supported by stocking. In recognition of this fact, the

Department of Game and Inland Fisheries strives to stock Chesapeake strain striped bass in

the reservoir so as not to change the genetics of downstream populations. (DW-0439 40)

(SW-0017 48)

Response: The use of the term “non-native” properly describes the striped bass population in

Lake Anna and differentiates striped bass from native species. Non-native species, such as

largemouth bass, bluegill, crappie, walleye, and channel catfish, are basically from habitats

similar to Lake Anna and its tributaries, are reproducing populations, and have adapted to

reservoir conditions. The terms “native” or “non-native” are used as descriptive terms and do

not state or imply a value or worth to a particular species. The terms are commonly used in

FWS discussions of plant and animal populations. The terms are also used by the Virginia

Department of Game and Inland Fisheries, VDGIF. The use of such terminology does not refer

to the recreational interest in the species. 

Regarding striped bass in Lake Anna, the EIS does not state that “...striped bass are not native

to this watershed.” The EIS correctly states that “...the Lake Anna striped bass population is

not native to this portion of the watershed and does not reproduce naturally in the lake; the

striped bass fishery is dependent on annual stockings.”

There was no record of a striped bass fishery in the North Anna River above the Fall Line

(about 25 miles downstream of the Dam) before the North Anna dam was constructed. 

Dominion has monitored this reach of the North Anna River for over 30 years, and during that
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 December 2006 3-139 NUREG-1811, Volume II

time, has collected only a single striped bass. Because the Fall Line represents a barrier to

upstream migration, the Dominion staff concluded that this one-time collection was the result of

a fish passing over the North Anna dam. Accordingly, no changes were made to this EIS as a

result of these comments.

Comment: An extensive amount of temperature data from historic monitoring of the lake was

used to model thermal conditions at various locations in the lake. Despite that extensive data

set, no modeling of summer striped bass habitat was conducted to support statements that the

impacts would be small in normal years and moderate in drought years (Draft EIS, page 5-3 1,

lines 18-19). In combination with the elevated temperatures and increased frequency of

drought conditions (lowering to elevation 248) within the lake, the striped bass population could

be stressed every 2.6 years. Based on the information in the Draft EIS, it is inconclusive

whether the installation of a third unit would cause acute mortality from exacerbated summer

habitat squeeze. It is also inconclusive, however, that such mortality would not occur. At some

point, striped bass will begin to die as water quality declines (based primarily on higher water

temperatures and lower dissolved oxygen). (DW-0439 41) (SW-0017 49)

Comment: Since no modeling of summer habitat was conducted, it is unknown whether the

additive impacts of a third unit would allow reservoir conditions to reach this point, and the exact

point at which this will occur is unknown; but to discount the possibility is subjective. Even with

the elimination of Unit 4, the predicted maximum surface temperature increase at the dam of

3.6 degrees Fahrenheit could result in striped bass mortalities depending on the plume

configuration, inflow, and stratification pattern. Striped bass habitat modeling is essential in the

Final EIS to explain the potential of a new (third) unit and its impact on striped bass habitat. 

(DW-0439 42) (SW-0017 50)

Response: These comments were received based on the evaluation in the Draft EIS on a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a substantially

lower discharge temperature and flow rate and would be expected to have a negligible effect on

the striped bass. The staff has not concluded that mortality would not occur but rather that it is

unlikely. Striped bass utilization and avoidance of habitat is a function of water temperature,

dissolved oxygen concentrations, and other water quality parameters. There is a considerable

body of research that has determined that striped bass avoid habitats where water

temperatures, dissolved oxygen levels, and other water quality parameters are less than

optimal. Potentially lethal conditions are not expected to occur instantaneously and lake-wide. 

The staff has reviewed the potential conditions that are expected to occur in Lake Anna with the

revision to the proposed Unit 3 cooling system. Striped bass are expected to avoid less than

optimal conditions that would occur during drought conditions. Additional modeling is unlikely to

provide a more accurate assessment of potential impacts to the Lake Anna striped bass fishery
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NUREG-1811, Volume II 3-140 December 2006

because current models do not have the fidelity to accurately predict impact on the fishery with

the data that are available. Furthermore, the additional modeling is unlikely to identify mitigative

measures that could reduce impact. Accordingly, no changes were made to this EIS as a result

of these comments.

Comment: The Sierra Club position is that currently, two reactors operating at Lake Anna

draws 1.9 million gallons of water per minute from the waters of the South Anna, and discharges

hot water back. Hot water has a negative affect on the striped bass, one of the most thermallysensitive fish species. This statement is supported by VDEQ statement of “a tenuous situation”

for the health of the striped bass population. We fear that the maximum daily surface

temperature would increase near the dam and intake pipe. According to the Virginia

Department of Game and Inland Fisheries, “It is likely that even a small increase in reservoir

water temperature would have a dramatic effect-further reducing the already limited habitat and

perhaps jeopardizing the entire striped bass fishery.” We cannot afford this impact on our

populations of sport fishery and recreation that Sierrans around the state enjoy. (DW-0857 2)

Comment: The addition of another once-through reactor will increase the temperature of Lake

Anna, which will affect the striped bass, one of the most thermally-sensitive fish species in the

lake. Striped bass prefer temperatures between 65 and 70(F and avoid temperatures above

77-81(F (DEIS, page 5-27, Table 5-7). According to Dominion’s models, the “maximum daily

surface temperature” near Thurman Island would reach 95.1(F (DEIS, page 5-28, line 4). The

“maximum daily surface temperature,” however, is calculated as an average of the upper 28 feet

of the water column. This ignores the temperature gradient, especially in the lower parts of the

first 28 feet water column where the striped bass reside. (DW-0437 13)

Comment: [T]he conclusory statements in the DEIS regarding the availability of striped bass

habitat and the practicability of mitigation measures render the discussion of impact upon the

Lake Anna striped bass population inadequate. (DW-1122 3)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a substantially

lower discharge temperature and flow rate and would be expected to have a negligible effect on

lake temperature and the striped bass. The Lake Anna striped bass population is a “put-growand-take” fishery created using stocked fish that did not historically occur in or migrate through

the North Anna River in the vicinity of Lake Anna before the North Anna Dam was completed

and Lake Anna was impounded. Because the proposed Unit 3 cooling system would be

expected to increase overall lake temperature by only 0.1(F, thermal impacts beyond those that

currently exist from the operation of Units 1 and 2 are unlikely. During the warmer months or

extended drought events, the staff have concluded that suitable refuge for striped bass would

continue to exist in Lake Anna. Accordingly, no changes were made to this EIS as a result of

these comments.
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 December 2006 3-141 NUREG-1811, Volume II

Comment: Striped bass are also sensitive the level of dissolved oxygen in the water, but no

dissolved oxygen data is presented in the Draft EIS. The selection of temperature and

dissolved oxygen is a balancing act for striped bass. In order to make a real assessment of the

impact of additional reactors on the striped bass, vertical profiles of temperature and dissolved

oxygen within the upper 28 feet of the water column and need to be provided in the Final EIS. 

(DW-0437 14)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and its elevated discharge temperatures relative to the

existing discharge from Units 1 and 2. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a substantially

lower discharge temperature and would be expected to have a negligible effect on the striped

bass. Water temperature data recorded at several locations and depths in Lake Anna have

shown that a thermally stratified condition exists in the lake during several months each year. 

This thermal stratum (i.e., thermocline) typically develops in Lake Anna in the spring months. 

However, the thermocline does not remain at a constant depth and deepen during the summer

because of surface heating from the atmosphere and NAPS operations. In the late fall, mixing

processes deepen the thermocline to the reservoir bottom and the lake becomes thermally

homogeneous.

During the summer and early fall, dissolved oxygen concentrations below the thermocline are

often too low to support striped bass. Data on dissolved oxygen concentrations in Lake Anna

are presented in the NAPS Clean Water Act Section 316(a) report and annual environmental

reports. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The following comment in the Draft EIS regarding droughts, "In such

circumstances, mitigation to reduce the impact could be accomplished by stocking more fish,

stocking larger fish, or managing the fishery to provide more catch opportunities of large fish," is

incorrect and not a scientifically recognized fishery management solution, according to the

Department of Game and Inland Fisheries. Such a comment does not recognize the biological

and physical factors necessary for a successful striped bass population. (DW-0439 43)

(SW-0017 60)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a substantially

lower discharge temperature and would be expected to have a negligible effect on the striped

bass. The striped bass is not endemic to this reach of the drainage and was placed in an

environment where it did not exist prior to 1970s. Even without current NAPS operations, the

habitat is sub-optimal. Management of the fishery through annual stocking is necessary to

maintain the fishery. Fishery biologists recognize the biological and physical factors necessary

for a successful striped bass fishery and use this information to effectively manage this species. 
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NUREG-1811, Volume II 3-142 December 2006

This approach represents a “scientifically recognized fishery management solution.” 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: If adult striped bass are forced to move to marginal habitat in the northern part of

the lake, they could be prevented from feeding normally. Spatial segregation from their forage

base and increased metabolic rates could cause loss of condition or starvation. The NRC Staff

concludes that the problem can be mitigated by stocking more fish or stocking larger fish. But

larger fish are known to be affected by increased temperature, and are often the first to suffer

summer “die-offs.” While more fish can be stocked, the potential for large fish greater than

10 lbs (or maybe even fish greater than 6 lbs) is greatly reduced with increased temperatures. 

It would also be very expensive to significantly increase the annual stock, and Virginia

taxpayers should not be held financially responsible. A cost analysis of the stocking proposals

should be included in the Final EIS. (DW-0437 16)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a substantially

lower discharge temperature and would be expected to have a negligible effect on the striped

bass. The staff stated in Section 5.4.2.5 that the condition of the fish could be affected if the

fish are forced to move upstream during summer. Given the change in the Unit 3 cooling

system, a cost analysis of maintaining a sub-optimal fishery in Lake Anna through stocking is

outside the scope of this EIS and would be more appropriate for the VDGIF. Accordingly, no

changes were made to the EIS as a result of this comment.

Comment: I am concerned that a drop in water level will adversely affect fish populations,

including striped bass as well as their striped bass eggs and larvae. Extra stocking is not an

attractive option as it doesn’t consider the unsuitability of a warmer lake for the fish population,

and only slightly mitigates the effects of a negative environmental change. (DW-0617 3)

Response: The potential impacts of lake level changes are discussed in the EIS

(Sections 5.3.2 and 5.4.1.3) and the ER (Section 5.2.2.2). The results presented quantify the

impact on lake levels that would occur with the proposed Unit 3 closed-cycle, combination wet

and dry cooling system. Striped bass are not known to spawn in Lake Anna or the tributaries to

the lake. Therefore, there cannot be any adverse impacts to striped bass eggs or larvae. 

Striped bass are maintained in the reservoir through annual stocking of fingerlings. The

maximum annual drawdown in most years would not differ greatly from the current operation of

the existing units. The results show that the minimum lake levels occur in the latter half of the

calendar year. During the 25 years (1978 to 2003) evaluated by the staff in its water balance,

differences in water levels were less than 3 in. between the base case and the ESP case for

69 percent of the period of the simulation. The timing of predicted differences is expected

during the times of the year when fish are less likely to be impacted by lower water levels. 

Impacts for species other than the striped bass are more likely to occur when fish are spawning
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(i.e., in the spring and early summer). Expected impacts from lake level changes on fish habitat

would not destabilize the fish habitat. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: Although the NRC Staff conclude that the striped bass will be forced “up-lake into

areas that provide suitable habitat” for “a three-to-four month period in summer and early fall”

(DEIS, page 5-31, line 3), no data was presented that shows that suitable habitat exists in the

other areas of the lake. This data should be included in the Final EIS. (DW-0437 15)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and its elevated discharge temperatures relative to the

existing discharge from Units 1 and 2 or the proposed Unit 3. The proposed cooling system has

since been changed to a closed-cycle, combination wet and dry cooling system, which would

have a substantially lower discharge temperature and would be expected to have a negligible

effect on the striped bass. Given the change in the proposed Unit 3 cooling system, it is

unlikely, that even extreme circumstances (e.g., an extended drought) would completely

eliminate striped bass habitat in the upper- and mid-lake areas. Striped bass mortalities have

been observed in Lake Anna during two-unit operation and have been reported in the WHTF. 

These are likely related to elevated water temperatures. Striped bass restricted to a narrow

layer of water around the thermocline or to thermal refuges may not be able to move freely and

feed normally; thus, they may be forced to live on stored energy reserves for several months. 

As a consequence, they may lose weight or show a decline in physical condition. This

phenomenon has been observed at a number of southeastern reservoirs where striped bass

experience a late-summer habitat “squeeze.” When surface waters cool in September and

October, striped bass are again able to move freely in the water column and resume normal

feeding. Weight gain and an improvement in their physical condition generally follow. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: [T]he DEIS concludes that the heat stress impact on striped bass would be small

during cooler months and non-drought years, and would be only moderate during the summer

months and drought years because “suitable habitat would continue to exist in Lake Anna”

during these times. DEIS, p. 5-3 1. The DEIS provides no evidentiary support for this

conclusory assertion. (DW-1122 10)

Comment: Increased lake temperature threatens the striped bass population in the lake. 

Lower water levels would adversely impact recreational activities in the lake. Yet, any analysis

to determine “operational practices and procedures” that might minimize adverse impacts” is

deferred until the COL application. (DW-0589 6)

Comment: [T]he DEIS fails to include any support for its determination that mitigation

measures could be implemented that would reduce the impact on the striped bass. The DEIS

specifically suggests that more and larger fish could be stocked, and that the fishery could be
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NUREG-1811, Volume II 3-144 December 2006

managed to provide more catch opportunities of larger fish. Adding more large fish to the lake

would seem to only increase competition for any remaining viable large-fish habitat in the lake. 

The Final EIS should include an explanation as to the practicability of the proposed mitigation

measures. (DW-1122 11)

Comment: [T]he ecological balance of lake could be significantly affected if the hybrid [sterile

white bass/striped bass] manages to reproduce, a phenomenon that has reportedly occurred

when other “sterile” species have been added to an ecosystem. Since this potential mitigation

measure was proposed after the DEIS was published, it has not yet been evaluated. If there is

any realistic possibility that this strategy might be employed, its potential impacts and effects on

the ecosystem need to be explored in a supplement to the DEIS that is circulated for public

review and comment. (DW-1122 13)

Comment: [I]n a significant new mitigation proposal, Dominion has recently offered to provide

financial assistance “to aid in the development and stocking of a more thermally-tolerant

species (such as a sterile white bass/striped bass hybrid)” in response to VDGIF concerns

regarding the impact of an additional unit on the lake’s striped bass population... The addition of

a white bass/striped bass hybrid to Lake Anna could further decrease the amount of suitable

habitat and food for the striped bass. (DW-1122 12)

Response: These comments were based on the evaluation in the Draft EIS of a once-through

cooling system for Unit 3 and its elevated discharge temperatures relative to the existing

discharge from Units 1 and 2 or the proposed Unit 3. The proposed cooling system has since

been changed to a closed-cycle, combination wet and dry cooling system, which would have a

substantially lower discharge temperature and flow rate and would be expected to have a

negligible effect on the striped bass. Previously, in an April 12, 2005, response to an NRC staff

request for additional information, Dominion transmitted to the NRC a letter to the VDGIF in

which Dominion proposed to assist with development and stocking of a suitable, more thermally

tolerant hybrid species. However, because of the change in the proposed cooling system and

its negligible effect on lake temperatures, Dominion need not consider implementing this plan

Accordingly, no changes were made to the EIS as a result of these comments.

3.4.2.6 Downstream Impacts

Comment: [A]dditional data and analysis...is needed to ensure that reduced downstream flows

do not harm striped bass and other fish. (SE-0046 2)

Response: This comment is nonspecific. Section 5.4.2.6 in this EIS discusses the potential

impacts of downstream flows on striped bass and other fish. Accordingly, no changes were

made to this EIS as a result of this comment.
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 December 2006 3-145 NUREG-1811, Volume II

Comment: According to the Department of Game and Inland Fisheries, the downstream

impacts to fisheries resources were ignored in the Draft EIS in spite of the increased frequency

of low flows that a third water-cooled unit would produce. Currently, (with two units in the

regulated “base scenario”), 67 weeks of drought conditions (20 cubic feet per second ("cfs") or

less) out of a 26-year period would be expected. Given the addition of a third unit, the expected

drought frequency would rise to 150 weeks using the once-through cooling method. The length

of time the drought frequency would increase using the closed-cycle cooling method would

depend on factors such as the frequency of triggering the Maximum Water Conservation Mode

and the design used. (DW-0439 44) (SW-0017 7) (SW-0017 51)

Comment: According to the Virginia Department of Environmental Quality, another reactor will

mean “nearly perennial condition of severe degradation” every fall. Dominion’s own model

shows that the minimum flow (20 cfs) is expected to occur 10 years out of the 25-year modeling

period with a third reactor. With the two existing units, minimum flow (20 cfs) is predicted in

only 3 years out of the 25-year modeling period. This will have a serious impact on the

downstream aquatic life, as well as increase conflicts over water use by downstream counties in

the future. Yet, there is no discussion of how the increased occurrence of minimum discharge

will affect on living organisms downstream. (DW-0437 21)

Comment: Dominion’s models predict that the flow from North Anna Dam will be reduced to

20 cfs for 11.8% of the time, compared to 5.3% of the time currently. The impact of increasing

periods of extreme low-flow at 20 cfs—not only increased periods of flow at 40 cfs—from the

dam on downstream habitat should be fully evaluated in the Final EIS. (DW-0437 26)

Comment: The DEIS fails to undertake a serious analysis of the impacts on downstream

aquatic habitat of the increased durations of low flow... NRC’s regulations make clear that

merely suggesting that Dominion’s compliance with the permitting scheme of the CWA will

protect aquatic resources downstream is insufficient. The Final EIS must therefore incorporate

a more thorough analysis of the impact of increased durations of reduced flow on downstream

aquatic habitat. (DW-1122 6)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system. The percentage of time that flow

would be reduced to 20 cfs was evaluated considering the system thermal discharge and

evaporative water loss associated with the proposed Unit 3 cooling system. The staff has

included additional information on the North Anna River fishery downstream of the dam in

Section 5.4.2.6 of the EIS. The release from the dam of less than 40 cfs in most years would

not differ greatly from the current flow regime with two units operating. The results indicate that

the discharge of less than 20 cfs would occur in the latter half of the calendar years in those
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NUREG-1811, Volume II 3-146 December 2006

years during drought conditions. Impacts to the river fishery are more likely to occur when fish

are spawning (i.e., in the spring and early summer). Expected impacts from reduced in-stream

flow during other periods of the year would not destabilize the fish habitat.

Aquatic organisms inhabiting small Piedmont streams, such as the North Anna River, are

pre-adapted to tolerate reduced in-stream flow rates during a portion of the year. The addition

of an additional unit would reduce the variability of downstream flow. The staff determined that

the downstream habitat would not be eliminated or diminished to the point that the aquatic

community would be destabilized as a result of low-flow conditions. 

Comment: What thorough studies have been conducted on the plant and animal ecology both

at the lake and downstream on the Pamunkey River and further downstream to the York River

and the Chesapeake Bay, all impaired water systems, and with the bay at 27 percent of its

historical percentage? (DT-0038 8)

Comment: Decreases in the downstream release of water will adversely affect the wildlife of

the streams in the York River watershed, including the North Anna and the Potomac Rivers. 

This will be particularly critical during periods of drought. (DT-0047 3)

Comment: [A] full evaluation of the potential impacts of reduced or variable discharge on the

life history stages of the native Pamunkey River striped bass population is warranted, especially

due to the fact that the Pamunkey River population is one of the healthiest populations in the

Chesapeake Bay ecosystem and is being used for propagation for Chesapeake Bay restoration

efforts. The impacts of extended periods of low-flow downstream should be fully analyzed in

the Final EIS as an integral part of determining site suitability, rather than simply punted to the

Commonwealth of Virginia to address after the ESP decision is made. (DW-0437 22)

Comment: DGIF has reviewed the impacts of stream flow on American shad juvenile

production in the Pamunkey River. The data were presented to Dominion and the NRC in

separate meetings in the spring of 2006. ...the best juvenile shad survival occurred during

wetter June-August years (those with flows at the 80th percentile). Lake Anna is about

one-third (1/3) of the drainage area of the Pamunkey River at the gauge station near Hanover,

and is an important contributor to that river's flow. Flow losses within Lake Anna due to

evaporation can have a significant impact upon downstream shad resources. The NRC

analysis would predict a much more significant impact on potential summer shad habitat than

the Dominion analysis. (SW-0017 46)

Comment: The SDEIS concludes 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. (SE-0045 29)
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Response: In response to these comments, the staff has included additional discussion of the

North Anna River and its aquatic life downstream of the dam in Sections 2.7.2.3 and 5.4.2.6 of

the EIS. The potential changes in discharges from the dam are not expected to adversely

impact the fishery in the Pamunkey River, which is formed at the confluence of the North and

South Anna Rivers 27 miles downstream of the dam. Most species of fish inhabiting coastal

Piedmont streams are preadapted to tolerate low flow conditions. Staff simulations of releases

from the North Anna Dam for Unit 3 operation indicate that during non-drought years, flows of

less than 40 cfs but more than 20 cfs could occur in the latter half of the calendar year. Fish are

most vulnerable to low-flow conditions during spawning, and most species (including striped

bass) inhabiting the North Anna River spawn in the spring and early summer. The staff

concludes that reduced flows resulting from the operation of Unit 3 are not likely to destabilize

the fishery downstream of the Lake Anna Dam. The principal tributaries draining into the

Chesapeake Bay have a combined annual average flow of 72,086 cfs. The changes in the flow

in the North Anna River as a result of the operation of Unit 3 would be less than 40 cfs. The

staff concluded that this 0.06 percent change in annual average inflow rate to Chesapeake Bay

would be insignificant. The Potomac River, an upstream tributary to Chesapeake Bay, is not

part of the York River drainage.

Comment: The Department of Game and Inland Fisheries remains concerned regarding the

increased evaporation from Lake Anna and its impacts upon downstream hydrology, attributable

to the addition of Unit 3. The increased frequency of flows below 40 cubic feet per second (cfs)

will, if allowed, cause the downstream hydrology to change to a drier condition than would occur

naturally, resulting in lower flows affecting downstream resources in the Pamunkey River, to

which the North Anna River flows. The required release flow of 40 cfs is 11.6% of mean annual

flow. Normal summer flows in a stream the size of the North Anna River would be from 70 to

100 cfs or 20-30% of mean annual flow. Reduced flows would result in reduced summer habitat

for resident Lake species as well as downstream migratory species. An analysis of Dominion's

long-term North Anna River monitoring data demonstrated that the fish community requires a

diverse flow pattern, with different species doing best in wet years. This is similar to study

results from the James River and the North Fork of the Shenandoah River. (SW-0017 43)

Response. Fish in Coastal Piedmont streams are preadapted to surviving large fluxuations in

annual flow. Because the minimum flow rate from the dam would not decrease, there would be

no additional loss of habitat. However, the staff recognizes that the duration of reduced flows

would likely be extended as a result of the operation of Unit 3. The Commonwealth of Virginia

has the authority to regulate Dominion’s water use and would specify release schedules at the

North Anna Dam, as appropriate, to protect the downstream environment. The staff has

included additional discussion of the North Anna River and its aquatic life downstream of the

dam in Sections 2.7.2.3 and 5.4.2.6 of this EIS. 

Comment: How can a 20% change (52% from 44%) in the low flow conditions not have

noticeable downstream impacts [on riparian vegetation]? (DW-0438 144)
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Response: Health and diversity of riparian vegetation is primarily influenced by extreme flow

regimes (floods) and not by low-flow conditions. In the coastal Piedmont, there is sufficient

moisture to maintain the riparian vegetation. Therefore, reductions in North Anna River flow

resulting from the operation of Unit 3 is unlikely to adversely affect downstream riparian

vegetation. The text in Section 5.4.1.4 of this EIS has been modified to explain the staff’s

assessment.

Comment: Impacts of those [generating] facilities upon the lake temperature, particularly in the

summer months, can affect the downstream fishery. (SW-0017 14)

Response: Because a closed-cycle, combination wet and dry cooling system is now proposed

for Unit 3, the increase in existing lake temperature would be negligible. Thus, thermal impacts

to Lake Anna and the North Anna River below the dam would not be increased as a result of the

operation of Unit 3. Accordingly, no changes were made to this EIS as a result of this comment.

3.4.3 Threatened and Endangered Species

Comment: Suggest that this DEIS statement reflect that the only listed aquatic species likely to

be present in the vicinity of the North Anna ESP site is the dwarf wedgemussel, that none were

collected in pre-impoundment surveys of the North Anna River, and none have been collected

in more recent years during routine monitoring surveys. [page 2-42, line22] (DW-0423 13)

Comment: Based on a review of the Virginia Department of Conservation and Recreation

website, two of the mussel species listed in the DEIS (Fusconaia masoni and Pleurobema

collina) are found in the James River drainage, but not the York River drainage (which includes

the North Anna River). It appears that the DEIS includes occurrences of protected/rare mussels

in counties (such as Albemarle, Fluvanna, and Goochland) that are within 25 or 50 miles of

NAPS, but do not adjoin Lake Anna or the North Anna River. Although there are

inconsistencies in the treatment of protected/rare mussels, the conclusions of the ER and the

DEIS are the same: one listed mussel species occurs in the counties of interest (Caroline,

Hanover, Louisa, Orange, and Spotsylvania), and this population would not be affected.

Comment: According to DCR [Department of Conservation and Recreation], natural heritage

resources have been documented in the project area. ...Laura's Clubtail, an odonate (Odonata,

i.e., dragonflies and damselflies), has been historically documented in Lake Anna. This insect

species is not listed as endangered or threatened. ...Because of their aquatic lifestyle and

limited mobility, the larvae are particularly vulnerable to siltation and to shoreline disturbances

that cause the loss of shoreline vegetation. Larvae are also sensitive to alterations resulting in

poor water quality, aquatic substrate changes, and thermal fluctuations. (SW-0017 70)

Response: This species was not considered in the EIS for the following reasons: (1) although

acknowledged as rare, it is not considered to be a species of concern by either VDCR or the
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 December 2006 3-149 NUREG-1811, Volume II

FWS, (2) the VDGIF does not list it as occurring in the area of concern, and (3) according to

NatureServe (2006), the closest occurrence is in a county at least 50 miles from the site. If

Dominion is issued an ESP and applies for a COL, then the staff would contact appropriate

State and Federal agencies at the COL review stage, and any significant new information about

important species would be obtained and evaluated at that time. Accordingly, no changes were

made to this EIS as a result of these comments.

Comment: [T]he SDEIS makes reference to the shortnosed sturgeon as being listed as

endangered by the National Marine Fisheries Service and by Virginia. It also appears on the

Virginia Department of Cultural Resources List of "Extinct and Extirpated Animals of Virginia."

(SDEIS, page 8-29, section 8.5.4). There is no "Virginia Department of Cultural Resources." 

Perhaps the reference is to the Department of Historic Resources, which does not have

responsibility for endangered species. (SW-0017 59)

Response: The correct reference should have been to the Virginia Department of

Conservation and Recreation, which maintains a list of rare animals. This reference has been

corrected in Section 8.5.4.

Comment: Suggest that this DEIS wording should reflect that none of the Federally or

State-listed species have been observed or collected in local streams or the North Anna River.

[page 2-42, line 29] (DW-0423 14)

Response: Section 2.7.2.4 of the final EIS was changed to make it clear that none of the

Federally or State-listed species has been observed or collected in local streams or the North

Anna River.

3.4.4 Wetlands 

Comment: Since Section 4.3.1 line 9 states that “Dominion did not provide information on

wetlands in its ER” how can the DEIS conclude that the impacts of hydrological alterations

would be SMALL? The text discusses numerous possible impacts. (DW-0438 92)

Comment: The Draft EIS/SDEIS does not provide information on the delineation (in acres) or

the type of wetlands impacted by the construction and operation of the proposed facility, nor

does it include any mitigation for the loss of wetlands. (DW-0422 5) (SE-0030 6)

Comment: Existing wetlands, streams, and woodlands on the North Anna Power Station

(NAPS) site may be adversely affected by construction activities for the proposed Units 3 and 4

(draft EIS, page 4-2, lines 20-23). (DW-0589 9)

Comment: Existing wetlands, streams, and woodlands on the North Anna site may be

adversely affected by construction activities for the proposed Units 3 and 4 (DEIS, page 4-2,
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NUREG-1811, Volume II 3-150 December 2006

lines 20-23). Dominion’s ER for the North Anna ESP observes, “Any work that has the potential

to impact a wetland would be performed in accordance with the applicable regulatory requirements.” (ER, Section 4.1.1.6.2) This is repeated almost word-for-word in the draft EIS at

Section 4.1.1. The ER concludes, without supporting evidence, “Therefore, no

construction-related impacts on water courses or wetlands would result” (ER, Part 3,

Section 4.1.1.6.2). Does it necessarily follow that “applicable regulatory requirements” will

preclude any negative impacts on wetlands? A more trenchant analysis of the question is

deserved in the Final EIS, especially since Dominion provided no information on wetlands in its

ER (DEIS, Section 4.3.1, line 9). Please explain the mitigation measures that will be employed

to achieve this end. (DW-0437 40)

Comment: Section 4.3.1 line 9 states that “Dominion did not provide information on wetlands in

its ER.” That does not relieve the NRC as lead agency from its responsibility to collect, analyze,

and report information on wetlands in the DEIS. This information must be included since Page

2-27 line 29 mentions that there are wetlands in the vicinity. (DW-0438 93)

Comment: The Draft EIS states, “a few small wetlands and two intermittent streams exist on

the North Anna ESP site” (page 4-7, Section 4.4.1), but no wetland delineation of the area has

been accomplished. The Draft EIS also states, in several different places, that avoidance and

minimization of wetland impacts will be practiced to the maximum extent practicable. Given the

above information, however, DEQ cannot determine whether project activities would adversely

affect wetland or stream areas subject to DEQ water permitting jurisdiction. For this reason,

DEQ recommends that the applicant submit the following: 1) a National Wetland Inventory

(NWI) map identifying the project area; 2) photographs of the intermittent streams; 3) a

confirmation of the wetlands delineation by the Army Corps of Engineers; and 4) any other

information pertaining to the location of wetlands or streams in or near the project area. This

information would be necessary for any Virginia Water Protection Permit application, but it is

also vital for an informed decision on federal consistency and on the environmental impacts of

the proposed project. (DW-0439 7) (SW-0017 41)

Comment: Page 2-27 line 29 discusses wetlands associated with streams and one within the

ESP site. What wetland preservation efforts will be done? (DW-0438 45)

Response: The staff examined National Wetland Inventory (NWI) maps of the North Anna ESP

site while preparing the Draft EIS and inspected the potential wetland areas at the North Anna

ESP site during a site visit in December 2003. This site inspection and the NWI maps were part

of the basis for the staff’s conclusions in the Draft EIS regarding impacts to wetlands at the

North Anna ESP site. 

Since publication of the Draft EIS, Dominion has completed a wetland delineation that identified

6.68 acres of wetlands in the North Anna ESP area. The delineation also identified

approximately 5500 linear feet of streams that cover an area of approximately 0.46 acres, and
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approximately 2.49 acres of open water within a beaver pond at the western edge of the North

Anna ESP area near the end of an unnamed arm of Lake Anna. The U.S. Army Corps of

Engineers (ACE) verified this delineation and indicated that a permit from the ACE or VDEQ

may be required prior to any mechanized land clearing, or any filling or excavation that could

disturbed these wetlands or streams. However, neither the ACE nor VDEQ can determine the

type of permit(s) required (e.g. CWA Section 404 permit, Virginia Water Protection Permit, or

NPDES construction site storm water permit) or the limitations or requirements, if any, would be

attached to the permit(s) until a more detailed site design and development plan is available. 

When other State or Federal agencies have regulatory jurisdiction over a resource such as

wetlands, those agencies have the authority to impose restrictions, requirements, or mitigation

measures. Therefore, the staff need not set standards for the specific protection and mitigation

measures that will be taken. However, Dominion has stated in the ER that watercourses and

wetlands would be avoided to the extent practicable during construction, and that it would

adhere to any ACE or VDEQ permit conditions or requirements. 

Approximately 128 acres of upland habitat would be permanently disturbed; much of this is pine

or pine-hardwood mixed woodlands. Land clearing would be performed using best

management practices to avoid impacts such as run-off and soil loss.

With respect to the comment regarding withdrawal of cooling water from, and thermal

discharges into, the WHTF, no response is necessary because Dominion has since revised its

application to eliminate once-through cooling for proposed Unit 3, in favor of a close-cycle,

combination wet and dry system, which would have an insignificant effect on the water

temperature within the WHTF, Lake Anna, and the North Anna River.

The text in Sections 2.7.1 and 4.4.1 was changed to include the wetland delineations performed

by Dominion and the ACE verification of the delineation.

Comment: I have a concern with the wetlands that were once surrounding the area where I

currently live. (DT-0057 2)

Response: The staff evaluated the potential impacts of station operation on wetlands along the

shoreline and upper reaches of Lake Anna based on its conservative assessment as described

in Appendix K of the EIS. This assessment estimated that the difference between the lake level

with and without the proposed Unit 3 would be less than 3 in. approximately 69 percent of the

time, less than 6 in. approximately 85 percent of the time, and less than 1 ft approximately

94 percent of the time. All of the days between 1978 and 2003 when the difference in lake level

with and without the proposed Unit 3 was predicted to be greater than 1 ft would have occurred

during the two major drought periods of 1980 to 1981 and 2001 to 2002. 

Differences in lake level that fluctuate between 0 and 6 in. are likely to have no discernable

effect on shoreline vegetation or wetlands. During the occasional periods when there are
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NUREG-1811, Volume II 3-152 December 2006

greater differences in the lake level, there likely would be noticeable temporary changes in the

shoreline and wetland vegetation. Upper areas may dry out, and lower, normally inundated

areas may develop stands of wetland vegetation over time. However, the increased drawdown

is expected to be temporary, and even if the additional drawdown lasts for a year or more, any

observable changes would not be detectable within a relatively short time after the water level

returns to normal. Riparian and wetland vegetation is adapted to survive in periodic drought

conditions without detectable long-term effects. 

Although no changes were made to this EIS as a result of this comment, the text in

Section 5.4.1.4 was revised to reflect the change in the proposed cooling system for Unit 3.

Comment: Existing wetlands, streams, and woodlands on the North Anna Power Station

(NAPS) site may be adversely affected by construction activities for the proposed Units 3 and 4

(draft EIS, page 4-2, lines 20-23) and possibly by potential increases in the maximum Lake

Level and decreases in the minimum Lake Level. (SE-0038 9)

Response: Dominion has stated in the ER that watercourses and wetlands would be avoided

to the extent practicable during construction, and that it would adhere to any ACE or VDEQ

permit conditions or requirements. Although no changes were made to this EIS as a result of

this comment, the text in Sections 2.7.1 and 4.4.1 was revised to include the wetland

delineations performed by Dominion and the ACE verification of the delineation.

3.4.5 Other Comments

Comment: Ameiurus catus is the correct scientific name. [page 2-35, lines 33 and 38] 

(DW-0423 57)

Response: Based on this comment, Table 2-3 in the EIS was revised to reflect the correct

name.

Comment: Table 5-7 on page 5-27 does not explain why there are two rows of numbers for

bluegill and large-mouth bass. According to a similar table in Dominion’s ER (Table 5.3-22,

page 3.5.91), the two rows are from different sources. Please clarify this in the Final EIS. 

(DW-0437 17)

Response: The two lines of data for bluegill and largemouth bass reflect information from two

different sources for each species. Based on this comment, the noted table was modified to

clarify the source of information for the final EIS.
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Comment: Page 2-34 discusses fish populations. What percentage of fish catches and deaths

show abnormal anatomy? How does this percentage compare to inland waters around other

nuclear plants? How does this percentage compare to inland waters not near nuclear plants? 

(DW-0438 51)

Response: The frequency of physical abnormalities in fishes resulting from exposure to

radiation in Lake Anna fish populations could be addressed if some organization had reason to

believe that an aquatic sampling program was necessary. However, radiation guidelines that

are protective of the public also provide adequate protection to plants and animals. This

conclusion has been upheld by national and international groups that have examined the issue,

including the National Council on Radiation Protection and Measurement (NCRP Report

No. 109, Effects of Ionizing Radiation on Aquatic Organisms, 1991), the International Atomic

Energy Agency (IAEA Technical Report Series No. 332, Effects of Ionizing Radiation on Plants

and Animals at Levels Implied by Current Radiation Protection Standards, 1992), and the

International Commission on Radiological Protection (ICRP Publication 26, Recommendations

of the International Commission on Radiological Protection, 1977). The national and

international groups emphasized that individuals of non-human species may be adversely

affected by such radiation levels, but effects at the population level are not detectable. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: How will the increased temperature of the lake contribute to mosquito populations,

particularly those that are West Nile disease carriers? (DW-0438 95)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and the elevated discharge temperatures relative to the

existing discharge from Units 1 and 2 or the proposed Unit 3. The proposed cooling system has

since been changed to a closed-cycle, combination wet and dry cooling system, which would

have a substantially lower discharge temperature and be expected to have a negligible effect on

lake temperature or result in a change in mosquito statistics. Accordingly, no changes were

made to this EIS as a result of this comment.

3.5 Socioeconomics

3.5.1 Region of Socioeconomic Evaluation

Comment: Page 2-1 talks about a 50-mile radius but in other parts of the document different

radii are used (see for example Figure 2-3, Table 2-1). A consistent area or areas should be

used throughout the document. For example, a 15 mile radius might be the HIGH area of

impact, a 50 mile radius (which would include Richmond) might be MEDIUM areas of impact,

and an 80 mile radius (which would include DC) might be a LOW area of impact. For each

parameter addressed in the DEIS the impacts in each area of impact should be defined. 

Impacts on DC must be addressed. (DW-0438 12)
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NUREG-1811, Volume II 3-154 December 2006

Comment: Along the lines of comment 12 above, Page 2-5 line 10 defined “the region” as

within a 50 mile radius but provides no basis for why that area was selected. In this comment I

also noted that DC is generally considered part of the region. (DW-0438 14)

Comment: Table 2-1 shows data for four counties. As mentioned in our comment #12, this is

inconsistent with discussion of a “region” of study. (DW-0438 21)

Comment: Page 2-37 line 24 acknowledges the project proximity to Washington, D.C. yet the

document is largely void of discussion of impacts on the D.C. area. (DW-0438 54)

Comment: The potential impacts to the DC area are not addressed at all in the document and

should be included. (SE-0045 3)

Comment: Page 2-45 line 16 states that the “impact area for the analysis” includes only the

counties of Henrico, Louisa, Orange, and Spotsylvania and the City of Richmond. This area is

too small because likely and potential impacts exceed as far out as 80 miles from the site. This

area is arbitrary and inconsistent with other study areas used in the DEIS (see comment #12). 

(DW-0438 59)

Comment: Page 2-57 line 32 mentions that there are 32 counties within a 50 mile radius of the

project. It is not clear whether this 50 mile radius is the subject area for this part of the analysis. 

As stated in comment #12, consistent subject areas should be used. (DW-0438 71)

Comment: Page 4-17 line 11 discusses a ten mile radius from the site without providing a

rationale for why this radius was selected. As suggested in comment 12, I believe that

rationales should be provided and several radii should be used for all parameters studies. 

(DW-0438 97)

Response: These comments relate to the following issues: (1) the basis for the radial

distances from the ESP site used in the analysis, (2) defining a region of study, and (3) defining

the economic impact area.

Apart from the specific geographic area for socioeconomic impact analyses, the NRC is guided

by EIS preparation principles for each issue analyzed. The staff focuses its review on the area

that may be affected by a specific action or by alternatives; the geographical area varies

depending on the issue and the resource. The impacts analyzed in an EIS are to be discussed

in proportion to their significance with less important material summarized, consolidated, or

referenced and the most important material to be presented for issues with the greatest

significance. The NRC uses the scoping process to inform the analytical efforts, discussions,

and documentation on those issues of greatest significance or of likely greatest impact resulting

from the proposed action whether direct, indirect or cumulative. In performing the analyses,

there is inherent uncertainty in characterizing the effects and in prescribing the geographical
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 December 2006 3-155 NUREG-1811, Volume II

area influenced. Simply put, the NRC does not undertake detailed analyses to assess

improbable impacts nor does it extend the geographical area of analysis to the point where the

environmental effects of the proposed action may be irrelevant, negligible, or may not be

observable. Consequently, the judgement requires forethought and flexibility if the scoping

process reveals some unique circumstances. 

NRC regulatory guidance to applicants in place since the 1970s, including Regulatory

Guide 4.2, Preparation of Environmental Reports for Nuclear Power Stations, has delimited the

region of interest for EISs to about 50 miles for most issues. The radial distances from the plant

site are generally scaled to reflect the reasonable range of influence of plant activities on the

environment. The region of influence, or affected area, is not uniform across the environmental

disciplines or environmental resources. For the socioeconomic issues, the NRC’s Standard

Plans for Environmental Review for Nuclear Power Plants (ESRP) (NRC 2000) states that the

term “vicinity” means “a band or belt 10 km (6 mi) wide surrounding the plant site.” An objective

of the analysis is to investigate socioeconomic factors in an area in which the site makes up no

more that 10% of the area. For purposes of the socioeconomic environmental reviews, “region”

means “an area within an 80-km (50-mi) radius of the station site, but excluding the site and

“vicinity.” The relevant region is limited to “that area necessary to include social and economic

base data for (1) the county in which the proposed plant would be located, and (2) those

specific portions of surrounding counties and urbanized areas (generally, up to 80 km (50 mi)

from the station site) from which ....work forces would be principally drawn, or that would

receive stresses to community services by a change of residence of these workers. Other

social and economic impacts can generally be presumed to fall within the same area covered by

this definition of region.

The guidance described above was used in conducting the socioeconomic analysis for this EIS. 

However, the actual focus of the socioeconomic analysis was on those counties (Orange,

Louisa, Spotsylvania, and Henrico) and the City of Richmond where approximately 79 percent

of the operations workforce for NAPS Units 1 and 2 live. With no evidence to the contrary, the

staff postulated that a similar percentage of the operations workforce of the proposed ESP Units

3 and 4 would likewise live in these counties. In addition, most of the socioeconomic impacts of

plant construction and operation of Units 3 and 4 would likely occur in Louisa County and, to a

lesser extent, Orange County. While there would be socioeconomic impacts to Spotsylvania

and Henrico Counties and the City of Richmond, these impacts would be more diffuse. The

impacts become diffuse because of the larger economic base of the counties and the City of

Richmond. The remaining 28 counties within the 80-km (50-mi) radius are far removed from the

NAPS site and have less socioeconomic connection to the site, so any socioeconomic impacts

would be very small and difficult to measure. Likewise, socioeconomic impacts occurring

beyond 50 miles from the ESP site would be very small and difficult to measure and,
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NUREG-1811, Volume II 3-156 December 2006

consequently, need not be considered for this EIS. The likely residential locations of the

construction and operating workforce and impacts are covered in Sections 4.5.2, 4.5.3.5, 5.5.2,

and 5.5.3.5 of the EIS. Accordingly, no changes were made to this EIS as a result of these

comments.

Comment: The use of population radii in Section 2.81 is good. However inconsistent radii are

used throughout the section so comparisons (for example of stable and transient populations)

are difficult. (DW-0438 62)

Response: Section 2.8 of the EIS describes the current, affected environment. Table 2-5

presents the population (using Census 2000 data) and estimated population by decadal

increments out to 2065 by concentric radii starting at 0 to 16 km (0 to 10 mi) and ending at 60 to

80 km (37.3 to 50 mi), which defines the region of analysis. Section 2.8.1 of the EIS then

discusses where some of the towns, cities, and other attractions (Lake Anna and King’s

Dominion) are located within the radii. As stated in the section, an accurate count of the

transient population within an 80-km radius of the site is difficult. As an alternative, the analysis

focused on the two biggest attractions for transient populations within the 80-km radius of the

NAPS site – King’s Dominion and Lake Anna Recreational Facilities and State Park – and used

these attractions collectively as a proxy for transient population in the region. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: Page 2-9 line 15 discusses “the region” and it fails to mention that Fredericksburg is

within the radius drawn. Was Fredericksburg considered in other parts of the analysis? 

(DW-0438 19)

Response: Fredericksburg was considered in the socioeconomic analysis of Spotsylvania

County. Accordingly, no changes were made to this EIS as a result of this comment.

3.5.2 Economics and Taxes

Comment: The economic considerations to the community are considerable and as a resident

who lives within 20 miles of the plant I feel comfortable about the addition of two units at the

site. (DW-0791 3)

Comment: I am a Louisa County resident and the benefits to our county and state are

extensive. (DW-0858 2)

Comment: [T]hey [Dominion Power] have provided jobs to the citizens of Louisa and

surrounding counties in the state of Virginia, which have been important to continued prosperity. 

(DW-1007 3)
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 December 2006 3-157 NUREG-1811, Volume II

Comment: Dominion is a good citizen of our community. They pay their taxes. They employ

more than 900 people with average wages significantly average the average wage of the

community as a whole. They provide good, clean electric power and they help reduce our

dependence on oil. (ST-0018 2)

Comment: It makes sense. It increases tax revenues at very little expense to the community. 

It adds high paying jobs for construction and ongoing operations. It is at the leading edge of

initiatives to reduce our dependence on oil. It's good business and it's good for business and

we support it. (ST-0018 3)

Comment: For the whole time that I've been here [since 1984]... they [Dominion] have always

helped the community and the environment. We have put fish structures in. We've helped

stock the lake. We've done everything we could to make the lake a viable resource for the

community to use. (ST-0023 1)

Comment: [B]y my own observations as well as published polls that I'm familiar with, the vast

majority of the people of the community are in favor of expansion at North Anna. It's little

wonder since North Anna has provided employment for so many thousands of people right here

in this community. In this community, North Anna has provide a tremendous tax base for the

local community and Dominion employees have provided valuable voluntary services including

volunteering in this very school that I'm in speaking right now. (ST-0020 1)

Comment: Construction and operation at North Anna will increase the tax base of the County

allowing it to improve education and other core public services. Businesses seek locations with

reliable energy sources and educated workforces. More workers with good jobs also drive the

economy. ...There will be the additional benefit of these new workers spending their money with

local businesses and providing a better life for their families. (SW-0003 3)

Comment: The construction and operation of an additional unit at North Anna would also result

in significant economies, economic benefits for the region, and for the Commonwealth. 

Dominion estimates that 400 permanent employees will be required to operate the new facility. 

These are high-paying jobs, as we've heard earlier, with annual salaries over twice the average

salary level in the region. (ST-0031 4)

Comment: I was going to talk about economic benefits ...to Louisa County and the State of

Virginia and the nation that this project could provide and the fact that the benefits that

Dominion Power has provided this county over the last 20 or 25 years. (ST-0016 1)

Response: These comments express support for the socioeconomic factors related to the

proposed ESP units. The operation of the current NAPS Units 1 and 2 continues to provide

economic benefits to Louisa County and the surrounding region. Construction and operation of

 the additional units, if undertaken, would have similar benefits. Accordingly, no changes were

made to this EIS as a result of these comments.
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NUREG-1811, Volume II 3-158 December 2006

Comment: Page 2-37 line 15 talks about “professional fishing guides” and line 25 states that

the Lake “is heavily fished.” What compensation will there be to these business if the impacts of

increased thermal loading from additional nuclear units affects their business? (DW-0438 53)

Response: This comment was received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and its elevated discharge temperatures relative to the

existing discharge from Units 1 and 2 or the proposed Unit 3. The proposed cooling system has

since been changed to a closed-cycle, combination wet and dry cooling system, which would

have a substantially lower discharge temperature and would be expected to have a negligible

effect on lake temperatures and associated fishing. It is unlikely that there would be a

significant adverse impact on fishing guides. No compensation is planned. For further

discussion of aquatic thermal impacts, see Section 5.4.2.4 of the EIS. For effects on

recreational activity, including guides and marinas, see Section 5.5.3.4 of the EIS.

Comment: Page 2-54 line 41 cites a 2002 study that Capital One is one of the largest private

employers in the area. How have well-publicized job cuts there since 2002 changed this rating? 

(DW-0438 65)

Response: With almost 9000 associates, Capital One remains one of Richmond’s largest

employers. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Page 2-55 states that NAPS has been economically beneficial to Louisa County but

does not cite any data to quantify this impact. (DW-0438 67)

Response: As stated in Section 2.8.2.1 of the EIS, operation of NAPS Units 1 and 2 in Louisa

County has kept the property tax assessment rates significantly below those of neighboring

counties. It also enabled the County to begin an economic development program in the 1970s

with the construction of its industrial park. In addition, Table 2-15 shows the property taxes paid

to Louisa County by Virginia Electric and Power Company (VEPCo), which range between 56

and 39 percent of the total property taxes collected by the County. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: Section 4.5.3.1 should include typical salary information for the jobs to be created. 

(DW-0438 101)

Response: The wages paid to the construction workforce would vary by the type of skills each

worker possesses. The wages paid would most likely be the prevailing wage rate or higher in

the area for each type of skill when the workforce is hired for construction activities and skilled

workers are in demand. Accordingly, no changes were made to this EIS as a result of this

comment.
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Comment: [T]he analysis has also not given adequate attention to the potential for the new

reactors to bring severe economic disruption in the region, particularly for those businesses and

individuals whose economic well-being is intricately connected with the health and viability of

Lake Anna. (DW-1176 3)

Response: For the most part, the economic effects of construction and operation of new units

is expected to be beneficial to the region by virtue of the new employment opportunities,

expenditures made by the new employees in the community, and taxes realized for any new

units in the Louisa County property tax base (Sections 4.5.3.1, 4.5.3.3, 5.5.3.1, and 5.5.3.3 of

the EIS). The construction and operation of the new units is not expected to materially affect

Lake Anna or the businesses relying on Lake Anna. Any potential adverse impacts to the lake,

such as decreased water level during periods of drought, are expected to be transitory and

temporary (Sections 4.5.3.4 and 5.5.3.4 of the EIS). Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: The power station has been a tremendous tax asset to Louisa County. (DT-0029 8)

Comment: Dominion Power has been a real good neighbor and friend here in Louisa

County...and Spotsylvania and Goochland Counties, too. It has provided a wonderful lake for

recreation and housing and a great state park. It has provided tax money and employment for

people all over the area. It currently pays Louisa County more than $10 million a year in taxes

just to be here. And the company has supported fairs and events and programs and kids and

road clean-ups and much, much more. (DT-0063 5)

Comment: Some of the opposition [to the ESP] comes from people living in the vicinity of the

plant. Somehow they forget to mention the low property taxes they are paying because of the

high taxes paid by Dominion. I would love to have a nuclear plant in my neighborhood. 

(DW-1248 2)

Comment: Additionally, the direct and indirect tax revenues generated by the project will

provide over $70 million per year to local and state coffers, as estimated by the Virginia

Economic Development Partnership. This will provide much needed funding for schools and

other critical infrastructures in the region. (ST-0031 5)

Comment: The construction and operation of an additional unit at North Anna would also result

in significant economic benefits for the region and for the Commonwealth. ...The Virginia

Economic Development Partnership (VEDP) estimates that 1,500 additional jobs would be

created due to economic activity associated with the plant. ...the direct and indirect tax revenues

generated by the project will provide over $70 million per year to local and state coffers as

estimated by VEDP. This will provide much needed funding for schools and other critical

infrastructure. (SW-0007 2)
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NUREG-1811, Volume II 3-160 December 2006

Response: NAPS Units 1 and 2 have had a beneficial economic impact on Louisa County and

the surrounding region. Louisa County has received property tax benefits as a result of NAPS

being located in the county. As a result, Louisa County’s property tax rate is the lowest of the

surrounding counties (Sections 2.8.2.1 and 5.5.3.3 of the EIS). In addition, the salaries of those

working at NAPS are higher than the prevailing salaries and wages in the area for the workforce

with similar skills. The expenditures made by plant employees in the surrounding counties and

the property taxes paid on their residences are an economic benefit to the surrounding counties. 

VEPCo is responsible for the recreational resource known as Lake Anna. The increases in

property values of residences around the lake, and resulting property taxes paid, are an

economic benefit to Orange, Spotsylvania, and Louisa Counties. Any new units are likely to

result in similar beneficial economic impacts. Accordingly, no changes were made to this EIS

as a result of these comments.

Comment: What potential effects could the institution of electric utility deregulation in Virginia

have on the taxation of Dominion and the NAPS? It is suggested on page 5-42 of the EIS that

deregulation may affect the amount of property taxes paid by Dominion. (DW-0437 52)

Comment: Page 5-42 on taxes mentions utility deregulation. Would the new units be merchant

plants or rate-based? (DW-0438 154)

Response: Virginia’s transition to a competitive energy market is in progress. While

competitive service providers of natural gas have been making offers to consumers in some

areas, electric service providers have not. As with other states, it may take time for a

competitive electric service market to fully develop in Virginia.

The potential effects of electric utility deregulation in Virginia and its impacts on property taxes

paid by both the existing NAPS Units 1 and 2 and the proposed ESP Units 3 and 4 are not

known. However, as stated in the EIS, it is reasonable to conclude that the operation of the

new units should result in an increase in the existing Louisa County property tax base. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: According [to] the EIS, no quantitative assessment of the impact on regional tax

revenue can be provided at this time because Dominion has not yet selected the type of reactor

it would build at the North Anna site. This is yet another example of the arbitrariness of the

licensing division between ESPs and COLs, a separation that precludes a complete analysis of

the environmental impacts that would be produced from the construction and operation of new

reactors at the North Anna site (or any reactor site, for that matter). (DW-0437 64)

Response: This EIS has been prepared in response to an application for an ESP submitted to

the NRC by Dominion. Specific plant designs have not been selected for the proposed new

Units 3 and 4; instead, a set of plant parameters was provided to establish the basis for

considering environmental impacts using the characteristics of the North Anna ESP site. 
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Dominion can choose from several reactor types (including new reactor technologies). The

actual NRC decision on whether to issue a license for the construction and operation of one or

more of the proposed units would be made only upon the filing of applications for a COL, or a

construction permit (CP) and then an operating license (OL). Each COL, CP or OL is a major

Federal action; an EIS on the requested action would be prepared to address the environmental

impacts (including socioeconomic impacts) of that action. Through NEPA concepts known as

“tiering” and “incorporation by reference” (see, 10 CFR Part 51, Appendix A), the findings and

conclusions of this EIS will serve as portions of a subsequent EIS prepared for an application

for a COL or CP that references an ESP for the North Anna ESP site. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: What mitigation measures is the applicant proposing to provide direct economic

benefit from the proposed project to those neighboring counties that do not receive tax

revenues? (DW-0438 69)

Response: No mitigation measures are proposed. While the surrounding counties will not

benefit from the property tax revenues paid with any new nuclear units, the neighboring

counties would still benefit economically from the proposed construction and operation of ESP

Units 3 and 4. The benefits would accrue through increased taxes (i.e., sales, use, and

property taxes) paid by the construction workforce and operating plant employees. In addition,

the general economy of the neighboring counties would benefit through the expenditures of the

employees and business associated with the construction and operation of the proposed units,

including a betterment in employment and wages/salaries paid to non-Dominion employees as a

result of the overall increased economic activity. Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: Section 4.5.3.3 is almost useless without including indicative numbers for the

capital and operating costs and the likely tax contributions that would result. (DW-0438 108)

Response: Tax revenues are dependent on the valuation of the facility, for example, power

production, which in turn would affect the size of the construction workforce. Dominion has not

committed to a particular type of reactor design (there are over half a dozen new reactor

technologies that could be chosen), therefore, the impacts of construction on tax revenues can

only be discussed qualitatively. Should Dominion decide to proceed with construction of new

nuclear units at the North Anna ESP site, it would need to file with the NRC an application for a

COL, or an application for a construction permit and an operating license. At such time,

Dominion would commit to a particular reactor technology, which would then enable tax

revenues to be estimated quantitatively. Accordingly, no changes were made to this EIS as a

result of this comment.
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NUREG-1811, Volume II 3-162 December 2006

Comment: Section 4.5.3.3 should consider the potential for loss of property tax revenue from

the residential sector in the area if the proposed project results in a devaluation of real property. 

(DW-0438 109)

Response: There is no evidence to support a conclusion that real property values would

decline with the construction of additional units at North Anna. The opposite has occurred with

the construction and operation of NAPS Units 1 and 2. Residents of Lake Anna have enjoyed

an increase in property values over the years since VEPCo’s construction of Lake Anna and the

operation of Units 1 and 2 (Section 2.8.2.3 of the EIS). Any adverse impact of construction

would be temporary and would be unlikely to affect real property values. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: The conclusion of SMALL impact for Section 4.5.3.5 is not supported by the text or

the actual situation in the region. (DW-0438 110)

Response: The conclusion of SMALL impact is supported by staff findings and the text in the 

EIS. The bases for the conclusion are as follows. Approximately 80 percent of the construction

workforce already lives within the region, which means they already have residences, would not

likely move, and would commute to the site. Of the approximately 1000 workers (of 5000

maximum expected to be hired) that would come from outside the region, some percentage of

them would also commute to the site. The remaining part of the approximately 1000 workers

who might potentially move to the region (80-km [50-mi] radius from the NAPS site) would most

likely live in the areas of the region where rental housing is more readily available (e.g., Henrico

County, City of Richmond). If, however, the above assumptions do not hold (for example, a

significantly higher cost for commuting), and more construction workers than anticipated attempt

to move closer to the NAPS site, then there could be a MODERATE adverse impact on housing;

this is unlikely given past trends for major construction projects and expected outcomes, as

described. Accordingly, no changes were made to this EIS as a result of this comment.

3.5.3 Population

Comment: Citing the comprehensive plan developed for Louisa County, the EIS notes that “it

is the goal of the Louisa County Board of Supervisors (LCBS) to preserve the rural character of

Louisa County” (page 4-17, lines 14-16). But the construction of new reactor units at the North

Anna site would require an additional workforce of up to 5,000 individuals (DEIS, Section 4.2.2),

and the operation of such reactors would require a workforce of an additional 720 persons,

which would increase the regional population by an estimated 2,900, assuming each worker

represents a family of four (DEIS, Section 5.5.2)... Even without the construction of the new

reactor units, the population of Louisa County is expected to grow by 13 percent in the next five

years and another 15 percent between 2010 and 2020 (DEIS, Section 4.5.1.3); moreover, the
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regional population is expected to grow by over 1 million by 2040. Is this degree of

development consistent with the wishes and plans described in the LCBS to preserve the “rural

character” of the region? (DW-0437 45)

Comment: Given that Louisa County had a population of about 25,000 in 2000... the

conclusion that a construction work force of 5,000 would have a SMALL impact... is

unsubstantiated and suspect. (SE-0045 19)

Comment: Considering the desires of the LCBS, how does the NRC consider these impacts

[on rural character] to be “small” (page 4-21, line 4). (DW-0437 46)

Response: The reason for the SMALL impact designation is that the staff expects that about

80 percent of the construction workforce would already live within the region (80-km [50-mi])

and, thus, would have established residences. The rest of the workforce (about 1000 workers)

that may come from outside the region may commute to the NAPS site from existing

residences. Some fraction of the approximately 1000 workers and up to 4000 persons may

relocate to the region, but not all of them would necessarily locate to Louisa County. Similarly,

of the expected 2900 person increase in population resulting from the operations workforce

moving to the region, it is expected (based on the distribution of place of residence of the

current operations workforce of NAPS Units 1 and 2) that the population of Louisa County would

increase by 3.2 percent, based on Census 2000 data. This would not change the rural

character of the county. Given the lead time to consider construction and operation of major

industrial projects, the County Planning Department, the County Board of Supervisors, and the

citizens of the county will have ample time to participate in county development plans.

Comment: [Regarding Dominion’s Site Safety Analysis.] The population data needs to be

strongly scrutinized as new developments in the Louisa area around Lake Anna are consistently

developing, as well as areas of Spotsylvania and Hanover County. (DW-0191 2)

Comment: [Regarding Dominion’s Site Safety Analysis.] There are many schools within the

region of the 80-km (50 mile radius) of the plant that are only briefly mentioned and could be

affected should conditions warrant. I am sure that additional plans and measures will be

developed as time permits, however, all of this data should be evaluated from current data not

data that is 15 to 18 years old. A determination should be made to accurately use the

information based on the 2000 Census data or current information. The total population totals

mentioned in Section 4.4.3 now far exceeds the totals referenced in this section, and the

disproportionately high and adverse human health or environmental effects mentioned. 

(DW-0191 10)

Response: The NRC staff reviewed Dominion’s ER and conducted an independent evaluation

of the regional population and its demographics. The information is presented in Section 2.8.1

of the EIS. All population data used in the staff’s socioeconomic analysis are based on Census
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NUREG-1811, Volume II 3-164 December 2006

2000 data, which are the most recent official counts of the population. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: Information regarding the demographic make up of the communities in close

proximity to the areas of potential impact is not well defined. The document does not contained

detailed information regarding the exact demographics of the areas that would be most

impacted by site activities. Community characterization at the small community level would be

most helpful. What is the make up of the areas closest to the site? Are there areas close to the

site where multiple site activities might take place? What would the cumulative impacts be on

such a community? (SE-0030 9)

Response: The socioeconomics section in the SEIS describing the affected environment

(Section 2.8) was by necessity an abbreviated version of the much more descriptive section in

the Draft EIS and in this Final EIS. Accordingly, no changes were made to this EIS as a result

of this comment.

Comment: The demographic data used in Section 2.81 on Page 2-45 is outdated and

inaccurate. Spotsylvania County, for example, has grown 24% in the last five years! 

(DW-0438 60)

Comment: It appears the NRC is basing decisions on 5 year old [population] data and has not

considered recent property development around the lake or world events in any of their decision

making. (SE-0022 4)

Response: Population data in the EIS are based on Census 2000 data and the recent

population projections from the Virginia Employment Commission and Weldon Cooper Center

for Public Service. The rapid rate of growth in Spotsylvania County population is acknowledged

in Section 2.8.1 of the EIS. The population of Spotsylvania County has grown by approximately

25 percent as of the end of 2004. Much of this growth has occurred in and around

Fredericksburg. The estimated population for the county is expected to increase to 125,000 by

2010, or an increase of approximately 38 percent over the decade, which is consistent with the

growth rate through 2004. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: As stated in comment #20, a population forecast through 2026 should form the

baseline of the existing environment. The project could then be overlayed on this forecast to

assess impacts at different time intervals. (DW-0438 61)

Response: Table 2-7 in the EIS was updated to include population forecasts through 2065

(2010 was used in the Draft EIS). However, doing this did not change any of the impact

conclusions reached in Sections 4.5 and 5.5 of the EIS. The reason is that any population

increases resulting from construction and operation of two new units at the North Anna ESP site
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are expected to be distributed across the region. In addition, an increase in the future

population base against the fixed number of construction and operations employees, whose

number is not expected to change, would mean a smaller percentage increase in population

because of the construction and operations impacts.

Comment: Page 2-57 line 9 states that “there are no growth restrictions in Spotsylvania

County.” Please define this phrase. The County has zoning and other restrictions. 

(DW-0438 70)

Response: The commenter is correct that there are zoning and other restrictions to regulate

new growth. However, the county has not implemented a moratorium or placed absolute limits

on new growth or construction. This could be imposed, for example, if the water or sewer

systems of the county were not adequate to handle new demands placed upon them because

of new residential, business, or industrial growth. Accordingly, no changes were made to this

EIS as a result of this comment.

3.5.4 Housing and Public Services

Comment: This EIS Section assumes a worst case of a large number of workers relocating

with their families even if they were in trailers. ER Section 4.4 implies that there would be little

likelihood that most construction workers would relocate with their families for this effort, that is,

this would be unusual. [page 4-33, line 9] (DW-0423 26)

Response: In Section 4.5.3.5 of the EIS, the staff indicates that most of the construction

workforce is expected to come from within the region. The staff also acknowledges that, in its

ER, Dominion states that approximately 80 percent of the construction workforce is expected to

come from within the region and already have established residences; thus, about 20 percent of

the construction workforce (about 1000 workers) could come from outside the region. 

Predictions of 20 years or more regarding the availability of the future workforce, such as that

needed for the construction of any new nuclear units, has some uncertainty. Thus, the

socioeconomic analysis discusses the potential aspects and related impacts that potentially

might occur, and then concludes that the impacts of the construction workforce on housing

would be SMALL because of the availability of rental housing in the region, particularly in the

larger metropolitan areas. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: According to this Section of the draft EIS, the construction workforce required to

build new reactor units at the NAPS could reach 5000, and there is a shortage of housing in

Louisa and Orange Counties. Yet the building of new rental units to accommodate the influx of

workers is not expected (though this seems to be contradicted by assertions to the contrary on

page 4-2, lines 32-37), and, as a result, rents may increase and “some low-income populations

could be priced out of their rental housing” (DEIS, page 4-30, lines 11-12). Nevertheless, the
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NUREG-1811, Volume II 3-166 December 2006

NRC staff opines that construction of new reactor units at the site will be “economically

beneficial” for “disadvantaged population segments,” concluding that impacts on housing will be

“small” and mitigation measures are not warranted. Would it not be prudent to recommend the

establishment of additional and/or affordable housing in the region in order to prevent a

shortage? (DW-0437 47)

Comment: The assumption on page 2-62 line 36 that temporary housing for refueling workers

is as dispersed as for permanent employees is unsubstantiated. Furthermore, if four units are

operational, the potential for overlap of refueling outages increases and thus the possibility that

significantly more than 700 temporary workers would be required at one time. (DW-0438 77)

Response: In Section 4.5.3.5 of the EIS, the staff states that the development of a significant

number of new rental units in anticipation of construction of the new units at the North Anna

ESP site is not expected. The reasons are that most of the construction workers are expected

to come from within the region and the construction period is for only five years and the

expected capital investment would most likely not be recovered in such a short time frame. In

addition, sufficient rental units exist in the larger metropolitan areas of the region to

accommodate the construction workforce. Based on discussions with Dominion, the temporary

refueling workers for the NAPS units would be dispersed across the region in a distribution

similar to that of the permanent employees. The projected number of temporary workers

employed for refueling outages with the additional two units would remain the same as with

existing units (700 to 1000) because Dominion plans to stagger refueling operations so that only

one unit would be refueled at a time, which is the current practice for NAPS Units 1 and 2. The

construction workers would be in addition to the normal outage workforce for Units 1 and 2. 

With four operating units, there would most likely be two outages each year – one in the spring

and the other in the fall. There may be some investment activities to accommodate the

construction workforce, as discussed in Section 4.1.1 of the EIS, or there may be some upward

pressure on rents if construction workers disproportionately locate in Louisa or Orange

Counties. The construction of new units would provide economic benefit to the region, including

the creation of construction and related jobs, that would benefit business in the region, primarily

in Louisa County. Through the multiplier effect of expenditures, jobs would be created that

would benefit the region, including its disadvantaged population segments. The staff considers

the case where low-income residents would be priced out of the housing market as an unlikely

event and therefore does not justify mitigative measures. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: Section 2.8.2.5 on Housing and the related parts of Sections 4-7 do not assess the

impacts of the proposed project on housing values in the Lake Anna area. (DW-0438 76)

Response: Section 2.8 of the EIS discusses the current baseline conditions in the region and

Section 4.7 discusses the Environmental Justice impacts of construction. Section 4.5.3.5

discusses the impacts of construction on housing. Because most of the construction workers
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are expected to come from within the region and commute to the NAPS site, it is unlikely that

there would be a direct impact of an increase in housing values due to the construction

workforce. However, housing values around the lake would most likely be supported because

of the increased economic benefits resulting from the construction activity. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: Section 5.5.3.5 should assess the impact on local housing values from the

proposed project. (DW-0438 157)

Comment: No mention is made of the impacts of the project on property values in the Lake

Anna Area. (SE-0049 1)

Comment: [T]here is no data on the impact that the project will have on local house values. 

(SE-0045 2)

Response: Section 5.5.3.5 of the EIS states that in Louisa and Spotsylvania counties, there

could be a temporary shortage of housing, thereby putting upward pressure on housing prices

or values, although the shortage would likely be alleviated with more construction. In general,

housing values are expected to be supported by the improved economic vitality of the two

counties resulting from the operation of the two new nuclear units. Accordingly, no changes

were made to this EIS as a result of this comment. Section 5.5.3.4 covers the effects of low

water on property values. A change was made to Section 5.5.3.4 in this EIS. See also

Section 3.5.5 of this volume.

Comment: What is the estimated number of new residences that would be required in

Spotsylvania to serve the construction (and later operating) personnel? If these persons have

school age children, this would add to the growing education demands. (DW-0438 111)

Response: Generally, it is expected that approximately 80 percent of the construction

workforce already lives in the region (defined as 80-km [50-mi] radius from the NAPS site). 

About 20 percent of the construction workforce (about 1000 workers) could live outside the

region and commute to the job site or move into the region. Those who move into the region

may or may not include the workers’ families (the workers may live in rental housing during

the workweek and commute back to their residences on the weekend). Based on these

assumptions, 1000 workers and their families moving into the region, or 4000 individuals

(assuming four members per family for each construction worker) would be a reasonable

estimate. If the staff assumes that these new, relocated construction workers distribute across

the region as the existing workforce for NAPS Units 1 and 2 (see Section 2.8.2.5 of the EIS),

then approximately 230 residences would be purchased in Spotsylvania County. If these

workers have school-age children, then they would add to the population of the county’s

schools.
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NUREG-1811, Volume II 3-168 December 2006

A workforce of approximately 720 employees would be needed to operate the two new nuclear

units, and they are expected to come from outside the region. Assuming these employees are

distributed across the region in a similar distribution as the employees of NAPS Units 1 and 2,

then the staff expects approximately 165 operating employees and their families (or

740 individuals) to locate in Spotsylvania County. The EIS already reflects these estimates.

Accordingly, no changes were made to this EIS as a result of this comment

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the

ESP]...Impact of 5,000 – 7,000 new workers (construction, periodic maintenance, professional)

employees for 5 years on local ... schools. ...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. (SE-0022 26)

Comment: [T]hree newly approved Louisa County subdivisions in the proximity [will be

needed] which is going to add about 1800 new homes in that area. New schools and other

county infrastructure, police, fire, rescue squads, etc. will need to be planned and build prior to

any new tax dollars coming from Dominion. (ST-0014 14)

Response: See the response related to schools in this section. Given the growth taking place

in these two counties, the infrastructure would need to be expanded independent of and in

anticipation of the potential North Anna ESP development. County services and potential

infrastructure needs are discussed in Sections 4.5 and 5.5. Accordingly, no changes were

made to this EIS as a result of these comments.

Comment: Life safety – there are no hospitals nearby Lake Anna and none in the adjacent

counties of Spotsylvania or Louisa. (DW-0432 3)

Comment: The “Police, Fire, and Medical Facilities” Section on page 2-68 is substantially

flawed. It states that there are TWO hospitals in Spotsylvania when there are NONE. 

(DW-0438 78)

Comment: The Section in 5.5.3.6 on Police, Fire, and Medical Services is flawed. It states that

patients travel to Spotsylvania for hospitalization, but in reality is no hospital there. 

(DW-0438 158)

Comment: The fact that there are no hospitals in the three closest counties (Orange, Louisa,

and Spotsylvania) should weigh heavily against the proposed facility. How far is the nearest

hospital? (DW-0438 159)
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 December 2006 3-169 NUREG-1811, Volume II

Response: The comments that there are no hospitals in Spotsylvania County are correct. The

Draft EIS stated there are no hospitals in Louisa and Orange Counties. There is one hospital in

Fredericksburg, which is a separate jurisdiction from the County. The nearest hospitals to the

North Anna ESP site are Mary Washington Hospital in Fredericksburg, Culpeper Regional

Hospital in Culpeper, Henrico Doctor’s Hospital in the Richmond area, and Martha Jefferson

Hospital in Charlottesville. All are in the range of 48 to 56 km (30 to 35 mi) from Mineral.

There are a number of hospitals scattered throughout the region (80 km [50 mi]). Because

approximately 80 percent of the construction workforce is expected to originate from within the

region and have places of residence scattered throughout the region, there is no evidence that

any one health care facility would be adversely impacted by construction of the two new nuclear

units.

In response to these comments, Sections 2.8.2.6 and 5.5.3.6 in the EIS were revised.

Comment: Section 4.5.2 ignores the strain that a new populace would place on the limited

health care resources in the region. This is a major socioeconomic factor and should be

thoroughly analyzed. (DW-0438 100)

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. How can the

SDEIS state that the impact is SMALL (with no hospitals in “the nearest three Counties” –

page 2-18) when the DEIS stated that the impact is SMALL and assumed the existence of two

hospitals in Spotsylvania? (SE-0045 14)

Response: The analysis considered that approximately 80 percent of the construction

workforce is anticipated to live in the region and is considered in the demand for medical

services already. Of the remaining 1000 construction workers that may originate from outside

the region, some percentage of those would commute to the job site and would continue to

maintain their residences outside the region. Some percentage of the 1000 workers and their

families would move into the region. These workers most likely would move to the City of

Richmond and greater metropolitan regions of Henrico County, where there are a number of

existing medical facilities. Also, such new residents (the fraction of the approximately

1000 workers and their families) would be a small number when compared to the larger

population base (several hundred thousand) and would place a minimal incremental demand on

the medical system. Accidents at the new facility likely would be covered by an extension of the

medical arrangements for the existing NAPS workforce. Accordingly, no changes were made to

this EIS as a result of this comment.

Comment: The Draft EIS acknowledges that even without the construction of new reactor units

at North Anna, there may not be sufficient water and sewer infrastructure in the region to keep

up with the expected growth. Further, a recent drought has exacerbated a shortage in the
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NUREG-1811, Volume II 3-170 December 2006

availability of water supplies in Louisa and Orange Counties, where there are no growth

restrictions (DEIS, Section 4.5.3.6). Thus, the NRC staff has judged that the construction of

new reactor units at the NAPS may have “moderate” impacts (page 4-31, line 34). Given this

conclusion, the environmental impacts of extending services in Orange and Louisa Counties

should be considered, as well as measures to mitigate those impacts. (DW-0437 44)

Response: Louisa and Orange County officials indicated that the existing water supply and

sewer infrastructure is currently near capacity. Given the growth taking place in these two

counties, the infrastructure would need to be expanded independent of the potential North Anna

ESP development.

Approximately 80 percent of the construction workforce (or 4000 individuals) is expected to

already have residences within a 50-mi radius of NAPS. About 20 percent of the construction

workforce (about 1000 workers) could live outside the region and commute to the job site or

move into the region. Some percentage of the 1000 construction workers residing outside the

region and their families would probably move to the region to be closer to the job site. 

Because there is more available rental and temporary housing in the larger metropolitan area of

Henrico County and the City of Richmond, it is expected that many of these workers would

probably relocate to that area, where water and sewer facilities are adequate and impacts would

be SMALL. Only if a majority of these workers relocate to Orange and Louisa Counties would

there be the potential for moderate impacts associated with the North Anna ESP development. 

This situation is unlikely because rental and temporary housing is less available in Orange and

Louisa Counties. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: [Another] issue is the impact on housing itself. ...we have many young teachers at

our schools...It will be very hard for them to compete in the rental market with 3 or 4 young

single...construction workers pooling their resources. (SE-0036 3)

Response: In Section 4.5.3.5 of the EIS, the staff states that the development of a significant

number of new rental units in anticipation of construction of the new units at the North Anna

ESP site is not expected. There may be some investment activities to accommodate the

construction workforce, as discussed in Section 4.1.1 of the EIS, or there may be some upward

pressure on rents if construction workers disproportionately locate in Louisa or Orange

Counties. The construction of the new units would provide economic benefit to the region,

including the creation of construction and related jobs, that would benefit business in the region,

primarily in Louisa County. Through the multiplier effect of expenditures, jobs would be created

that would benefit the region, including its disadvantaged population segments. The staff

considers the case where low-income residents would find it difficult to secure housing as an

unlikely event and therefore does not justify mitigative measures. Accordingly, no changes

were made to this EIS as a result of this comment.
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 December 2006 3-171 NUREG-1811, Volume II

Comment: I feel it very important to say the Louisa County School Board is not here in support

of or in opposition to the new reactors. Our business is to educate students who come to

Louisa County Public Schools, and this will happen whether the reactors come or not. ...The

school division receives approximately 60 percent of the tax base from Louisa County. With this

money, Louisa County Public Schools is a strong and growing school division. ...The school

district must remain neutral in political matters, however, we do have to consider the

contingencies of all outcomes and how they might impact the school division financially and in

terms of student population. With the increase in taxes from Dominion Power, we must

understand this will raise our composite index. When the index goes up, the funding from the

State of Virginia will go down and the state will expect the localities to pick up the lost funding. 

We could at best guess estimation lose between $6 to $8 million. We must understand that it

will be the job of our local government to pick up this portion of lost revenue. There could be a

lag time between the lowering of the index and when we actually start getting more tax dollars. 

Again the county and its taxpayers must be willing to fund the school budget should this

happen. (ST-0011 1)

Comment: [Regarding Dominion's ESP Application] Major influx of new persons to Louisa,

Spotsylvania, and Orange Counties will result in need for new schools. ...Since the nuclear plant

may be a national priority, then possibly school construction grants can be provided by the

Federal government to assist with new school construction. (SE-0003 3)

Comment: This major influx of new Louisa residents [from addition of new construction and

operations employees] will have a major impact on schools requirements. Since the nuclear

plan may be a national priority, then possibly school construction grants can be provided by the

Federal government to assist with new school construction. (SW-0005 4)

Comment: It is a given that tax revenues will increase if two new reactors are built, but those

taxes will not be forthcoming until each reactor is at least partially on line. In the interim, our

schools will more than likely be impacted with a significant increase in student population and

will invariably include many more students for whom English is a second language. ...in the

interest of education and future nuclear power construction...we are asking the Virginia

Department of Environmental Quality and the U.S. Nuclear Regulatory Commission to petition

the federal government, on our behalf, for funding to allow us to minimize any adverse impact

from this construction. (SE-0036 2)

Comment: The Draft Environmental Impact Study indicates that the impact on demography,

housing, and education would all be “small” and “mitigation is not warranted”. We disagree with

this assessment....The first problem we see is the possibility of providing services to a large

increase in our student population in a relatively short time period. We currently have

approximately 4,400 students in our system and our facilities are at capacity. An immediate

increase of even 100-200 students will create a financial and educational burden. ...When the

first two reactors were built...our student population increased by almost 21 % during that
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NUREG-1811, Volume II 3-172 December 2006

construction period...At this time, three new subdivisions have already been approved by Louisa

County for development in near proximity to the construction site...for a total of approximately

1800 potential homes that could be built in the next few years...With the much greater

availability of housing during future reactor construction, we would have to anticipate an even

larger percentage of increase in student population. (SE-0036 1)

Response: The staff assumes that up to 1000 construction workers and their families could

move into the region. The permanent operations workforce that would come later would be

somewhat smaller. Louisa County likely would obtain considerable property tax revenue, some

of which could be directed at construction of necessary education infrastructure, although timing

of revenues might be a problem (they could be needed before they are available). The other

counties would not receive such revenues. Because all three counties are growing anyway and

will have to add schools in any event, the influx of plant-related personnel could accelerate this

process. Depending on the specific circumstances, outside assistance may be deemed

appropriate. Federal grant policy is beyond the scope of this EIS. The staff has already

evaluated the impacts to schools in Sections 4.5.3.7 and 5.5.3.7. Accordingly, no changes were

made to this EIS as a result of these comments.

3.5.5 Property Values Related to Water Levels

Comment: Lower water levels will impact the lake ecosystems and could lower property

values. (DW-0772 3)

Comment: Lower water levels will adversely impact the lake and could lower property values. 

(DW-MM1 5)

Comment: If I had known three years ago that there was a chance that the water abutting my

lot would be that much warmer, I would not have purchased the lot. I believe that, if the

proposal to use water from the lake to cool another reactor is approved, the value of real estate

on the hot side will be greatly reduced from what it would be if the proposal is not approved. It

may be true that the reactor will not be built until I am long gone, but I will be affected because

the value of my property will be suppressed or reduced. If all real estate values on the hot side

are reduced, county revenue will be reduced by the reduced property values. Thus, real estate

taxes for the rest of the county will have to be raised to make up the difference. (DW-0190 2)

Comment: The impact on property values from increased periods of lower lake levels should

be analyzed in the Final EIS. (DW-0437 9)

Comment: As a home owner, I’m concerned about my property values. (DT-0013 2)

Comment: That area of the lake has been pretty heavily populated. It’s pretty heavily used for

all kinds of recreation fishing. So I don’t think the construction of these plants, if it creates
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 December 2006 3-173 NUREG-1811, Volume II

problems for people that live there, I don’t think those problems can be ignored, and I hope that

Dominion doesn’t ignore them. The water temperature being what it is, it wouldn’t take much of

an increase to make that part of the lake unusable during certain months of the year: July,

August, early September. If that happens or even if the public thinks it’s going to happen, if

there’s a public perception that part of the lake is going to become unusable for the period of the

year when most people want to use it, that’s going to diminish property values quite a bit,

including mine, and for a lot of other people also. (DT-0024 2)

Comment: What will happen to the local economy property values if reactors impair fishing and

recreational uses of Lake Anna? (DT-0038 4)

Comment: No mention is made of the impacts of the project on property values in the Lake

Anna Area. (DW-0594 14)

Comment: Lower lake levels lead to mudflats in the back yards of homes located around the

lake, and could decrease property values. (DW-MM4 4)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and its elevated discharge temperatures relative to the

existing discharge from Units 1 and 2 or the proposed Unit 3. The proposed cooling system has

since been changed to a closed-cycle, combination wet and dry cooling system, which would

have a substantially lower discharge temperature and would be expected to have a negligible

effect on lake temperature. The projected lake levels during periods of drought were evaluated

based on the new proposed cooling system. If two new units are constructed, lower lake levels

could occur during periods of drought. For example, during the period from October 2001

through December 2002, an extreme drought occurred in the region from Georgia to northern

Virginia. It was the worst drought that had occurred since climate records have been kept in

that part of Virginia. As a result of this climatic anomaly, Lake Anna experienced the lowest

lake water levels and lowest estimated inflows in its history. Although the boat ramp at Lake

Anna State Park remained usable throughout the drought period, some private boat ramps were

not usable. Some residences located adjacent to the lake had mud banks adjacent to their

homes because of low lake levels.

The change to the proposed Unit 3 cooling system is projected to increase the consumptive use

of water from Lake Anna and decrease the duration of lake levels above 75.6 m (248 ft) above

MSL from 94 percent to 89 percent of the time (Section 5.3.2 of the EIS). Most of the increase

in low-water days would take place in times of drought when lake levels otherwise would be low. 

There is expected to be almost no noticeable effect from Unit 3 on lake levels in non-drought

years. Unit 4, which has dry cooling, would have no effect on lake levels.

During 2001 to 2002, lake levels were quickly restored when normal precipitation levels

returned to the region. Overall, in terms of the historic record, the drought was a rare event and
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NUREG-1811, Volume II 3-174 December 2006

temporary in nature. Based on the historical record, drought impacts are temporary and quickly

reversible. Potential impacts on property values would not be permanent and would be

reversed once normal precipitation patterns reappeared. Available mortgage data for census

tracts touching Lake Anna does not indicate any property value decline as a result of the 2001

to 2002 drought (Section 5.5.3.4). In addition, several Federal, State, and local regulations

(e.g.,VDEQ NPDES permit for the plant) would minimize possible impacts on the lake of plant

operation.

The “warm side” of Lake Anna is currently licensed by the Commonwealth of Virginia as an

industrial waste heat treatment facility and is regulated as such. Some of the lakefront property

is located around this facility, and it does not appear that property values are harmed by the

temperature of the water. The NRC staff determined that as a result of the changes in the Unit

3 cooling system, Unit 3 would not increase water temperature in the WHTF (Section 5.3.3 of

the EIS). In view of the other factors affecting property values, such as population growth and

the economy of the area, warm water temperature is not expected to have a significant effect on

property values (Section 5.5.3.4). Section 5.5.3.4 was modified in response to these

comments.

Comment: [Regarding Dominion's ESP application] Possibly raising the lake level 6 to 12

inches to retain more water in the lake so it would help in times of drought. ...Raising the lake

level would create major hardships and destruction of private property to all adjoining

landowners and businesses that have piers, boathouses, launching ramps, bulkheads, etc. It

would also destroy many lake front business locations. (SE-0003 8)

Comment: Raising the lake level by 6 to 12 inches would create major destruction of personal

property located at the water's edge. The expense and effort by property owners necessary to

establish new bulkheads, docks, boat houses, etc., backfill with soil to meet the new height of

the modified structures, and establish new landscaping is beyond calculation at this point. All

waterfront properties would be effected and some properties would suffer significant loss in

value! (SE-0012 1)

Response: The staff analyzed the impact of raising the normal pool elevation as a possible

mitigation consistent with NRC’s role under NEPA. This specific mitigation was considered

based on a request by the Commonwealth of Virginia to evaluate raising the lake elevation to

maintain the current frequency at 20 cfs. Any decision to change the operating policies for

North Anna Dam are responsibility of VDEQ and not NRC. Section 5.5.3.4 states that if the

normal operating lake level were raised 6 to 12 inches, then modification of some residential

and marina boat ramps might be necessary. This was described as a MODERATE impact on

the basis that, although there might be considerable one-time expenses on the part of

individuals and businesses to adapt, Lake Anna would continue to be used for recreation and

lake front homes, docks, and businesses would continue to exist. Accordingly, no changes

were made to this EIS based on these comments.
Comments Within Scope

 December 2006 3-175 NUREG-1811, Volume II

3.5.6 Recreational Issues Related to Water Levels

Comment: Suggest that this DEIS statement describe the concern as during times of severe

drought. [page 5-44, line 6] (DW-0423 35)

Comment: Suggest that this DEIS statement describe the impact as during multiple drought

years like 2001-2002. [page 5-44, line 27] (DW-0423 36)

Response: As stated in Section 5.5.3.4 of the EIS, during times of severe drought, such as the

drought of 2001 to 2002, the staff expects that the usability of stationary boat docks may be

impacted when the lake level drops below 76 m (248 feet) MSL. Lakefront houses temporarily

could have mud-flat views instead of the preferred water views. However, the drought of 2000

to 2001 was a rare event, and none of these impacts from such an event would be considered

permanent. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Water levels can be expected to drop and temperatures rise even further. This

will also affect the lake’s recreational appeal and value for the state’s tourism industry. 

(DW-0623 4)

Comment: Construction and operation of the new facilities will ...[damage] the environment

and disrupting recreational uses of Lake Anna. (DW-0640 3)

Comment: The two reactors that are already operating at North Anna withdraw 1.9 million

gallons of water per minute and then return hot water back into the lake. This utilization of

water already has a damaging effect on... the residents of the lake...The additional nuclear

reactors will undoubtedly have serious adverse effects on...the Lake Anna homeowners, and

the people using the lake for recreation and fishing. (DW-0653 3)

Comment: Creation of Lake Anna has provided recreational opportunities for thousands of

people - more than indicated in Section 2.8.1 of the Draft EIS. Unlike some utility and Corps of

Engineers impoundments, Dominion Power only bought a small amount of shoreline and

allowed shoreline usage rights to lake-front property owners. (DT-0029 7)

Comment: Lake Anna [is] a valuable area recreational facility - fishing, especially- and I am

worried that the use of the water would adversely... impact the use of the lake recreationally. 

(DW-1151 2)

Comment: Lower water levels will adversely impact water-based recreational uses of the lake,

for example by preventing access to boat launch ramps. (DW-MM4 3)

Comment: [Another reactor would affect] water based recreational uses of the lake, especially

in drought years. (DT-0019 5)
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NUREG-1811, Volume II 3-176 December 2006

Comment: What will happen to the recreation on the [Pamu]nkey River downstream, such as

kayaking and canoeing, which Lake Anna feeds into, when the low flows occur? (DT-0038 6)

Comment: This section fails to adequately consider the potential impacts on recreational use

of Lake Anna from the operation of additional reactor units at the NAPS, which may significantly

reduce the water levels in Lake Anna and, consequently, adversely affect river flow and aquatic

life downstream. (DW-0437 29)

Comment: We definitely have enjoyed the last few years of increased rains, but we know that

these have been unusual. We know that increased water withdrawals up to 60% over current

conditions would impact recreation to an estimated 43,000 recreational users and also for home

water usage during normal or drought conditions. During the 2002 drought, boats could not

launch from many of the home and recreation sites so desired by our members. (DW-0857 3)

Comment: In the 2002 drought, the water level dropped to 245 feet above mean sea level. 

That doesn’t mean much to me either, but this is about five feet lower than normal. Boats could

not be launched from ramps on the lake. The back yards of homes around the lake were mud

flats. (DT-0019 7)

Comment: By now we should all understand clearly that those impacts that were reported in

the NRC report will affect some of us temporarily or permanently, and we need to weigh those

impacts up against the goal. We need knowledge that those who live and enjoy recreation on

the warm side of the lake will experience about a three percent increase in the temperature, and

that change in temperature will be most noticeable during the hottest summer months. The lake

level on the cold side is going to be lower, and it’s going to last longer during periods of drought

conditions. So what does that mean to me and perhaps to some of you? Well, maybe that year

I won’t be able to boat. Maybe I’ll only boat 15 times rather than 30, but I personally feel that

sacrifice is worth it to achieve the goal of independence. (DT-0011 5)

Comment: It seems like if it [using dry cooling for Unit 4] would eliminate the thermal impacts

and the evaporation impacts, we should do it. What's important here is protecting the lake, for

people to use their boats in the lake, to fish in the lake, to swim in the lake if people do that and

to protect downstream people's ability to kayak and canoe and also the fisheries. (ST-0005 5)

Comment: [Regarding Dominion’s ER] Par[agraph] 5.2.2.2 page 3-5-16 We disagree with the

conclusion “Potential impacts would be greatest in the reach of the North Anna River extending

below the North Anna Dam to its confluence with the South Anna River”. Are there any uses of

the water in this area? What about the property owners around the lake who can not use their

boats, docks and the water? Aren’t they impacted just as much? (SE-0004 26)
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 December 2006 3-177 NUREG-1811, Volume II

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. (SE-0045 21)

Comment: The Department of Conservation and Recreation has concerns about the impacts

of the proposed addition of Unit 3 upon the water quality and quantity in Lake Anna and in the

North Anna River below the dam. (a) Lake Anna. Lake Anna supports a significant amount of

recreational activity from people getting to the lake from public and private lands. Lake Anna

State Park is a particular example of the public investment in facilitating public use of the Lake. 

Proposed new generating facilities will deplete the water available for other uses. 

(WC-0017 13)

Response: Collectively, this group of comments make the following two points. One, the

commenters indicate that recreational experiences at Lake Anna and downstream locations

would be impaired by operation of new units at the North Anna site, particularly during times of

drought. Two, the commenters indicate that Lake Anna has provided recreational opportunities

for thousands of people and, unlike some U.S. Army Corps of Engineers (ACE) impoundments,

Dominion bought only a small amount of shoreline and allowed shoreline usage rights to

lakefront property owners. To expand upon this point, the commenters indicate that the

operation of new units could change recreational use of the lake that could be exacerbated in

times of drought (e.g., 15 boat trips a year versus 30).

Management of water resources involves balancing tradeoffs among various and often

conflicting uses. The U.S. EPA, U.S. Army Corps of Engineers, and the Commonwealth of

Virginia have jurisdiction for regulating water use through Federal and State laws. 

With respect to the first point, Lake Anna, which was created for the purpose of providing a

cooling reservoir for the nuclear power plant, has become known for its fishing, water skiing,

recreation, and boating. The values of homes around the lake have consistently increased

since the lake was constructed as a cooling reservoir for NAPS, and, apparently, during the

drought period of 2001 and 2002. The October 2001 through December 2002 extreme drought

that occurred in the region from Georgia to northern Virginia was the worst drought that had

occurred since climate records have been kept in that part of Virginia. As a result of this

climatic anomaly, Lake Anna experienced the lowest lake water levels and lowest estimated

inflows in its history. Although the boat ramp at Lake Anna State Park remained usable

throughout the drought period, some private boat ramps were not usable. Some residences

located adjacent to the lake had mud banks adjacent to their homes because of low lake levels.

Lake water levels quickly increased when normal precipitation levels returned to the region. 

The drought was an extremely rare event and was temporary in nature. Nevertheless, this

period of extreme drought was considered as the critical period in the analysis for hydrological

assessments and impacts to resident fisheries.
Comments Within Scope

NUREG-1811, Volume II 3-178 December 2006

With the change of the proposed Unit 3 cooling system to a closed-cycle system, the staff

determined that additional heat discharged from Unit 3 to Lake Anna from the WHTF would be

negligible, would not increase water temperature appreciably, and would not destabilize the

native fish populations. During the summer when warmer temperatures exist near the

discharge, most of the lake is unaffected by operations, and fish would be able to find sufficient

habitable areas. Additionally, the fish found in the lake most frequently are prolific, exhibit a

high reproductive potential, and modify behavior to offset losses. 

The striped bass is a non-native species introduced into Lake Anna for recreational fishing; it is

a thermally-sensitive fish species and may be the most vulnerable species to thermal stress of

all of the fish species in Lake Anna. The striped bass population is sustained by annual

stocking and provides a “put-grow-and-take” fishery. The staff determined that waste heat input

to Lake Anna from the proposed Unit 3's combination wet and dry cooling system would be

negligible and would not affect striped bass in the reservoir.

With respect to lake level and downstream flows, temporary impacts on recreation are possible

to downstream recreational users during drought conditions and low flows to the Pamunkey

River. The staff concluded that the water supply provided by Lake Anna is adequate to meet

plant and current downstream water demands except during periods of severe drought, such as

that experienced in 2001 to 2002. Through the Lake Level Contingency Plan (a condition of the

NAPS NPDES permit issued by VDEQ), releases from Lake Anna Dam during the 2001 to 2002

drought were reduced to below the normal minimum of 1.1 m3

/s (40 cfs) to 0.57 m3/s (20 cfs). If

such low-flow conditions were imposed during a drought in the future, recreation below the Lake

Anna Dam could be impacted. The staff concluded that the impacts of the operation of Unit 3

on downstream aquatic communities would be SMALL. Low water conditions in 2001-2002

were quickly reversed when normal precipitation levels returned to the region.

Consequently, the staff determined that the water use, from the proposed Unit 3 closed-cycle,

combination wet and dry cooling system would not destabilize the fish populations. During the

summer with warmest water temperatures near the discharge, most of the lake is unaffected by

operations and fish would be able to find sufficient habitable areas. Although some private boat

ramps were not usable during periods of drought, at least the boat ramp at Lake Anna State

Park was. It is unlikely that there would be a significant long-term adverse economic impact on

recreational use of the lake. Some residences located adjacent to the lake had mud banks

adjacent to their homes because of low lake levels. Some of the lakefront property is located

around the WHTF, and it does not appear that property values are harmed by the temperature

of the water. Based on review of assessed values on Louisa County website and records of

mortgage values issued for areas in Louisa County near Lake Anna, 2001-2002 Lake Anna

property values were not adversely affected during the low lake water levels during the drought.

With respect to the second point, Lake Anna has provided recreational opportunities for

thousands of people since its construction as a cooling reservoir for NAPS Units 1 and 2. The
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 December 2006 3-179 NUREG-1811, Volume II

lake has a reputation for its fishing, particularly for largemouth bass and striped bass, and other

recreational pursuits. Recreational use during drought conditions may be temporarily, not

permanently, impacted. Section 5.5.3.4 of this EIS was modified in response to these

comments.

Comment: [T]he recreational lake...would not even be there if it wasn't for nuclear power nor

would their lakefront property and astronomical property values. (ST-0020 6)

Comment: [H]ere we're dealing with a lake as far as I understand is your property, Virginia

Power's property, and I'm also a big advocate of property rights. I don't want somebody coming

and all of a sudden putting constraints on my property. But at the same time, I understand your

wanting to be fair and treat the environment properly and I applaud you for that. (ST-0015 4)

Comment: [T]he recreational lake whose boat traffic is audible from great distances would not

even be there if it wasn't for nuclear power. (ST-0020 5)

Response: Lake Anna, which was created for the purpose of providing a cooling reservoir for

the nuclear power plant, has become known for its fishing, water skiing, recreation, and boating. 

These comments offer no new information. Accordingly, no changes were made to this EIS as

a result of these comments.

3.5.7 Roads and Transportation

Comment: The traffic discussion on pages 2-59 and 4-25 regarding Spotsylvania roads is hard

to understand and I am familiar with the local road network and plans. Presently, Courthouse

Road is 208, not the Spotsylvania Parkway. The Spotsylvania Parkway is significantly north of

route 606. (DW-0438 75)

Response: A correction has been made to the text in Chapters 2 and 4.

Comment: There is no planned Spotsylvania Turnpike exit from I-95 (Page 4-25 line 36). 

(DW-0438 106)

Response: A correction has been made to the text in Chapter 4.

Comment: Section 4.2.2 does not include detailed background transportation counts or LOS

[level-of-service traffic designation characteristics, see Table 2-14, LOS-A through LOS-F,

ranging from free flow to flow breakdown] projections which are typically used to assess

transportation impacts. The suggested methodology is to do a 20-year traffic forecast as the

baseline and then overlay the 2800 vtpd at several instances to assess the impact. 

(DW-0438 91)
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NUREG-1811, Volume II 3-180 December 2006

Response: While the comment proposes a valid methodology, the staff believes that the level

of analysis in the EIS is adequate to make an appropriate determination of the overall impact

level on traffic congestion during construction. Accordingly, no changes were made to the EIS

as a result of this comment.

Comment: The drastic increase of traffic during construction of the power plants will crowd our

highways and pollute our air. (DT-0047 5)

Comment: This makes no sense whatever [that the decision is made on current data],

especially considering that the entire area around Lake Anna, but especially north towards D.C.,

is experiencing one of the highest rates of growth in the country. These localities are dealing

with growth induced problems and financial crises in health, education and transportation right

now, and it does not appear to me that these issues were taken into account by this study, in

particular the transportation issue. Transportation is entirely inadequate for not only

construction phase of the proposed facilities, but certainly in the event of the need for an

evacuation. Virginia does not have the funds for any new transportation projects, and is only

able to finance maintenance work at this time. Where is the money going to come [from to] plan

and build the roads to support the 5000 construction personnel? (DW-0431 3)

Comment: [Regarding Dominion’s Site Safety Analysis.] Section 4, 4.4.1.1.3 Roads - The

transportation network in the Louisa County area is very well-developed, however, new

construction and development in this area has hampered travel on many instances especially

during the peak vacation time around the lake area and also during inclement weather as most

roadways are two lane rural. Further investigation in to this information would be beneficial,

especially with regard to route alerting should it be necessary for any reason during construction

activities as the roadway network could be hampered during construction, should an emergency

event occur. (DW-0191 6)

Comment: Roads and transportation – there are already real problems in the region and this

project will only make them worse (especially during construction or god forbid if an evacuation

is required). Projects of traffic and impacts generated within the 20-year window of the ESP are

not addressed (VTRANS 2025). (DW-0432 2)

Comment: Construction activities associated with adding additional reactor units to the NAPS

site would require an additional workforce of 5,000 (DEIS, § 4.2.2, line 26), bringing the total

peak workforce at the site to 7,000 during reactor outages, requiring roughly 3,900 transport

vehicles (ER, Part 3, Section 4.4.2.2.1(d)) – representing a “major increase in traffic” in certain

places (draft EIS, page 4-24, lines 4-5). Despite this dramatic increase in traffic to and from the

site, the draft EIS describes the transportation impacts of the proposed action to be “small” and

proposes no additional mitigation measures beyond Dominion’s traffic management plan (draft

EIS, § 4.2.2, lines 5-8), which may not fully alleviate traffic congestion (page 4-23, line 35).

There are no plans to build new roads or alter current roads, despite existing congestion on
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 December 2006 3-181 NUREG-1811, Volume II

roads around Lake Anna (draft EIS, page 4-19, line 17). Would not this dramatic increase in

traffic alter the “rural character” of Louisa County that the Louisa County Board of Supervisors

wants to preserve (draft EIS, page 4-17, lines 14-16)? (DW-0437 48)

Comment: [H]ow can the NRC claim to predict the sufficiency of existing regional roads to

support construction activities, considering that the potential for a dramatic increase in

population over the next 20 years (see draft EIS, Table 2-5), the duration of the ESP? 

(DW-0437 49 and DW-0437 50)

Comment: A measure propounded in the Draft EIS to mitigate traffic impacts from the

construction of new reactors at the North Anna site is the widening of a country road, SR 700

(page 4-24, lines 30-32). For what section and length of roadway would this be required, and

what environmental impacts would be expected? What would be the impact on property owners

along the route? (DW-0437 51)

Comment: Page 2-5 line 30 rightfully states that “the land adjacent to Lake Anna is becoming

increasingly residential as the area is developed.” No new transportation routes (roads or

railroad lines) or new industrial activities are currently planned in the vicinity...” The

combination of increased population without increased transportation for emergency

egress/ingress could be a recipe for disaster even without the proposed nuclear expansion. 

This DEIS statement itself is enough basis to reject the later conclusion that impacts on

transportation and the human environment are small. (DW-0438 15)

Comment: Page 2-57 line 34 acknowledges that there are only two major freeways in the area. 

The impact on these thoroughfares and their feeder roads during an evacuation is not really

addressed in Sections 4-7. (DW-0438 72)

Comment: Along the lines of the prior comment, Sections 4-7 does not address the impacts to

the commuter roads listed on page 2-58 line 6. (DW-0438 73)

Comment: Page 2-58 line 13 acknowledges that the Thornburg area is getting congested. 

This is a major route to/from Lake Anna and there currently are no funds dedicated to the

needed improvements. (DW-0438 74)

Comment: Section 4.2.2 states that Construction impact on transportation is SMALL. The text

(“2800 vehicle trips per day” roadways would experience congestion, “five existing roads are

expected to be impacted”) does not support this conclusion and seems to indicate a LARGE

local impact. (DW-0438 90)
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NUREG-1811, Volume II 3-182 December 2006

Comment: The conclusion of SMALL impact for Section 4.5.1.3 is not supported by the text or

the actual situation in the region. There is little to no funding for road expansions. The

VTRANS 2025 report shows that gridlock is expected on major roads and at major

interchanges. (DW-0438 98)

Comment: In Section 4.5.1.3 local officials are cited as being of the belief that road alterations

need to be evaluated “prior to construction.” This does not mean that this issue should be

deferred to the CP/COL stage – local access and the impacts on transportation are clearly site

related issues and should be thoroughly evaluated at this time. (DW-0438 99)

Comment: The conclusion of SMALL impact for Section 4.5.3.2 is not supported by the text or

the actual situation in the region. There is little to no funding for road expansions. 

(DW-0438 103)

Comment: The Spotsylvania road improvements on page 4-25 line 7 are not fully funded and

thus may not occur or may be delayed. (DW-0438 105)

Comment: Page 4-25 line 39 acknowledges that the I-95/606 interchange is congested at

“LOS D or worse.” Line 13 acknowledges 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. (DW-0438 107)

Comment: The assumption in 5.5.1.3 that “any needed upgrades in the road system would

have been made” is flawed. This assumption leads to the DEIS conclusion that road impacts

are SMALL. Funds for transportation in Virginia are seriously constrained. The analysis should

be re-done without this assumption. (DW-0438 148)

Comment: The sentence starting on Page 5-43 line 39 is too speculative and should be

deleted. (Also, road improvements undertaken to alleviate congestion during the construction

phase of the project could alleviate or minimize any congestion around the lake as a result of

new employees and their families.) (DW-0438 155)

Comment: The EIS basically says that all the road problems will be fixed to support transport

of the huge number of construction personnel but there is no connection to the current reality in

Virginia that there is limited or no money for roads. The VTRANS 2025 report is an unbiased

view of the future of traffic and roads in the area and it predicts almost total gridlock along the

I-95, US1 corridor within the life of the proposed project. (DW-0594 15)

Comment: According to the Virginia Department of Transportation (VDOT), the SDEIS makes

reference to several plans and recommendations for roadway improvements in the Lake Anna

area of Louisa County, and acknowledges that these plans are not tied to any time frame or

funding source. (SW-0017 77)
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 December 2006 3-183 NUREG-1811, Volume II

Comment: VDOT does not now have any plan for improving the road network in the project

area. The proponents of some developments are proposing road improvements; the largest of

these is the Cutalong Club development, whose proponents hope to move the connection

between Routes 208 and 652 to eliminate the skewed intersection and add the required turning

lanes at the intersection. These plans are under design and are proposed for construction in

the next several years, according to VDOT. (SW-0017 78)

Comment: VDOT indicates that it intends to work with Dominion, the applicant, to ensure that

roads in the vicinity of the North Anna Power Station are maintained and that necessary

improvements are in place prior to any major activities at the project site. VDOT has requested

a traffic impact analysis from Dominion; this would compare the future background traffic in the

area with future traffic including construction traffic ("total traffic"), and would identify areas of

impacts. The impacts -- some of which would be temporary, from construction, and some of

which would be permanent - are the responsibility of Dominion. The traffic impact analysis

should also provide mitigation measures to reduce the impacts. (SW-0017 81)

Comment: The EIS basically says that all the road problems will be fixed to support transport

of the huge number of construction personnel. This is contrary to the current reality in Virginia

which is that there is limited or no money for roads and the needs are great throughout the

region. (SE-0049 3)

Comment: Table 10-1 acknowledges that increased traffic congestion is unavoidable. This is

not congruous with the SMALL impact determination. (SE-0045 42)

Comment: 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. (SE-0045 43)

Comment: The transportation section is totally deficient. There is currently insufficient

infrastructure to support the construction workforce or handle an evacuation. (SE-0045 5)

Comment: We request that Virginia DOT upgrade the roads at the lake so that they are

adequate for evacuation of the current and expected populations. We request that VDOT,

Dominion, and the public develop a traffic management plan relevant to evacuation. 

(ST-0004 7)

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the ESP]...You

have the impact of 5,000 – 7,000 new workers (construction, periodic maintenance,

professional) employees for 5 years on local roads and schools... This will create the need for

new expanded roads before the project begins because of the workers and the three newly

approved Louisa County subdivisions for about 1800 new homes in close proximity to the plant. 

(SE-0022 25) (ST-0014 13)
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NUREG-1811, Volume II 3-184 December 2006

Comment: Too many workers & residents, with a small 2-lane road (Route 652 Kentucky

Springs Road). Dominion plans to bring in 5,000 construction workers. for a five (5) year period

for the new plant. ...They will add about an additional 720 permanent workers when the new

third reactor is activated. ...Pro-offers should be made by Dominion and/or Federal Government

to widen Route 652. . . [prior to beginning of construction or we will experience a traffic

nightmare. (SW-0005 2) (SE-0003 1)

Comment: A more thorough EIS would tell us what the data is from VDOT on the level of

service rating for the roads, what their carrying capacity is, and how the project laid over that

would support or worsen the traffic situation. (ST-0036 5)

Comment: They [those opposing the ESP action on the basis of transportation impacts] forget

that Rt. 652 was a dirt road before nuclear power. (ST-0020 7)

Comment: There's been no real analysis of transportation, whether for a construction

workforce of 5,000...if you live in the area or read the newspaper, or even just drive on 95, you

know that transportation congestion is one of the biggest problems in the region. There's little to

no funding for new roads and improvements. (ST-0036 3)

Comment: [Regarding Dominion’s ER] How would this large increase in work force and their

families effect the traffic patterns on existing two lane roads around the lake? Particularly

during the summer months when large boats and recreation trailers crowd the roads already. 

(SE-0004 16)

Comment: [Regarding Dominion’s ER] Table 3.1-1 Number of people to operate plants 3 and 4

only is 1160 people. During construction what is the maximum number of people including

operation type on board (ie max at any one time)? Could the indicated 5,355 construction

workers overlap the 1160 operations people? (SE-0004 15)

Response: Collectively, this group of comments makes six main points. First, the commenters

state that the region is one of the fastest growing regions in Virginia and that Spotsylvania

County, for example, has grown 25 percent in population from 2000 to the end of 2004. 

Second, the commenters indicate that many of the highway systems in the region are already

crowded and that increased growth in transportation associated with population growth would

only make conditions worse; the commenters suggest that adding 5000 construction workers to

the existing 720-member operations workforce at NAPS Units 1 and 2 and to the 700 to 1000

temporary workers employed during refueling would only exacerbate the situation. The

commenters also indicate that, during the peak vacation season, travel around Lake Anna is

already hampered. Third, the commenters state that just because a road or highway is on a list

to be upgraded in the future does not mean that it will happen. The commenters also indicate

that funding for road improvements in Virginia is constrained. Fourth, the commenters indicate

that the description of some of the highway construction plans for the area need to be updated

to reflect the plans of the recently released “Virginia Transportation 2025" report (VTRANS
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 December 2006 3-185 NUREG-1811, Volume II

2025). Fifth, commenters stated that projections of traffic impact through the 20-year duration

of an ESP were not addressed. Sixth, the commenters suggest that the transportation system

is not adequate now to handle an evacuation.

Regarding the first two points, the Richmond-to-Fredericksburg area is one of the fastest

growing areas in the Commonwealth of Virginia. This means that some of the roads in the area

are already congested and, absent any action to alleviate the congestion, will only get more

congested. Consequently, action is necessary to alleviate the forecasted congestion

independent of any additional traffic associated with the construction of any additional nuclear

units at North Anna. The issue is whether the traffic from a construction workforce would

significantly increase this congestion and result in a MODERATE or LARGE impact, rather than

SMALL to MODERATE.

The staff evaluation shows that 5000 (maximum) commuting workers to the NAPS site would

not significantly affect the transportation system in the region. There are several reasons for

this conclusion. First, the staff estimates that 80 percent of the construction workforce already

lives within the 80-km (50-mile) region. Therefore, a large portion of the workforce commuting

pattern is accounted already in the existing traffic congestion. Second, several commuting

routes to the NAPS site exist. It is highly unlikely that the entire construction workforce will use

the same commuting route, especially the heavily traveled I-95 corridor. Third, the commuting

pattern of the construction workforce would be distributed over the multiple shifts that would be

staffed during a 24-hour period. Conservatively, assuming that there would be two 10-hour

shifts and that all of the construction workforce drives separately, then a maximum of

approximately 2500 automobiles would be traveling to the ESP site at any one time. In reality,

the total number of automobiles on the road at one time would be less because the work shifts

for numerous construction activities overlap, a proportion of the workers share rides, and all

shifts do not begin at the same time for each construction activity. In conclusion, the impacts of

the construction workforce traveling to and from the ESP site, given the expected conditions

and for the reasons stated, are not expected to have a significant impact on the regional

transportation system. This does not mean that there would be no additional congestion around

the NAPS site entrance at shift changes or that traffic congestion is not a problem around Lake

Anna during peak vacation periods. However, as stated in the EIS, the congestion can be

mitigated using measures described in the EIS and in Dominion’s ER.

On the third issue, the VTRANS 2025 report acknowledged that funding for road improvements

in Virginia, now and in the future, is constrained. However, this does not change the conclusion

that impacts of the commuting construction workforce on the regions transportation system

would be SMALL for the reasons given in the previous paragraph.
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NUREG-1811, Volume II 3-186 December 2006

Regarding the fourth issue, in the time frame that the Draft EIS was prepared for issuance, the

VTRANS 2025 report and other supporting documents were not available. Subsequent to their

release, this EIS has been updated to reflect the current Commonwealth of Virginia, Department

of Transportation construction plans. For example, activity continues on construction

preparation for SR 208 in Spotsylvania County, which is to be advertised for construction bids in

July 2007.

With respect to the fifth issue, the staff projected the transportation impacts in Sections 4.5.3.2

for construction activities and in Section 5.5.3.2 for operational activities. The staff concluded

that, if the planned upgrades and improvements to the road systems and Dominion’s traffic

management mitigation plans were implemented, then the temporary impacts of construction on

traffic in the region would be SMALL to MODERATE. The permanent impacts of operation on

traffic in the region could not exceed the temporary impacts of construction if mitigation plans

were implemented.

Finally, while concerns about emergency evacuation are outside the scope of this EIS, to the

extent that they relate to the ESP application and not to NAPS Units 1 and 2, they are

addressed in the ESP Safety Evaluation Report (SER) (ML051250112).

Comment: This DEIS wording suggests that accessibility to the site would be restricted for

heavy loads unless Route 700 is substantially upgraded. The condition of Route 700 between

Route 652 and the site was discussed with the VDOT (Fluvanna and Louisa District)

representative. This road has been upgraded with a fairly thick layer of asphalt that is capable

of handling a number of heavy vehicles such as cement trucks, if needed. That is, it is not the

same thin layer of asphalt/chips that is typical of local roads and that would easily be torn up

with passage of a number of such trucks. Route 652 also has been upgraded with the heavier

layer of asphalt. (Note that Route 700 west of the intersection with Route 652 is a typical local

road.) [page 4-19, line 6] (DW-0423 25)

Response: The condition of State Route (SR) 700 between SR 652 and the site has been

substantially upgraded compared to SR 700 between SR 618 and SR 652; the SR 700 roadway

between the SR 618 and SR 652 is the portion of the road that the staff identified as in need of

an upgrade to handle heavy construction traffic. Section 4.5.1.3 of this EIS has been changed

to reflect the upgrade of a portion of SR 700 and SR 652.

3.5.8 Site Aesthetics

Comment: 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. 

(SE-0045 20)
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 December 2006 3-187 NUREG-1811, Volume II

Comment: Dominion is planning on constructing cooling towers that will be between 150 and

180 feet (15 - 18 stories) in height. ...Current trees in area are approximately 50 feet to 75 in

height, with a few going up to about 100 feet. ...It is requested that the cooling towers be no

higher then 80 feet (equivalent of an 8 story building) to...provide an esthetically pleasing profile

of the adjoining skyline. (SE-0003 6)

Comment: [Regarding Dominion’s ER] Same section as 4 [paragraph 3.1.2.2]. Unit 3

combined wet and dry cooling towers will be 180 ft tall. We were told the height would be much

lower about 60 feet tall. During a formal presentation to the public and press by Eugene S.

Grecheck, Vice President- Nuclear Support Services on January 6, 2006, we were told the

cooling towers would be less than 75 feet tall for wet/ dry units and 50 feet for the dry only unit. 

Why did this change to 180 feet? Unit 4 dry towers will be 150 feet tall. (SE-0004 12)

Comment: As stated in Revision 7, combination wet and dry towers would be used for Unit 3

only. Dry towers would be used for Unit 4. The dry tower proposed for Unit 4 would be an

expected 150 ft (46 m) tall. However, the combination wet and dry cooling towers for Unit 3

would have an expected maximum height of 180 ft (55 m). (SE-0050 7)

Comment: Towers extending above the tree line and up to 180 ft above ground level would

represent site pollution to many residents of Lake Anna...The cooling towers should be kept to a

height so as not to be visible from beyond the Dominion property line. (SE-0012 4)

Comment: Why is the building 100 feet taller than the current one? The buildings should not

be higher than the current tree lines surrounding the property. (SE-0007 5)

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the

ESP]...Height of dry and wet cooling towers and facility buildings should not exceed the tree

line to protect the rural esthetic atmosphere of the community as Dominion indicated in Jan 06

stakeholder meeting. (SE-0022 24) (St-0014 12)

Comment: These heights are too tall. The cooling towers should not exceed the 80 foot height

of the tree lines surrounding the NAP for shielding them from view. (SE-0004 13)

Comment: Dominion is planning on constructing cooling towers that will be between 150 and

180 feet (15-18 stories) in height. ...A 180-foot (about an 18 story building) would be an

eyesore. (SW-0005 5)

Response: The North Anna site is zoned “industrial,” and it is not expected that the visual

impact would be appreciably different than the current visible structures onsite. There are no

standards for visual intrusion of industrial structures. Section 5.5.1.4 in this EIS acknowledges

that the cooling towers extend above the treeline, even though they are partially screened. This
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NUREG-1811, Volume II 3-188 December 2006

section also describes the visual impact of the steam plume from Unit 3. The impacts are

described as MODERATE: they would be noticeable, but would not destabilize important

aspects of the resource.

Comment: [Regarding Dominion’s ER] Par[agraph] 3.1.2.2 New Unit Description. Please

explain in detail “An operating unit or group of modules.....The structure would consist of

between 1 and 8 reactors or reactor modules structured around a common support

operations.... Are plants 1 and 2 structured like this now? Will there be up to eight concrete

domes for each plant? (SE-0004 11)

Response: The existing units consist of one reactor per unit. For the proposed ESP units, the

PPE approach provides the flexibility for the applicant to select from a number of different

designs. Some designs such as the ESBWR and AP1000 have one reactor per unit. Others

such as the PBMR can have multiple reactors or modules per unit. The PPE limits a unit to a

total thermal output of 4500 MW(t) and can include any number of reactors. The external

design has not been selected; however, for bounding evaluation, the PPE limits the maximum

height of the reactor building to 234 ft to accommodate the possible selection of the AP1000

reactor design. Other designs, including the modular designs, would likely be considerably

shorter.

3.5.9 Other Comments

Comment: These possible negative impacts [of construction and operation] will...[affect] the

human community who call Lake Anna and Mineral home. (DW-0817 4)

Response: The comment did not identify any specific deficiency or raise any specific question

regarding the socioeconomic analysis. Sections 4.5 and 5.5 of the EIS address the

socioeconomic impacts on the region surrounding the North Anna ESP site, including the Lake

Anna and Mineral communities. The impacts were generally found to be SMALL, or at most

MODERATE in a few cases. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: Page 2-48 mentions Paramount’s Kings Dominion. Have they been directly

consulted about the likely impacts of the proposed project on their facility and its use? 

(DW-0438 63)

Response: The NRC staff did not contact Paramount directly. However, information related to

the number of visitors to the facility was useful in assessing the transient population in the

region. Paramount’s internet website was accessed to obtain information on park attendance

(see Section 2.8.1.1). Accordingly, no changes were made to this EIS as a result of this

comment.
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 December 2006 3-189 NUREG-1811, Volume II

Comment: Page 2-48 states that Kings Dominion usage rates “could” slow in the future. They

easily “could” increase or remain stable, depending on the regional economy, the success of the

Kings Dominion’s marketing efforts, and any impact that the proposed project would have on

the region. (DW-0438 64)

Response: The source for the representation that the usage rates could slow in the future for

King’s Dominion is its public relations officer; this was stated in the Dominion ER. Accordingly,

no changes were made to this EIS as a result of this comment.

Comment: Page 2-55 states that Louisa County would like to lessen its dependence on NAPS

through diversification of the local economy. The proposed project would be counter to this

local goal. What mitigation measures is the applicant proposing to foster the County’s

diversification goals? (DW-0438 68)

Response: Dominion has not proposed any mitigation measures to foster Louisa County’s

diversification goals. The economic stability already afforded by the operation of NAPS Units 1

and 2 has allowed the County to build an industrial park and to begin an economic development

program; any additional nuclear units would be expected to enhance the program. The most

recent success of Louisa County’s efforts to diversify the economy was its ability to attract the

Wal-Mart distribution center at Zion Crossroads. Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: Page 4-24 line 9 states that mitigation measures would be required. These

measures should be detailed now and included in the DEIS. (DW-0438 104)

Response: Several mitigation measures are identified in Section 4.5.3.2 in the EIS. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Change the word “could” to “would” on Page 5-41 line 18. (DW-0438 152)

Response: Dominion’s participation in managing traffic congestion should be coordinated with

the agencies of the Commonwealth of Virginia and local government authorities. The word

“could” states Dominion’s intent and provides flexibility for Dominion and other governmental

agencies to consider and implement such mitigation measures that may be more effective in the

future, in accordance with State and local laws. Accordingly, no changes were made to this EIS

as a result of this comment.

Comment: The socioeconomic sections of the DEIS are unfortunately weak. The DEIS thus

cannot be used as an effective decision-making tool. (DW-0438 56)

Response: The comment did not identify any specific deficiency or raise any specific question

regarding the socioeconomic analysis. Sections 4.5 and 5.5 of the EIS address the

socioeconomic impacts on the region surrounding the North Anna ESP site, including the Lake
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NUREG-1811, Volume II 3-190 December 2006

Anna and Mineral communities. The economic analysis developed a baseline condition of the

socioeconomic conditions in the region (80-km [50-mi] radius) using the most recent information

available from official data sources, plus extensive information obtained from interviews with

representatives of the local governmental and private sector during the conduct of the NRC

review. This information is reflected in Section 2.8 of the EIS. Thereafter, analyses were

performed to evaluate potential socioeconomic impacts of construction (Section 4.5) and

operation (Section 5.5) at the North Anna ESP site. Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: Page 4-22 line 17 seems to indicate that the NRC consulted primarily with

Dominion in assessing whether there is a sufficient labor force. Independent analysis should be

done especially since the residential and commercial construction markets have taken off since

the December 2003 survey. (DW-0438 102)

Response: The NRC places the initial burden to represent current conditions and potential

impacts that could result from the construction and operation of the facilities contemplated on

the proponent of the action (in this case, Dominion). Upon receipt of the ESP application, the

NRC staff independently assesses the applicant’s representation, including developing

independent sources and identifying new information that may be relevant to the staff’s analysis

of impacts. In its ER, Dominion asserted that a sufficient construction work force would be

available in the region. Section 4.5.3.1 of the EIS states that “[T]hrough information obtained

from the interviews conducted during the December 2003 site visit, the staff confirmed that a

sufficient number of construction workers would be available to meet the expected demand.” 

The analysis was based on published sources and the staff’s interviews with local planning

agencies in the area, county planning departments, and economic development organizations,

and published sources. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: Dominion Resources / Virginia Power gave up the right to fence off, or cause either

of the reservoirs to become recreationally unusable short of a nuclear disaster. In fact

Dominion Resources / Virginia Power encouraged the use of the reservoirs for recreation

liberally allowing access, and individual investment and construction of marinas, homes, docks,

boathouses etc both on the main lake and the cooling lagoons. (SW-0015 4)

Response: Virginia Power and Old Dominion Electric Cooperative own all the land within the

NAPS boundary, both above and beneath the water surface, including those portions of Lake

Anna and the waste heat treatment facility that lie within the site boundary. They also own the

land outside the NAPS boundary that forms Lake Anna, up to the expected high-water mark. 

The only projected adverse impact on recreation from the proposed Unit 3 is that the it could

slightly exacerbate water level decreases during times of drought. The recreational impacts are

discussed in Section 5.5.3.4 of this EIS. Accordingly, no changes were made to this EIS as a

result of this comment.
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Comment: Towers extending above the tree line and up to 180 ft above ground level

would...represent a possible hazard to aircraft as structures of 180 ft would probably be the

tallest large structures in Louisa County. (SE-0012 5)

Response: The Federal Aviation Administration has cognizance over the intrusions into

navigable air space. Its regulations at 14 CFR Part 77, “Objects Affecting Navigable Airspace”

deal with construction requiring notice to the Administrator prior to beginning construction. 

Notice to the Administrator in the event that an structure exceeds 200 feet above ground is

included in the list of Authorizations and Consultations in Appendix L. Accordingly, no changes

have been made to the EIS as a result of this comment.

3.6 Historic and Cultural Resources

Comment: [W]hat is the nature of the communications with Native American tribes that have

concluded the probable absence of any significant traditional properties or cultural resources?

(DW-0437 54)

Comment: Why not stipulate the need for cultural resource assessments now (Page 4-35

line 37)? (DW-0438 112)

Comment: Parts of the North Anna site that would be used for new reactors and related

facilities have been identified as having a “Moderate-to-High” potential for containing historic or

cultural resources (EIS, page 4-35, lines 33-39). What is the basis for this assessment, and

what sort of mitigation measures would be employed should such resources be discovered? 

(DW-0437 53)

Comment: Page 2-72 line 26 mentions that some undisturbed areas have some potential for

cultural resources. I was unable to find in the DEIS a statement that these areas would be

examined and cleared prior to any site work occurring there. (DW-0438 80)

Response: Ground-disturbing activities for previously undisturbed land may never occur. 

Therefore, stipulating a cultural resource assessment is premature. However, as described in

Section 4.6 of this EIS, Dominion recently commissioned an archaeological survey for the ESP

site. With the exception of two previously recorded cemeteries, no artifacts, cultural features, or

cultural deposits were identified during this field survey. The staff concluded that there would

be no adverse effects upon historic and cultural resources resulting from construction and

operation of the proposed Units 3 and 4 and assigned an impact level of SMALL. Previous

studies leading to the assessment of lands with potential for unrecorded cultural resources at

the North Anna plant site are referenced in Section 2.9.2 of this EIS. Dominion would consult

with the Virginia Department of Historic Resources regarding the need for and types of cultural

resource investigations prior to undertaking any ground-disturbing activities at the ESP site on

land that was previously undisturbed. Any field survey, documentation and evaluation of
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NUREG-1811, Volume II 3-192 December 2006

cultural resources, and mitigation of potential impacts would occur prior to ground-disturbing

activities. The existing NAPS site has a Work Procedure that would initiate a stop-work order

during construction activities if a previously undetected cultural resource is discovered. The

ESP applicant would adopt a similar procedure. Accordingly, no changes were made to this EIS

as a result of these comments.

Comment: The Nuclear Regulatory Commission is consulting directly with the Department of

Historic Resources pursuant to Section 106 of the National Historic Preservation Act

(NRC 2005). The Department expects this consultation to continue. (DW-0439 28)

Comment: The Department of Historic Resources (DHR), which is the State Historic

Preservation Office in Virginia, has previously advised NRC and the applicant that a

Programmatic Agreement is necessary between NRC, DHR, and other consulting parties if the

NRC does not wish to complete the identification and effect process pursuant to section 106 of

the National Historic Preservation Act. (SW-0017 73)

Comment: The SDEIS indicates that an archaeological site assessment has been conducted

on the project property in question (Voight, 2003), and that portions of the property appear to

retain the potential to contain intact archaeological resources (pages 2-18 and 2-19, section

2.9). This suggests that NRC and the applicant wish to complete the section 106 process prior

to permitting, rather than to address NRC's responsibilities programmatically. However, DHR

had not, as of its August 9 letter to NRC (enclosed), received the report of the assessment and

cannot, therefore, comment on the report's conclusions. DHR recommends that NRC submit

this report to DHR to allow its comment on the need for further studies of identification and

evaluation of archaeological resources. (SW-0017 74)

Comment: In the absence of an executed Programmatic Agreement or the completion of the

section 106 process, as prescribed in the regulations at 36 CFR Part 800, the Department of

Historic Resources finds the NRC's site redress plan to be insufficient to fully consider the

project's effects on historic properties. Continued consultation, however, is expected to resolve

the matter. (SW-0017 75)

Response: Pursuant to 36 CFR 800.8, the NRC has completed its Section 106 consultation

under the provisions of the National Historic Preservation Act (NRC 2005). Dominion has

completed the archaeological field assessment for all lands included in the ESP area of

potential effect [APE] at the North Anna Site. The field survey of this acreage revealed no

historic properties that would be adversely affected by the proposed project activities. The final

written report was submitted to DHR on September 21, 2006. During a follow-up teleconference

on October 12, 2006 between NRC and DHR, DHR staff indicated that the survey report was

sufficient to allow NRC to complete the Section 106 consultation responsibilities. Appropriate

revisions discussing this survey have been made to Section 4.6 of the EIS. Documentation of

the consultation process is included in Appendix F of the EIS.
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 December 2006 3-193 NUREG-1811, Volume II

3.7 Environmental Justice

Comment: I appreciate the section on Environmental Justice in plant siting. How does the

conclusion reached therein mesh with the statement on page 2-55 line 29 that Louisa County

(where the project would be sited) has the second highest poverty rate and second lowest

median income? (DW-0438 66)

Response : For purposes of the staff’s NEPA review, a low-income population is defined to

exist if the percentage of low-income population within a census block group exceeds the

corresponding percentage of low-income population in the State (if the 80-km [50-mi] radius

from the site is entirely in one State) by 20 percent, or if the corresponding percentage of

low-income population within a census block group is at least 50 percent. For counties and

census block groups within an 80-km (50-mi) radius of the NAPS ESP site, the percentage of

minority and low-income populations is compared to the percentage of minority and low-income

populations in Virginia and Maryland, as applicable.

In Louisa County, the estimated percent of the county population that falls into the poverty level

is 10.2 percent compared with 9.6 percent for Virginia, based on Census 2000 data, thus falling

below the applicable percentage for low-income population to be considered. No census block

groups in Louisa County met the criterion for low income. Louisa County has the secondhighest poverty rate of the nearby counties, but the rate is not particularly high. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: [Regarding Dominion’s Site Safety Analysis.] Section 4.4.3 - Environmental Justice

Impacts - In this section the information only mentions the potential for disproportionately high

and adverse human health or environmental impacts on minority and low-income populations

that reside within an 80-km (50 mile) radius of North Anna during construction. This information

could be construed as discriminatory. This implies that only minorities and low-income

individuals reside within a 50-mile radius to the plant or that the implications and analysis was

only performed on impact to low income residents located within this area and that other

populations within this region were not considered. However, again the information mentioned

in Section 2.5 is current data with regard to this information. I would suggest that the NRC take

a very wholesome look at this population data and the potential effects on the entire population

within this region of 80-km (50-mile radius) of the plant. With the increased development within

this region some of the housing developments and homes around Lake Anna are valued up to

and well over [$300,000]. There are also several very large housing developments and

expensive farm operations within this area that do not seem to be considered in this evaluation

in the areas of Louisa, Orange, Spotsylvania, Hanover, Montpelier, Charlottesville, and

Goochland. (DW-0191 9)

Response: As stated in Section 2.10 (Environmental Justice) of the Draft EIS, Environmental

Justice refers to a Federal policy under which each Federal agency specifically identifies and
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NUREG-1811, Volume II 3-194 December 2006

addresses, as appropriate, disproportionately high and adverse human health or environmental

effects of its programs, policies, and activities on minority and low-income populations, in

addition to the evaluation that considers all affected populations. 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. The

CEQ has provided guidance for addressing environmental justice, and although the

Commission is not subject to the Presidential Executive Order mandating environmental justice

review, the NRC has voluntarily committed to consider environmental justice in its NEPA

environmental reviews. This was recently affirmed in an updated Commission policy statement

issued in August 2004 (69 FR 52040). In its environmental reviews, the NRC considers the

demographic and economic circumstances of local communities where nuclear facilities are to

be sited, and takes care to ensure that the license applicant mitigates or avoids special impacts

attributable to the special character of these communities.

The impact analysis was not restricted to low-income and minority populations in the analysis of

the North Anna ESP. For example, the entire population within a 50-mi radius is evaluated with

respect to radiological health impacts of plant operations. The low-income and minority

populations are specifically analyzed to ensure that they are not being disproportionately

impacted, when compared to other population or income groups, by the plant’s siting.

In its EIS, the staff recognizes that more expensive homes are located around Lake Anna and

Lake of the Woods, and that some areas within Orange, Louisa, and Spotsylvania Counties are

developing rapidly. The construction and operation of North Anna Units 3 and 4 would likely

add to this development, putting upward pressure on home values within these communities,

until new construction begins to fill any initial shortages of housing that might develop. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The data used in the determination of populations -of-Environmental-Justice

concern is out dated. The assessment needs to be redone using the most recently available

census information (2000 Census data). (SE-0030 11)

Response: Because the description of environmental justice in Section 2.10 of this EIS clearly

identifies the 2000 Census as the basis for analysis, the comment appears to be incorrect. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The Environmental Justice assessment provided in the document is vague. Little

information of use is provided, and no documentation is presented to support conclusions. It is

difficult to determine if the conclusions drawn in this document are valid based upon the scarce

information provided related to potential impacts and target populations. (SE-0030 12)

Comment: [Comment assumed to relate to environmental justice due to order of comments] It

is not clear as to the methods used to determine the level or degree of impact anticipated. 

What are the criteria upon which the conclusions are based? (SE-0030 14)
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 December 2006 3-195 NUREG-1811, Volume II

Response: For purposes of the staff’s NEPA review, Dominion followed the convention of

including census tracts and employing census block groups in its assessment. The NRC staff

reviewed Dominion’s assessment and conducted its own review in conjunction with an

evaluation of socioeconomic aspects of the region. The staff interviewed local government

officials and the staff of social welfare agencies concerning potentially disproportionate impacts

to low income and minority populations. The staff did not identify any location-dependent

disproportionately high and adverse impacts affecting these minority and low-income

populations. This description including maps of the minority populations and low-income

populations are provided in Section 2.10 of this EIS. Accordingly, no changes were made to

this EIS as a result of this comment.

Comment: The listing of groups and organizations contacts lacks representative groups from

the Environmental Justice and grassroots community. While a number of tribes were listed in

the contacts list, the listing lacked local community-based organizations, local churches and

other groups traditionally associated with the Environmental Justice movement. ...It is strongly

suggested that a more comprehensive outreach and community involvement plan be instituted. 

(SE-0030 13)

Response: The NRC publicizes every one of its public meetings through official means and is

receptive to public participation. The NRC takes additional measures to ensure that all of the

local communities have the opportunity to become aware of the public meetings to discuss the

North Anna ESP application. For the environmental review, the first meeting was a scoping

meeting in December 2003, the second was in February 2005 on the Draft EIS, and the third

was in August 2006 on the SDEIS. In addition to the notice at the NRC website, in the Federal

Register and the issuance of press releases, these meetings were widely advertised in

newspapers throughout the region of interest (The Richmond Times-Dispatch, The Daily

Progress, The Free Lance Star, and The Central Virginian), through flyers posted in Louisa and

Orange Counties and through announcements on radio stations in the area. Known public

interest groups were also alerted to the meetings by the meeting facilitators. The Draft EIS and

Supplement have been available for public review at the Louisa Public Library and on the NRC

website, and a copy of the Draft EIS and SDEIS were made available to anyone who requested

it. The scoping meeting and the meeting on the Draft EIS and Supplement occurred during

specified comment periods so that interested members of the public could attend and share

their insights; even if a person could not attend either of these meetings, the official comment

period remained opened for a period thereafter to afford the public the opportunity to share

information with the NRC. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: What is the rationale of using national averages for the assessment of minority and

low-income populations? The comparison of community data to national averages alone seems

unreasonable. ...It is much more appropriate from a statistical point of view to use state and
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county level benchmarks. ...In view of the fact that the poverty level differs from one state to

another, it would seem more reasonable that the assessment would use state level data. 

(SE-0030 10)

Response: For purposes of the staff’s NEPA review, the NRC staff reviewed Dominion’s

assessment and conducted its own review of socioeconomic aspects potentially related to

environmental justice in the region. The evaluation was conducted primarily within the 50-mile

region surrounding the North Anna site. A description of the affected environment including

maps of the minority populations and low-income populations are provided in Section 2.10 of

this EIS where it is clear that state averages, not national averages, were the basis of

comparison. Accordingly, no changes were made to this EIS as a result of this comment.

3.8 Site Redress Plan

Comment: Dominion claims that it has made no decisions about building new reactors at North

Anna. Yet, an ESP is a “partial construction permit,” meaning that Dominion would be allowed

to carry out large-scale construction operations, including site clearing, stream clearing, and

excavation, as well as construction of permanent foundations, intake structures, and outfall

structures. (DW-0437 3)

Comment: Abstract page iii line 10 et. seq. states “that the proposed action does not include

any decision or approval to construct or operate one or more units.” This is misleading since a

lot of construction is permitted by the ESP. To the layman it seems that all but the nuclear

reactor itself could be permitted by the ESP. (DW-0438 4)

Comment: The draft environmental impact statement fails to consider or to fully acknowledge

numerous environmental issues that indicate that the North Anna site is not suitable for

additional reactors. It has been said that these issues are not as critical now since the ESP

would not permit full construction, but if the ESP is granted, “site preparation and preliminary

construction activities” can be carried out, including site clearing, stream clearing, and

excavation, as well as construction of permanent foundations, intake structures, and outfall

structures. (DW-0401 2)

Response: The EIS states that site preparation and preliminary construction activities are

allowed if a redress plan is part of an approved application for an ESP. Allowable activities are

enumerated in 10 CFR 50.10(e)(1) and authorized by 10 CFR 52.25 upon issuance of an ESP. 

The site preparation and limited construction activities that could be allowed with an ESP

specifically do not include safety-related structures, such as the containment building housing

the reactor. Therefore, certain activities would be permitted, as discussed in Section 4.11 of

this EIS, so that, if the activities were actually undertaken, but the ESP expires before it is
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 December 2006 3-197 NUREG-1811, Volume II

referenced, then redress carried out under the plan should achieve an environmentally stable

and aesthetically acceptable site condition. Accordingly, no changes were made to this EIS as

a result of these comments.

Comment: This DEIS wording is inconsistent with 10 CFR 50.10(c)(1) which allows “changes

desirable for the temporary use of the land for public recreational uses, necessary borings to

determine foundation conditions or other preconstruction monitoring to establish background

information related to the suitability of the site or to the protection of environmental values.” 

Drilling for samples/monitoring wells or additional geophysical borings is not listed in Part 4,

Section 1.1, of Dominion’s ESP application or in DEIS Section 10.1. [page 4-45, lines 19-21, 38] 

(DW-0423 27)

Response: There are a variety of activities that are undertaken to characterize the site as part

of the ESP application process; some of these activities are performed for safety purposes and

are addressed in the applicant’s Safety Analysis Report and evaluated in the NRC staff’s Final

Safety Evaluation Report (FSER). Those site characterization activities that have a bearing on

the environmental review were addressed in the applicant’s Environmental Report and this EIS. 

The safety activities are not included in the EIS and are not included in the site redress plan. 

This item was deleted from Section 4.11 of the EIS.

Comment: The Draft EIS indicated the potential risk of radioactive waste occurring on site after

construction (pages 4-39, 4-40, 6-22, and 8-12). Any soil suspected of radioactive wastes or

other contamination generated during construction-related activities (including site preparation)

must be tested and disposed of in accordance with applicable federal, state, and local laws and

regulations. [Reference to State and Federal laws provided.] (DW-0439 24) (SW-0017 62)

Comment: The discussion of the Site Redress Plan (Draft EIS, page 4-46) raises the potential

for structures to be demolished or removed. These should be checked for lead-based paint and

asbestos before any action takes place. If lead-based paints are found, NRC or the applicant

must comply with the rules in the Virginia Hazardous Waste Management Regulations

(9 VAC 20-60-261); if asbestos-containing materials are found, compliance with the Virginia

Solid Waste Management Regulations (9 VAC 20-80-640) is required. (DW-0439 25)

(SW-0017 63)

Response: The staff agrees with these comments from VDEQ, which provide information

regarding regulations for wastes generated during demolition of new structures (for example, a

warehouse) authorized under an ESP with an approved redress plan. The materials used for

any new construction activity are expected to comply with applicable Federal, Commonwealth,

and local requirements. No changes to the EIS were made as a result of these comments.
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NUREG-1811, Volume II 3-198 December 2006

Comment: Page 4-46 line 1 states that Dominion would post a $10 million guarantee. Given

the recent risks in the utility industry, Dominion should be required to post a Letter of Credit from

a bank rated A or better in the event that its own credit rating drops below investment grade. 

(DW-0438 120)

Response: NRC regulations do not require an applicant to post a guarantee or obtain a letter

of credit. Absent a regulatory requirement, the NRC cannot require an applicant to post a letter

of credit. Accordingly, no change were made to this EIS as a result of this comment.

3.9 Human Health (Nonradiological Impacts)

Comment: Discussion of the impulse noise level from construction activities may not be an

appropriate comparative measure for operational noise impacts. [page 5-53, line 35] 

(DW-0423 37)

Response: The EIS text provides a full range of sound intensities for common situations to

permit readers to place the noise level in context. The noise levels given for plant operation are

clearly below the construction noise levels. Accordingly, no changes were made to this EIS as

a result of this comment.

Comment: Noise from the plant should meet the Louisa County Noise Ordinance as measured

at adjacent non-Dominion properties. It is recognized that this will be a "white" noise. 

(SW-0004 11)

Comment: We believe that the noise issue is currently covered by the Louisa County Noise

Ordinance, as measured at adjacent non-Dominion properties. (ST-0004 8)

Comment: The proposed noise level of the cooling fans is excessive. As a minimum the noise

emitted should not exceed the current Louisa County noise ordnance of 55 DB at night. 

(SE-0012 6) (SE-0016 1)

Comment: [Regarding Dominion’s ER] Dominion states “Public use of the lake is transient and

is less sensitive to noise impacts.” We do not agree with this statement, since we have

approximately 10,000 residential lots surrounding the lake in 3 different counties. Over the

water there is no noise abatement and noise levels travel unimpeded. ...Also please note that

Louisa County has noise ordinances (Chapter 51 of the County Code). (SE-0007 6)

Comment: We're concerned about ...The noise concerns emitted from the 180 to 230 foot

buildings that will travel long distances without having tree barriers to protection the sound from

giant fans. (ST-0014 18) (SE-0020 30)
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 December 2006 3-199 NUREG-1811, Volume II

Comment: These cooling towers will have huge fans that are planned to emit noise levels at

about 65 decibels 24 hours a day, 7 days a week. ...Noise travels long distances if not distorted

by various barriers (trees, buildings, etc). Louisa Noise Ordinance says no more than 55DP (at

night in residential neighborhoods. (SW-0005 6) (SE-0003 5)

Comment: [Regarding Dominion’s ER] Par 5.3.4 page 3-5-69 a - With the addition of the new

units 3 and 4, Cooling Lagoon residences are stated by Dominion as being “one of the areas

possibly affected by the noise from the new cooling systems”. ...What is the noise that can be

expected from the turbine building? (SE-0007 4)

Comment: [Regarding Dominion’s ER] These heights are too tall. The cooling towers should

not exceed the 80 foot height of the tree lines surrounding the NAP for...noise abatement. 

(SE-0004 14)

Comment: [T]he noise levels are well below the country ordinance levels in residential areas. 

The amount of noise we're talking about is about the same as a refrigerator at that distance. So

if you find your refrigerator annoying, then you would find the nuclear plants annoying. 

(ST-0020 2)

Response: Louisa County adopted a new noise ordinance in May, 2004 (Louisa County 2006). 

That ordinance limits daytime noise levels in industrial zones to 75 dBA and nighttime noise

levels to 65 dBA. The North Anna ESP site is zoned “industrial.” Spotsylvania County has only

a general prohibition of “unreasonably loud, disturbing and unnecessary noise.” Noise

customarily emitted from construction activities and industrial establishments is exempt from

this prohibition during daytime hours (6 am to 10 pm) (Spotsylvania County 2006). The text

4.8.3 has been revised to reflect the change in the Louisa County ordinance.

According to Dominion’s ER, noise from the cooling tower for Unit 3 would be less than 65 dBA

at the exclusion area boundary, and noise from the cooling tower for Unit 4 would be less than

60 dBA at the exclusion area boundary. At these levels, cooling tower noise at the exclusion

distance from the cooling towers to the exclusion area boundary is about 700 ft, while the

distance to the nearest residence is more than 3000 ft. Noise from the cooling towers is not

likely to be noticeable at this distance. Accordingly, no additional changes were made to this

EIS as a result of these comments.

Comment: Sentence fragment. [And verify the NESC limits at the COL stage for the

transmission of electricity from Units 3 and 4.] This wording is inconsistent with ER Section

5.6.3 that describes the analysis results, which have already been confirmed by field

verification. [page 5-54, line 24 (line 28 in hard copy version)] (DW-0423 38)

Response: The sentence fragment was deleted because the text did not reflect that field

verification had already been performed.
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NUREG-1811, Volume II 3-200 December 2006

Comment: Since it is possible to make a reasonable estimate of the electric generation output

from additional reactors at the North Anna site, why is Dominion allowed to wait until the COL

licensing stage to determine whether transmission lines from the site meet the requirements of

the National Electric Safety Code (NESC) regarding electrostatic effects from operation (DEIS,

Section 5.8.4)? (DW-0437 71)

Comment: The maximum steady-state current allowed by the NESC is 5 mA root mean square

(rms), and the current from Units 1 and 2 was found to range as high as 4.95 mA (§ 5.8.4, line

26), so is it reasonable to assume that increased capacity from two new units at the site would

exceed NESC standards for electrostatic fields? If so, why is this issue not being addressed at

this stage in the licensing process? (DW-0437 72)

Response: New connections to the grid are subject to the rules and regulations of the Federal

Energy Regulatory Commission (FERC) and the Virginia State Corporation Commission. Their

requirements include numerous studies and reviews if new transmission lines are installed;

Dominion has indicated that new lines are not necessary for any additional units at the NAPS

site. Dominion considered the transmission line design features for its limiting-case scenario

and field-verified the results with actual electric field measurements under energized

transmission lines. Dominion concluded that none of the four transmission lines has the

capacity to induce more than 5 milliamperes in a vehicle parked beneath the lines. The staff

independently reviewed the information provided, and in Section 5.8.4, assumed that the

transmission lines would meet the NESC criteria for electric shock. Accordingly, no changes

were made to this EIS as a result of these comments.

Comment: [T]he National Institute of Environmental Health Sciences (NIEHS) has determined

that electromagnetic fields may pose a leukemia hazard in human populations (draft EIS,

page 5-55, lines 1-3). Would a stronger electromagnetic field produced by increased voltage

capacity on the transmission lines from the NAPS amplify this hazard? (DW-0437 73)

Response: The NIEHS actually suggested that the level and strength of evidence supporting

extremely low frequency - electromagnetic field (ELF-EMF) exposure as a human health hazard

are not sufficient to warrant aggressive regulatory actions. The Institute did not determine that

electromagnetic fields pose a leukemia hazard, but that such a hazard cannot be dismissed. 

The Institute did not recommend actions such as stringent standards on electric appliances and

a national program to bury all transmission and distribution lines; it suggested that passive

measures, such as a continued emphasis on educating both the public and the regulated

community on means aimed at reducing exposures, should be employed. The Institute

suggested that the power industry continue its current practice of siting power lines to reduce

exposures and continue to explore ways to reduce the creation of magnetic fields around

transmission and distribution lines without creating new hazards. Therefore, it would not be

appropriate to speculate about the possible effects of additional generation at the North Anna

site with respect to such a hazard at this time. Accordingly, no changes were made to this EIS

as a result of this comment. 
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 December 2006 3-201 NUREG-1811, Volume II

Comment: WHTF temperatures of 100(F or more will make the WHTF unsuitable for

recreation, swimming, and aquatic life. In Table 5-12 of the ESP, hydrological alterations as

presented will have an impact level of MODERATE and not SMALL as represented by ESP. 

(DW-0806 6)

Comment: I’m concerned about the water temperature and the water level. I swim in the back

of my property in the months of August and July, sometimes early September. The water is

pretty warm... During the drought year, the water was down very low, and so that would be a

problem, too. (DT-0024 1)

Comment: My wife enjoys the lake more than I and enjoys the warmer temps provided by the

discharge, allowing her to be on the lake early in April and late in December. (DT-0060 2)

Comment: What will happen to the fish and to humans as they recreate on the lake when the

temperatures increase, causing possible harmful bacteria and algae to continue to live all winter

long and not die off in a natural winter cycle? (DT-0038 7)

Response: These comments were received based on the evaluation in the Draft EIS of a

once-through cooling system for Unit 3 and its elevated discharge temperature relative to the

existing discharge from Units 1 and 2. The proposed cooling system has since been changed

to a closed-cycle, combination wet and dry cooling system, which would have a substantially

lower discharge temperature and would be expected to have a negligible effect on temperatures

in the WHTF and Lake Anna. The WHTF was licensed by the Commonwealth of Virginia as an

industrial waste heat treatment facility; as a result of that designation, the Commonwealth does

not require that Dominion meet water quality standards within the WHTF. Operation of the

proposed Unit 3 cooling system would not be expected to raise the water temperature of the

WHTF by any appreciable amount. The nonradiological human health impacts of swimming in

those isolated areas where the water temperature could exceed 40(C (104(F) was evaluated

by the Virginia Department of Health (VDH 2005). The VDH recommended that people do not

swim in areas where the water temperature is above 40(C (104(F) to be protective of persons

who might be particularly vulnerable to the effects of submersion in hot water. Based on the

use of a closed-cycle, combination wet and dry cooling system for proposed Unit 3 and its

minimal effect on water temperature in the WHTF, the staff determined that the health effects

from the operation of Unit 3 were SMALL. Section 5.8.1 of this EIS has been modified to reflect

this assessment. 

Comment: What is the basis for the conclusion that the increased water temperature in

Lake Anna caused by the additional cooling structures required for new reactor units at the site

would not be sufficient to “create an environment conducive to the optimal growth of

thermophilic organisms,” which can cause primary amoebic encephalitis in humans (DEIS,

Section 5.8.1)? (DW-0437 28)
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NUREG-1811, Volume II 3-202 December 2006

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the

ESP]...Human health problems due to increased water temperatures and increased bacteria

from increased water temperatures. (SE-0022 18) (ST-0014 9)

Comment: We have become increasingly concerned about the high temperatures on the

cooling lagoon side of the lake and of the potential of detrimental bacteria flourishing in the

warm water. ...This lake is an area of recreation, it is advertised as such, and the safety and

well being of those using it need to be considered. (SE-0008 1)

Comment: Primary Amebic Meningoencephalitis (PAM)...should be tested for and monitored in

Lake Anna Main Reservoir and the Cooling Lagoons. ...This is a public safety issue. 

(SW-0004 12)

Comment: Any increase in the temperature of the water entering Lake Anna would result in a

significant health risk as defined by the Surgeon General of the United States. (SE-0012 3)

Comment: [Regarding Dominion’s ER] Dominion suggests postal mail, signage, or Internet for

Virginia agencies to inform the public. Since Dominion’s power plants are the cause of the

increased temperature that can cause the PAM problem, they solely hold responsibility and

liability and not Virginia agencies. (SE-0007 8)

Comment: Insure that the Lake Anna cooling lagoon residents are provided the same

protections for health, safety, welfare and water quality that are provided the Lake Anna users

on the main reservoir. (SE-0015 1)

Response: The first comment of those immediately above was received based on the

evaluation in the Draft EIS of a once-through cooling system for Unit 3. The following six were

received in response to the SDEIS, which evaluated the impacts of the proposed closed-cycle,

combination wet and dry cooling system for Unit 3, which would have a substantially lower

discharge temperature and would be expected to have a negligible effect on lake temperature. 

The bases for the staff conclusions reached are presented in Section 5.8.1, which summarizes

the correspondence related to the operating license renewal of NAPS Units 1 and 2. The

thermophilic pathogenic amoeba (Naegleria fowleri) found in freshwater throughout the United

States, was found in the WHTF following startup of NAPS Unit 1 in June 1978. In 1981, Virginia

Electric Power Company (VEPCo) environmental personnel met with the Virginia Epidemiologist

to determine whether N. Fowleri at NAPS represented a public health risk. Following

consultation with other State and Federal agencies, the risk of contracting primary amoebia

meningoencephalitis (PAM) was determined to be too low to justify any action by VEPCo or

state agencies (VEPCo 1985). The correspondence includes reference to Medical College of
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Virginia researchers isolating N. Fowleri from the WHTF. Dr. Miller, Virginia State

Epidemiologist, determined that the potential risk from the amount of N. Fowleri in the WHTF

was too low to justify any necessary action by Virginia Power or State agencies (VEPCo 2001,

Appendix F). Additionally:

& The summer water temperatures in the sampled locations (in Lake Anna and the WHTF)

were found to be below those considered optimal for the growth of thermophilic forms

(VEPCo 2001).

& Virginia Power recently upgraded the onsite sewage treatment plant to include

disinfection processes that reduce coliform bacteria and other micro-organisms to levels

that meet State water-quality standards. (On January 15, 2003, new bacteria standards

in the Water Quality Standards Section 9 VAC 25-260-170.A became effective, as did

the revised disinfection policy of 9 VAC 25-260-170.B. These standards replaced the

existing fecal coliform standard and disinfection policy of 9 VAC 25-160-170

[VDEQ 2005]). This upgraded sewage treatment plant would be able to handle waste

from the new units.

& At the North Anna ESP site, the addition of proposed Unit 3 and 4 would be expected to

have a negligible effect on the temperature in Lake Anna and would not be likely to

create an environment conducive to the optimal growth of thermophilic organisms. The

Virginia Department of Health (VDH) assessed the public health effects of swimming in

the WHTF. The risk of contracting PAM was determined by the VDH to be low (less

than the risk of being struck by lightening).

Dominion is working with VDH and VDEQ to establish a mechanism to communicate public

health information to residents around the WHTF. Information from VDH about N. fowleri

proliferation temperatures was added to Section 5.8.1 of the EIS.

3.10 Human Health (Radiological Impacts)

3.10.1 Comments Related to Regulatory Limits and Occupational Exposure

Comment: During construction of new units and during operation, construction workers and

plant personnel would be exposed to radiation sources within the restricted area boundary of

existing nuclear power plants. Exposure would occur via direct radiation, gaseous effluents and

liquid effluents. The federal annual radiation worker limit is 5 rem which will result in excessive

genetic defects, morbidity and mortality. The Nuclear Regulatory Commission’s standard is

more than double the standard set by the International Commission on Radiation Protection. 

The ICRP estimates that 5 rems of exposure would result in a 1 in 500 cancer death rate. The
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Commission’s standard [does] not conform to ALARA standards (As Low As Reasonably

Achievable); rather, it is an illegal and unacceptable compromise which is based primarily on

cost, not on the protection of worker health. (DW-1163 12)

Comment: The federal occupational radiation worker dose limit of 5 rem per year is arbitrary

and capricious and would not protect worker health or safety — The NRC’s 5 rem limit is based

too heavily on economic factors, not medical knowledge. The NRC standard is more than

double the maximum set by the International Commission on Radiation Protection. The NRC

standard is illegal and unacceptable. (DW-1163 3)

Comment: [T]he Commission’s annual radiation worker limit of 5 rem does not conform to the

ALARA concept (As Low As Reasonably Achievable), adopted by the Commission in 1991. The

5 rem standard will result in excessive genetic defects, morbidity and mortality. The NRC

standard is 150% higher than the standard set by the International Commission on Radiation

Protection. The ICRP estimates that 5 rems of exposure would result in a 1 in 500 cancer death

rate (20E+04). This is not ALARA; this is not legal; this is not acceptable. (DW-1163 15)

Comment: The federal occupational radiation worker dose limit of 5 rem per year is arbitrary

and capricious and would not protect worker health or safety - The NRC’s 5 rem limit is based

too heavily on economic factors, not medical knowledge. The NRC standard is more than

double the maximum set by the International Commission on Radiation Protection. The NRC

standard is illegal and unacceptable. (DT-0034 4)

Comment: The federal occupational radiation worker dose limit of 5 rem per year is arbitrary

and capricious and would not protect worker health or safety. The Nuclear Regulatory

Commission’s standard is more than double the standard set by the International Commission

on Radiation Protection. The ICRP estimates that 5 rems of exposure would result in a 1 in

500 cancer death rate. The Commission’s standard is not conform to ALARA standards (As

Low As Reasonably Achievable); rather, it is an illegal and unacceptable compromise which is

based primarily on cost, not on the protection of worker health. (DT-0034 14)

Comment: Dr. Stuart Bushong, Professor of Radiology, Baylor College of Medicine says, “The

5-rem standard is an administrative standard.” In other words, it is the result of a compromise

forced by economic factors, not medical knowledge. The U.S. Environmental Protection Agency

estimates that tightening the worker radiation exposure standard by 70% would require the

nuclear industry to hire 30,000 additional personnel and would cost hundreds of millions of

dollars. (DT-0034 15, DW-1163 13, DW-1163 14)

Response: The primary mission of the NRC is to ensure that authorized activities are

conducted in a manner to provide adequate protection of public health and safety from the

effects of the radiological hazards posed by nuclear reactor, materials, and waste facilities. The

exposure limits for radiological protection are established by the NRC to protect workers and the

public from the harmful health effects of radiation on humans. The occupational exposure limits
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are set to be protective of workers during their entire working career. The limits are based on

the recommendations of standards setting organizations. Radiation standards reflect extensive

scientific study by national and international organizations (e.g., the International Commission

on Radiological Protection [ICRP], National Council on Radiation Protection and Measurements

[NCRP], and the National Academy of Sciences [NAS]) and are conservative in ensuring that

the public and workers at nuclear power plants are adequately protected; the NRC monitors the

scientific studies of these organizations. The NRC radiation exposure standards are in

10 CFR Part 20, “Standards for Protection Against Radiation.” In promulgating these standards

based on the recommendations in ICRP 26 and 30, the NRC has determined that they are

protective of human health; should additional information warrant changes in the exposure limits

for radiological protection, then this would be reflected in the NRC rules.

The 5 rem annual limit is an upper limit separate from the “as low as reasonably achievable”

(ALARA) objective that licensees are to apply to further reduce exposure to radioactive material. 

The ALARA requirements are specified in 10 CFR 20.1101. ALARA requires the licensee to

use, to the extent practicable, procedures and engineering controls based on sound radiation

protection principles to achieve occupational dose and doses to members of the public as low

as is reasonably achievable. An annual occupational dose summary report issued by the NRC

(NUREG-0713, Vol 25) showed that the average measurable total effective dose equivalent

(TEDE) per worker for a recent 10-year period (1994-2003) ranged from 0.21 to 0.31 rem with a

declining trend in recent years; this is indicative of the effectiveness of ALARA programs. This

NUREG also showed that no worker at a commercial power reactor received more than 4 rem

annually and only 18 of the 109,990 workers monitored exceeded 3 rem annually in 2003. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: [T]he first step of the fuel cycle, extraction of uranium ore from the earth, involves a

deadly exploitation of uninformed and unprotected miners. (DW-0411 2)

Response: The staff evaluated the impacts of uranium mining assuming underground or

strip mining techniques were used (see Chapter 6 of the EIS). This evaluation was derived from

Table S-3 of 10 CFR 51.51, which was based on WASH-1248; in promulgating this rule, the

Commission presented its conclusions of the environmental impacts of the fuel cycle. As

discussed in Section 6.1.1 of the EIS, the primary method of uranium mining in the United

States today is in situ leach mining. It involves injecting a solution into uranium ore to dissolve

the uranium and pumping the solution to the surface for further processing. This process

eliminates the dusty labor-intensive underground or open pit mining techniques. Accordingly,

no changes were made to this EIS as a result of this comment.

Comment: When it comes to our occupational exposure, our Unit 2 has the second lowest

radiation exposure in the nation for our type of reactor and Unit 1 has the ninth lowest exposure.

...As for public dose, it's minimal. (ST-0022 2)
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Response: The comment provides information on doses from the existing units and does not

address the new units. Accordingly, no changes were made to this EIS as a results of this

comment.

3.10.2 Cancer and Health Effects

Comment: In particular, I want to start off, which I hope is a constructive criticism of the NRC,

and that has to do, again, with [NRC’s contractor, Project Team Leader] Maryann Parkhurst’s

comments about lack of harm of a radiation dose of ten rads, or 10,000 millirems. I mean, she

chose to emphasize this, that there’s no studies that show any health effects for exposure to

10,000 millirems, but she knows and I know that if Dominion Power reported that one of their

workers at North Anna received 10,000 millirems, there would be an immediate investigation,

and at the end of that process, there would be a considerable fine...So I think it’s important for

the NRC to rein in that sort of activity because, on the one hand, suggesting that radiation is

harmless while their own policies which are designed to protect workers are based on the

knowledge that radiation is not harmless. (DT-0002 2)

Response: The NRC staff routinely inspects operational programs at nuclear power plants to

ensure that they are effective in meeting regulatory requirements and NRC expectations. The

NRC would follow up on any incident in which a worker received a dose that exceeded the NRC

regulatory annual limit of 5 rem to determine whether it is indicative of a breakdown in

radiological control practices at the plant. The 5 rem annual limit is an upper limit and licensees

apply the ALARA principles to further reduce doses below the limits. Licensees typically

establish administrative control limits that are less than the NRC regulatory limit of 5 rem. An

annual occupational dose summary report issued by the NRC (NUREG-0713, Vol 25) showed

that the average measurable total effective dose equivalent (TEDE) per worker for a recent

10-year period (1994-2003) ranged from 0.21 to 0.31 rem with a declining trend in recent years;

this is indicative of the effectiveness of ALARA programs. This NUREG also showed that no

worker at a commercial power reactor received more than 4 rem annually and only 18 of the

109,990 workers monitored exceeded 3 rem annually in 2003. 

A position statement entitled Radiation Risk in Perspective by the Health Physics Society

(revised August 2004) puts the health impact into perspective. Key points addressed in the

statement included:

1. Radiological health effects (primarily cancer) have been demonstrated in humans through

epidemiological studies only at doses exceeding 5 to 10 rem delivered at high dose rates. 

Below this dose, estimation of adverse effect remains speculative.

2. Epidemiological studies have not demonstrated adverse health effects in individuals

exposed to small doses (less than 10 rem delivered over a period of many years).
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3. In accordance with current knowledge of radiation health risks, the Health Physics Society

recommends against quantitative estimation of health risks below an individual dose of

5 rem in one year or lifetime dose of 10 rem above that received from natural sources.

4. A person receives approximately 0.3 rem from natural background radiation each year

which would accumulate to 5 rem in 17 years and 25 rem in an 80-year lifetime.

Accordingly, no changes were made to the EIS as a result of this comment.

Comment: [Regarding the risk of cancer caused by radiation exposure at North Anna ...

[page 6-13], the report covers the assumptions made in calculating the risks: “The cancer risk

factors, used in this analysis, are from the BEIR-V report, “Health Effects of Exposure to Low

Levels of Ionizing Radiation” (National Research Council 1990). In this report, it is estimated

that “if 100,000 persons of all ages received a whole body dose of 0.1 Gy (10 rad) [roughly

equivalent to 10 rem] of gamma radiation in a single brief exposure, about 800 extra cancer

deaths would be expected to occur during their remaining lifetimes in addition to the nearly

20,000 cancer deaths that would occur in the absence of radiation.” Therefore, even with a

large exposure (i.e., twice the annual dose limit for workers), the cancer mortality would change

by less than a percentage point (i.e., from 20% to 20.8%).” My objection here is not how the

calculations were arrived at, but how the results are considered. Granted, less than one

percentage point sounds low on paper, but one must consider the size of the population. 

(DW-0426 10)

Comment: [T]here is a huge difference between considering less than one percent when one

is thinking about profit margin and when one is considering the number of new cancer cases. 

Supposing you do have a population of 100,000 people. What sort of justification is it to say,

Well, 20,000 of them are going to get cancer anyway, so what’s another 800.” We are talking

about 800 additional families suffering from preventable tragedies. In this light, less than one

percent is unacceptable. (DW-0426 11)

Comment: Now, the report did say that this is assuming an amount of radiation that is twice the

annual dose limit for workers. However, let’s consider that workers will work at the plant for

many years. How does that change the radiation exposure and subsequent risk of cancer? I

also realize that the plant will not have 100,000 workers. But let’s also consider the small

possibility that more radiation escapes the plant than we optimistically expect, either because

calculations are wrong, or because of a plant malfunction. Then you are dealing with a potential

population of much greater than 100,000 people, depending on which direction is downwind. I

cannot accept that even a small percent of my neighbors would get cancer or worse so that I

can turn on my air conditioner in the summer. Can you? (DW-0426 12)

Comment: We can figure out better ways to boil water that do not come with...the destruction

of DNA for thousands of years or cancer. (DW-0861 3)
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Comment: [A]s someone who was born and raised near the Hanford Nuclear Reservation, I

have seen the reality of nuclear contamination on the human body: It’s so ugly. Watching

people die slowly and painfully from contaminated water and air and soil--no one wants that on

their conscience. I know you don’t. (DW-0453 2)

Comment: My sister in law who lives in Berlin had thyroid cancer which was caused by the

Chernobyl accident. Which shows how far away people are affected. (DW-1074 2)

Comment: One of my concerns is that I’ve seen and heard about a study or more than one

study that has shown that if you live within 50 to 100 miles of Lake Anna, you have statistically a

higher rate of cancer, and now maybe somebody else in this room can talk more about that. I’m

not an expert, but that’s a great concern to me as a parent. (DT-0013 1)

Comment: The DEIS fails to address negative impacts on human health caused by historic

radiation releases from existing North Anna nuclear reactors--In the ten counties nearest the

plants, the breast cancer mortality rate increased 73% in the decade after the reactors began

operation; the increase in the counties nearest the plant was triple the statewide increase. 

(DT-0034 3 and DW-1163 2)

Comment: The public record contains evidence that North Anna has not and will not meet the

requirements under 10 CFR §100.21(c)(1). In the ten counties nearest North Anna, the breast

cancer mortality rate increased 73% in the decade after the reactors began operation, an

increase made more significant by the fact that the combined rate for all counties within

100 miles of the plant is only 4% higher. Moreover, the increase in the counties nearest the

plant was triple the statewide increase in breast cancer mortality during that period. [“The

Enemy Within,” Jay Gould et al, 1996, Appendix B, p. 244] In human terms, 172 more women

died from breast cancer during the decade after North Anna 1 and 2 opened than in previous

decades in Goochland, Fluvanna, Albemarle, Louisa, Orange, Greene, Cumberland,

Buckingham, Powhatan, and Nelson counties. Airborne emissions of radioactive gases at North

Anna during the decade after Unit 1 reached criticality in 1978 was on average 8,900 Curies per

year. Emissions to water during this same period was on average 2.16 Curies per year. [“The

Enemy Within,” Jay Gould et al. 1996, Appendix C, p. 310] (DT-0034 13, DW-1163 11)

Comment: Then there is the carefully concealed fact that breast cancer rates rise around such

facilities, and I’m sure other types of cancer do too. (DW-0198 6)

Comment: Dominion and the DEIS failed to investigate impacts caused by the addition of two

or more reactors at its North Anna nuclear station including but not limited to the risks of cancer

from ionizing radiation, birth defects (congenital anomalies), infant mortality, infant cancer

incidence, heart disease, and neurological effects. (DW-1163 7) (DT-0034 7) 
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Comment: Dominion and the DEIS failed to investigate impacts caused by the addition of two

or more reactors at its North Anna nuclear station including but not limited to the risks of cancer

from ionizing radiation, birth defects (congenital anomalies), infant mortality, infant cancer

incidence, heart disease, and neurological effects. 

Comment: The Blue Ridge Environmental Defense League calls upon the Nuclear Regulatory

Commission for a comprehensive health study before the federal government issues an early

site permit for new nuclear plants at North Anna. BREDL recommends death and disease

studies be done in Albemarle, Culpeper, Fluvanna, Goochland, Green, Louisa, Madison,

Orange, Spotsylvania Counties, and Charlottesville because of data showing significantly higher

death rates in the nine-county area. Records show that death rates rose sharply soon after

Dominion Virginia Power’s North Anna nuclear reactors began operation, and those effects

continue to the present time. (DT-0034 1)

Comment: On the Blue Ridge Environmental Defense League Website, Lou Zeller claims the

death rate for children age one to 14 almost doubled in the surrounding counties after North

Anna started up. He claims the data suggest these children were harmed by radioactive

emissions from the plant. Mr. Zeller referenced the CDC Website as his data source. So I went

on line myself to check out the numbers, and I encourage all of you to do the same. While the

Blue Ridge Website says the death statistics exclude accidents, homicides and suicides, what I

saw at wonder.cdc.gov proved otherwise. Zeller’s before numbers did correctly exclude

accidents, but his after numbers did not. This is how Lou makes these numbers appear to

actually double...What’s truly alarming here is your [Mr. Zeller’s] sloppy use of statistics and

your clear attempt to scare these people into thinking that North Anna is killing our children. 

(DT-0031 2)

Comment: I was a little surprised to hear that you don’t know of any studies that show

radiation health effects under ten rads...I’d point to Alice Stewart’s studies in the 1950s that

showed fetal effects, leukemia increases from X-rays given to pregnant women. (DT-0001 3)

Comment: You said that there have been no studies that would indicate that 10,000 millirem

would induce cancers in the population, and according to the linear no threshold theory that’s

simply not true. (DT-0002 1)

Comment: There is no such thing as a safe dose of radiation, and background natural

radiation does exist and we can’t do anything about it, but knowing that exposure to radiation

causes cancer and that cancer rates have increased since the power station came on line, why

would we want to expose ourselves further? (DT-0036 9)

Comment: Contrary to what many nuclear power advocates claim I do not agree that it

[nuclear power] is a clean energy source. That is such a selfish and shortsighted conclusion. 

What kind of legacy are we leaving behind for our children? Are you familiar with the effects of
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NUREG-1811, Volume II 3-210 December 2006

exposure to even the smallest amount of radiation?... it is a horrific blight to cast upon our future

generations for our immediate comforts. (DW-0404 2)

Comment: According to a study I learned about...after the construction of the first two reactors

at North Anna, breast cancer in white women increased by 73%. Also, the rates of stillborns

went up by 28%. It is a well known fact that even low levels of radiation (which the two reactors

already periodically emit) can cause cancer and genetic dysfunction. There is no smoking gun

that points directly to the North Anna reactors as culprits for the rise of cancer and other

problems in the area. However, looking at the circumstantial evidence, do we really want to

build two new reactors that would increase risks? (DW-0408 3)

Comment: The discussions of potential radiation hazards to humans living near Lake Anna are

not clear enough in the EIS. The document simply sites studies that are in the interest of

Dominion without a discussion of why these particular studies are more scientifically credible

than those indicating that nuclear reactors do cause radiation damage to the human community

around a reactor. It is not scientifically appropriate to simply choose a particular set of studies

without showing why. (DW-0630 5)

Comment: It really doesn’t matter how great a place this is to live if our children and our world

are being exposed to radiation and to the potential of catastrophic nuclear disasters. 

(DT-0037 7)

Comment: Contrary to NRC’s assertions, “low-level” is NOT low-risk in terms of environmental

damage and the public’s health and safety. (DW-1154 7)

Comment: And like someone mentioned before, a lot of them [radioactive isotopes] act as

analogues to nutrients so that they end up in our bodies. (DT-0018 4)

Comment: Closer to home, an anti-nuclear group claimed that cancer rates had risen near

North Anna. But inspecting their work showed that they had compiled their data rather

strangely. While they took the data from some counties far away from the plant, they ignored

the data from Spotsylvania County right across the lake. Why did they do that? Because it

didn't support their claims. (ST-0012 5)

Comment: In October 2004, Mr. Lou Zeller, on the Blue Ridge Environmental website, cited a

study by Joseph Mangano, which claimed the death rate for children almost doubled in the nine

counties closest to North Anna. The study examines causes of death in a 30-mile radius from

the plant. This first map shows those nine counties and the 30-mile radius. Let me show this to

you for a second. The nine counties closest to the plant in a 30-mile radius that the study

considered. Note that Caroline and Hanover Counties to the east and southeast were not

included, even though they're within 10 miles from the plant. Green County to the west was

included, although it's completely outside the 30-mile radius. The black dot to the west is the
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City of Charlottesville. It was included, but it's also outside the 30-mile radius. Richmond is the

same distance as Charlottesville to the southeast, but was excluded, as was Fredricksburg,

which is only 25 miles from the plant. Five months later in March 2005, Mr. Zeller, in written

comments to the NRC, cited yet another flawed health study. This one claimed women's deaths

from breast cancer increased 73 percent in the ten counties closest to North Anna. If you

thought this new study added Caroline or Hanover Counties in as the tenth county, you'd be

wrong. This next map shows the differences in green. The second study dropped Madison and

Culpeper Counties to the northwest, but added Nelson, Buckingham, Cumberland, and Palatan

Counties to the southwest. Nelson County is 50 miles from North Anna, yet they still ignored

Hanover and Caroline Counties only 10 miles away. Strangest of all, and Lisa mentioned this,

they ignored Spotsylvania County in the study, which is right across the lake from North Anna. 

Spotsylvania has more people than any of the ten counties included in the study. Does

hand-picking counties and cities like this bias the results of the study? You bet it does. (ST0026 2)

Comment: After the public meeting last year, Mr. Zeller wrote the NRC saying I falsely accused

him of misusing public health data. I wish to clarify. They aren't just misusing public health

data, as you can see, they're playing shell games with women's and children's death statistics. 

It's a shameful scare tactic. This misinformation is still on the Blue Ridge website today. 

(ST-0026 3)

Comment: [I]f you want to talk about the health effects on a community population, then you

need to be fair, what kind of issues you're evaluating. You're not looking fairly at, for example,

the medical sources of radiation, which we've already heard this evening are tremendously

higher for the impact on the population than the impact from the radiation that comes from a

nuke station. (ST-0025 3)

Response: Health effects from exposure to radiation are dose-dependent, ranging from no

effect at all to death. Above certain doses, radiation can be responsible for inducing diseases

such as leukemia, breast cancer, and lung cancer. Very high (hundreds of times higher than a

rem), short-term doses of radiation have been known to cause prompt (or early, also called

“acute”) effects, such as vomiting and diarrhea, skin burns, cataracts, and even death. When

radiation interacts within the cells of our bodies, several events can occur. First, the damaged

cells can repair themselves and permanent damage does not result. Second, the cells may die,

much like large numbers of cells do every day in our bodies, and dead cells may be replaced

through normal biological processes. Third, the cells may either incorrectly repair themselves

(resulting in a change in the cells’ genetic structure), they can mutate and subsequently be

repaired without any effect, or they can sometimes form precancerous cells that may become

cancerous.

Radiation is only one of many agents with the potential for causing cancer, and cancer caused

by radiation cannot be distinguished from cancer attributable to any other cause, such as
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chemical carcinogens. The chances of getting cancer from a low dose of radiation is not known

precisely because the few effects that may occur cannot be distinguished from normally

occurring cancers. The normal chance of dying from cancer is about one in five.

The actual amount of radiation any member of the public receives from activities at nuclear

power facilities is so small that scientists have been unable to make empirically based estimates

of radiation risk with any precision. There are many difficulties involved in designing research

studies that can accurately measure the projected small increases in cancer cases that might

be caused by low exposures to radiation when compared to the rate of cancer resulting from all

other causes. In the absence of a clear answer, the U.S. Nuclear Regulatory Commission

conservatively assumes that any amount of radiation may pose some risk for causing cancer or

having some hereditary effect and that the risk is higher for higher radiation exposures. This is

called a linear, no-threshold dose-response model and is used to describe the relationship

between radiation dose and the occurrence of cancer.

This model suggests that any increase in dose above background levels, no matter how

small, results in an incremental increase in risk above existing levels of risk. Although the

U.S. Nuclear Regulatory Commission has accepted this hypothesis as a “conservative”

(i.e., cautious) model for determining radiation standards, the U.S. Nuclear Regulatory

Commission, like other authoritative bodies, recognizes that this model will probably

over-estimate radiation risk. The association between radiation exposure and the development

of cancer are mostly based on studies of populations exposed to relatively high levels of

ionizing radiation (for instance, the Japanese atomic bomb survivors and the recipients of

selected diagnostic or therapeutic medical procedures). 

Although radiation can cause cancers at high doses and high dose rates, currently there are no

data to establish unequivocally the occurrence of cancer following exposures to doses at or

below about 10 rem. The average annual dose to a member of the public from a nuclear power

facility is in the range of less than 1/1000th rem (1 millirem) per year. This is compared to the

10 rem (10,000 millirem) discussed previously. At doses above 10 rem, a relationship between

radiation and cancer can be observed. Although there is a statistical chance that radiation

levels that small (i.e., less than 10 rem) could result in a cancer, it has not been possible to

calculate with any certainty the probability of cancer induction from a dose this small. Because

many agents cause cancer, it is often not possible to say conclusively whether the cancer was

radiation-induced cancer.

Authors of various reports have stated or implied that there are cause-and-effect relationships in

the statistical associations between cancer rates and reactor operations. While it is true that

cancer rates vary among locations, it is very difficult to ascribe the cause of a cluster of cancers

to some local environmental exposure, such as radiation from a nuclear power facility. 

Statistical association alone does not prove causation, and well-established scientific methods

must be used to determine causation. For example, a person could say, “In the winter I wear
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boots, and in the winter I get colds.” While there is a strong statistical association between

wearing boots and getting colds, it would be inappropriate to say that wearing boots

causes colds.

The scientific community adheres to several principles of good science that need to be

employed before a cause-and-effect claim can be made. These principles include whether the

study can be replicated, whether it has considered all the data or was selective (e.g., in the

population or in the years studied), whether it evaluated all possible explanations for the

observations, whether the data were valid and reliable, and whether the conclusions were

subjected to independent peer review, evaluation, and confirmation.

A number of studies that conformed to these principles have been performed to examine the

health effects around nuclear power facilities.

& In 1990, at the request of Congress, the National Cancer Institute conducted a study

(NCI 1990) of cancer mortality rates around 52 nuclear power plants and 10 other

nuclear facilities. The study covered the period from 1950 to 1984 and evaluated the

change in mortality rates before and during facility operations. The study concluded

there was no evidence that nuclear facilities may be linked causally with excess deaths

from leukemia or from other cancers in populations living nearby.

& Investigators from the University of Pittsburgh found no link between radiation released

during the 1979 accident at the Three-Mile Island nuclear station and cancer deaths

among nearby residents. Their study followed more than 32,000 people who lived within

8 km (5 mi) of the facility at the time of the accident.

& In January 2001, the Connecticut Academy of Sciences and Engineering issued a report

on a study around the Haddam Neck nuclear power plant in Connecticut and concluded

that exposures to radioactive material were so low as to be negligible and found no

meaningful associations to the cancers studied.

& In 2001, the American Cancer Society concluded that, although reports about cancer

clusters in some communities have raised public concern, studies show that clusters do

not occur more often near nuclear plants than they do by chance elsewhere in the

population. Likewise, there is no evidence linking the isotope strontium-90 with

increases in breast cancer, prostate cancer, or childhood cancer rates.

& In 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there

are striking increases in cancer rates in southeastern Florida counties caused by

increased radiation exposures from nuclear power plants. However, using the same
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NUREG-1811, Volume II 3-214 December 2006

data to reconstruct the calculations on which the claims were based, Florida officials did

not identify unusually high rates of cancers in these counties compared with the rest of

the state of Florida and the nation.

 C In 2000, the Illinois Public Health Department compared childhood cancer statistics for

counties with nuclear power plants to similar counties without nuclear plants and found

no statistically significant difference.

In summary, there are no studies to date that are accepted by the nation’s leading scientific

authorities that indicate a causative relationship between radiation dose from nuclear power

facilities and cancer in the general public. The amount of radioactive material released from

nuclear power facilities is well measured, well monitored, and known to be very small. These

comments did not result in a change to the environmental impact statement.

Comment: The Blue Ridge Environmental Defense League (BREDL) requested that an

attached press release from U.S. Congressman Ed Markey (Massachusetts) entitled, “New

Study Suggests Spike in Infant Mortality Associated with Radiation from Nuke Plants” be added

to the BREDL comments. Mr. Markey referenced an article, a study, and a data set from Illinois

suggesting higher incidences of cancer in populations living near nuclear power plants and

asked that the NRC study the connection between serious health risks and radiation released

from nuclear reactors. (DW-1163 20)

Response: In a letter dated March 7, 2005, the NRC responded to Congressman Markey. The

NRC discussed the levels of radioactive release and doses at the edge of the Dresden Nuclear

Power Station (referred to in Congressman Markey’s letter) as being less than 10 percent of the

dose from natural background in the country. In its letter, NRC notes that it routinely reviews

information from studies and evaluations of the health effects of radiation exposure conducted

by national and international radiation protection experts. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: It is relevant to this EIS to understand that the off gassing of the radioactive waste

occurs to this community’s air and water before so-called “disposal.” The noble gases of

radioactive xenon and krypton with half lives of minutes and hours decay into radioactive fallout

of strontium and cesium particulate with half lives on the order of decades and millions of years. 

It is the surrounding community that is the cumulative “disposal” grounds for these radioactive

isotopes. More reactors means more long lived radioactivity deposited onto the land and into

the water, where it biomagnifies eventually to humans. Yet this human health concern is

casually dismissed by NRC and industry. (DW-1154 1)

Comment: A greater worry is the prospect of an environmental and health disaster. Even IF

everything goes right with the construction, testing and operation of this untried new design,

there will be increasing routine releases of radiation into the lake and air, as well as dramatically

increased amounts of nuclear waste traffic from the plant. (DW-0614 9)
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Comment: A new reactor will further contaminate this area. How much is cleaned up depends

on the political clout of the community and a place to send the radioactive contamination. 

(DW-1154 10)

Comment: And as I understand it, there are five annual releases of radioactivity every year,

which we’re not told about, and the results of that I’m not sure we’re aware of. (DT-0018 2)

Comment: I don’t know if the people who even run these power plants know what they’re doing

to the environment because it just seeps through the ground and gets to people’s backyards

and other animals and beings. (DT-0008 2)

Response: All nuclear power plants are licensed with the expectation that there will be routine

very low-level releases of radioactive material to the environment through airborne and liquid

releases from the facility and that these releases may be detectable offsite. All releases of

radioactive material each year are reported in the licensee’s annual radioactive effluent release

report. The NRC requires that nuclear power plant licensees monitor their liquid and gaseous

effluents and report on them in an Annual Radioactive Effluent Release Report. Each licensee

has an Offsite Dose Calculation Manual that designates effluent release limits in addition to the

limits for calculated doses to the public. The licensee must maintain effluent releases to

unrestricted areas ALARA as defined in 10 CFR Part 50, Appendix I.

As discussed in Section 5.9.2 of this EIS, calculated doses to the public that would result from

operation of the proposed new units are well within regulatory limits. In addition, the licensee

would monitor the environment for radioactive material releases as discussed in Section 5.9.6 of

the EIS. Environmental monitoring program results for NAPS Units 1 and 2 are reported in the

Annual Radiological Environmental Operating Report - North Anna Power Station. The Annual

Radiological Environmental Operating Report - North Anna Power Station for calendar

year 2004 showed no plant-related radioactive material in the airborne pathway, well water,

shoreline sediments, milk, and the direct exposure pathway. One of 25 vegetation samples

showed detectable cesium-137 activity, which was attributed to fallout from nuclear weapons

testing. Tritium was found in the surface water in Lake Anna and downstream in the river at

levels below EPA drinking water standards. Xenon and krypton releases from NAPS Units 1

and 2 are monitored upon release from the plant via stack monitors and in the environment by

environmental thermoluminescent dosimeters (TLDs). Environmental TLD results for the

existing units have remained within the range of preoperational TLD results. Certain xenon and

krypton radioisotopes decay into strontium and cesium radioisotopes. For example, xenon-135

decays to cesium-135, a low-energy beta emitter, and it contributes little to dose. Still other

noble gases decay to stable nuclides that are not radioactive. Accordingly, no changes were

made to the EIS as a result of these comments.
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Comment: I also want to mention the idea of radioactivity and, again, forgive me because I’m

not an expert, but I think that it is disingenuous to suggest that the radioactive environment is

natural because, as I understand it, there are over 200 radioactive isotopes that are created

in the process that do not exist in nature, and so these are outside of our natural world. 

(DT-0018 3)

Response: Although there are numerous human-made isotopes and other sources of humanmade radiation (such as medical x-ray equipment), these sources of radiation are responsible

for approximately 0.60 mSv (60 mrem) of the average annual dose to an individual. NCRP

Report No. 93 reported the average dose for an individual in the United States is 360 mrem

annually; of this amount, approximately 300 mrem result from natural background radiation. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The dose assessment on page 4-40 line 28 ignores potential overtime hours. 

(DW-0438 115)

Response: The number of hours used for the calculation of direct exposure to a site

preparation worker was estimated to be 2080 hours. This would average to a 40 hour week for

52 weeks in a year. It is not expected that any worker would actually work every week of the

year in a radiation environment, so even though overtime is not specifically called out, the

estimation of average hours worked in a radiation environment during a year is probably high. 

Overtime hours are not likely to increase the annual dose significantly. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: Why were samples taken to the west when the prevailing winds are to the northeast

(page 4-41 line 30)? (DW-0438 116)

Response: The locations were not sampling locations, rather they were geographical points for

calculating doses. The calculation represented the location of the construction workers and the

gaseous effluent dose estimate was based on an atmospheric dispersion factor between the

operating units and the construction site. The location of the NAPS ESP site is to the west of

the operating units, not to the northeast of the operating units. Accordingly, no changes were

made to this EIS as a result of this comment.

3.10.3 Opinions and Statements

Comment: We already have pollution - we don’t need a bigger possibility of radiation. 

(DW-0798 3)

Comment: For those of us who live in the 30 mile radius and/or in the wind-shadow of the

North Anna Nuclear Plant, it is only our lives, our health and our well-being that are at stake. 

(DW-0823 4)
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Comment: I live only a few miles from the existing plant, and have always had concerns about

my safety and health from living so close to a nuclear plant. (DW-0900 2)

Comment: Nuclear energy is harmful to our environment, the radioactive waste produced by

nuclear energy is harmful, not only to us, but future generations. (DW-0429 2)

Comment: [T]he nature of working with radioactivity is extremely hazardous. (DW-0173 3)

Comment: We deny that any process that produces waste so toxic that it remains a threat to

human health for tens of thousands of years is clean. (DT-0041 3)

Comment: I would remind you that the birth rate of normal children within a radius of

Chernobyl is below fifteen percent. As a firefighter and EMT, I am well aware of the health

concerns if there is a failure. (DW-0309 3)

Comment: All of those countries I mentioned [Sweden, Norway, Germany, Spain, Denmark,

Austria, Australia, Portugal, United Kingdom, Ireland, Greece, and Italy] have infant mortality

rates less than the United States and life expectancy that is greater than the United States. 

(DT-0002 3)

Response: The comments reflect views and opinions, but do not provide new information

about the proposed project and will not be evaluated further. Accordingly, no changes were

made to this EIS as a result of these comments.

3.10.4 Supportive of Nuclear Power as It Relates to Human Health

Comment: If I could lend an outside perspective, I believe that the health risks associated with

a nuclear reactor should be brought to the forefront. If a comparison between coal burning

power plants and nuclear power plants were ever fully debated there would be no question to

which one is more environmentally friendly. Be proactive and inform as many people as

possible. (DW-0858 4)

Comment: It [nuclear power] is the one option that I consider to be the most environmentally

friendly and the least hazardous to my health, my family’s health and the health of the general

population of central Virginia and all the surrounding areas. (DW-1167 2)

Comment: I have two children. I am very concerned about their well-being growing up. If I

thought nuclear power was not the right way to go, by golly, I wouldn’t be in this industry. I’d be

doing something else. (DT-0049 2)
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NUREG-1811, Volume II 3-218 December 2006

Comment: Some critics have yelled about Strontium-90 dangers to neighbors of power plants,

but the facts are quite the opposite. The biggest source of Sr-90 in the environment is from

weapons testing, and a large fraction of the remaining 1% was from Chernobyl. The total

annual release of Sr-90 from all 103 commercial nuclear power plants in the U.S. is 1/1000 of a

curie, or lower than the minimum detectable activity of equipment placed within 30 miles of any

of the plants. (DT-0063 3)

Response: The comments reflect views and opinions, but do not provide new information

about the proposed project and will not be evaluated further. Accordingly, no changes were

made to this EIS as a result of these comments.

3.10.5 Plant Emissions and Environmental Transport

Comment: Brian Smith,...a bright young man who appears to be in physics from MIT, found a

rather startling defect in the EIS, and I brought some baby food for the contractor, four bottles

here, for the contractor, for the NRC staff, for the administrative judges, and for the Commission

because it says here on page 5-61 that no infant doses were calculated for the vegetable or

meat pathway as infants do not consume these foods...I also looked at the NRC guidance,

NRC Regulation 1.109. I looked at the EPA guidance. I looked at the NCRP reports, and all of

them admit that infants consume considerable amounts of vegetables and meat. (DT-0001 4)

Comment: This table that infants don’t eat vegetables is directly from Dominion. That may be

Dominion’s opinion, but it shows a shocking lack on the part of NRC and its contractor that they

have not paid attention to EPA, NRC, or any of the rules in evaluating the NRC site application,

and I am very skeptical that the safety analysis which claimed that confirmatory and

independent evaluations have been done, have actually been done, and we would like to see all

of the input data, the runs, the output date, in electronic and hard copy files. (DT-0001 7)

Response: As outlined in NRC Regulatory Guide 1.109, an “infant” is considered to be a

newborn up to one year of age. NRC Regulatory Guide 1.109, which provides acceptable

methods for an applicant or licensee to use in calculating annual radiation doses to humans

from routine effluents, does not provide usage factors for an infant for (1) fruits, vegetables, and

grains, (2) leafy vegetables, (3) meat and poultry, and (4) fish and other seafood (see, Table

E-5, Regulatory Guide 1.109) for the reasons discussed below. This Guide is used to evaluate

compliance with 10 CFR Part 50, Appendix I. 

In addition to their mothers’ breast milk and packaged formula, infants consume cereal, cow’s

milk (notably, there are no milk cows within 5 miles of the ESP site), and canned/bottled baby

food products such as fruits, vegetables, and meat. Prepared foods products generally would

have been grown in areas away from the ESP site. It is unlikely, but possible, that infants would

consume meats, fruits, and vegetables from the livestock and gardens near the ESP site. The

bottled baby food offered by the commenter provide an illustrative example of this; the
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manufacturer has processing facilities in Freemont, MI, Fort Smith, AR, and Reedsburg, WI,

with production fields throughout the U.S. Oversight of the safety of the food supply through the

50,000 food manufacturers, processors and warehouses in the U.S. is performed by the Food

and Drug Administration. 

Although infant ingestion dose factors (i.e., mrem per pCi ingested) would be higher for most

radionuclides compared to child ingestion dose factors, the dose to an infant from ingestion of

vegetables and fruits would still be bounded by the dose to a child. This is because an infant’s

annual consumption of vegetables and meats is expected to be less than that of a child’s. 

Section 5.9.2 of the EIS was revised to include this information.

Comment: I’d just like to say that there is release of radioactivity from these two existing plants

on a daily basis in the form of tritium, if I’m pronouncing that correctly, the radioactive isotope

that goes into the water and comes out as part of the process. (DT-0018 1)

Comment: Radioactive tritium, an isotope of hydrogen, is released every day into the warm

side of the lake and the air above it in the form of water and water vapor. The North Anna

Power Station uses 2,736,000 gallons of water per day. Airborne tritium can be inhaled and

absorbed, and tritiated water is incorporated into the food chain. Radioactive corrosion

products stick to the interior of the reactor vessel and slough off into the cooling water, which is

then released into the lake. Fission products also enter the cooling water from leaks in the fuel

rods which are allowed by government regulations and which contain the equivalent

radioactivity of 1000 Hiroshima bombs. (DT-0036 8)

Comment: Saying it’s clean ignores the routine release of radioactive gases that build up

inside the reactor building. Filters catch some of these, but some gases get through, like Xenon

135, which decays into Cesium 135, which is an isotope with a three million year half-life. 

(DT-0036 7)

Response: The EPA drinking water concentration limit for tritium is 20,000 pCi/L (40 CFR

141.16). Tritium is released from NAPS Units 1 and 2 and it is found in the Lake Anna surface

waters and at downstream locations in the North Anna River; this was reported in the Annual

Radiological Environmental Operating Report – North Anna Power Station, January 1, 2005 to

December 31, 2005. No plant-related tritium was found in ground water. Average tritium levels

for 2005 were less than 20 percent of the EPA standard (3137 pCi/L in the surface water and

3170 pCi/L at 5.8 mi downstream in the North Anna River). These concentrations compare to

pre-operational tritium concentrations in surface water and lake water in the range of 90 to

250 pCi/L. The licensee calculated the maximum dose to a hypothetical individual at the station

boundary resulting from liquid and gaseous effluents released during 2005, including the tritium

releases, to be 0.38 mrem compared to approximately 360 mrem received from background

radiation and from man-made sources (2005 Annual Radiological Environmental Operating

Report for North Anna [VEPCo 2006]). Fission product releases to the environment are
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NUREG-1811, Volume II 3-220 December 2006

monitored and were reported in Annual Radioactive Effluent Release Reports as well; fission

products are also monitored for in the environment as part of the licensee’s Radiological

Environmental Monitoring Program. The Annual Radiological Environmental Operating Report

North Anna Power Station for calendar year 2005 did not identify detectable radioactive material

in the atmosphere from North Anna. The 2005 Report did not identify detectable radioactive

material in well water, shoreline sediments, vegetation, milk, and the direct exposure pathway

from North Anna as well (VEPCo 2006).

Xenon-135 does decay to cesium-135. Cesium-135 is a fission product that emits a low-energy

beta particle and does not contribute significantly to dose. The applicant did not report any

cesium-135 being released. This is consistent with current releases from NAPS Units 1 and 2

(see Annual Effluent Monitoring Reports).

Similar to the programs at the NAPS Units 1 and 2, radiological effluents from any new units on

the North Anna ESP site will be monitored. The radiological environmental monitoring program

will also include the results from any new units. Dose estimates from radioactive effluents and

environmental sample data from NAPS Units 1 and 2 are within regulatory limits. Accordingly,

no changes were made to this EIS as a result of these comments.

Comment: And the draft environmental impact statement has trivialized the known and

potentially harmful environmental impacts of nuclear waste generation... The report states at

Section 6.1.1.6, radioactive wastes, and to boil it down really quick, they say that there’s no

release to the environment that’s expected. It is worth noting that in this same section the

staff has admitted that, quote, “It has been assumed that all of the gaseous and volatile

radionuclides contained in the spent fuel are released to the atmosphere before the disposal of

the radioactive waste. (DT-0040 1)

Response: Gaseous and volatile radionuclides contained in the spent fuel will decay and some

of it may be released during storage in the spent fuel pool. Any releases from the fuel would be

subject to NRC’s monitoring and annual reporting requirements. There are no gaseous or

volatile radionuclides released from the spent fuel after it is removed from the spent fuel pool. 

For example, there are no airborne releases during storage at interim locations such as at the

independent spent fuel storage facilities. Nor would there be any airborne releases following

disposal at a waste repository. Accordingly, no changes were made to this EIS as a result of

this comment.

Comment: Page 2-18 line 18 states that this DEIS tiers off the preoperational environmental

radiation monitoring program. Since the two units have been operational for some time, the

baseline should be re-established via a new study. (DW-0438 33)

Response: Section 2.5 describes the current radiological environment at the NAPS site. 

Baseline environmental conditions established prior to Units 1 and 2 becoming operational
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will continue to be the appropriate baseline upon which to compare impacts from continued

operation of Units 1 and 2 and the operation of the proposed ESP Units 3 and 4. The

preoperational monitoring period was conducted between July 1974 and March 1978 (Unit 1

became operational in 1978) (2004 Annual Radiological Environmental Operating Report for

North Anna Power Station [VEPCo 2005]). Since then, the Radiological Environmental

Monitoring Program for Units 1 and 2 has continued to provide for collection and analyses for

the NAPS site. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Page 2-18 line 33 states that the NRC concluded that radiation doses were small.

Since a DEIS is intended to be a public document, data of this type should be summarized and

included in the DEIS along with the staff conclusions derived there from. (DW-0438 34)

Response: The Draft EIS stated that doses to the maximally exposed individuals around NAPS

were calculated to be a small fraction of the limits specified in Federal (NRC and EPA)

environmental radiation standards, 10 CFR Part 20; 10 CFR Part 50, Appendix I; and

40 CFR Part 190. Section 2.5 of the EIS was revised to update the public dose estimates from

the 2005 Annual Radiological Environmental Operating Report for North Anna Power Station

(VEPCo 2006). The maximum dose to a hypothetical individual at the station boundary

resulting from liquid and gaseous effluents released during 2005 was calculated to be

0.38 mrem compared to approximately 360 mrem received from background radiation.

Appendix H, which provides supporting documentation on radiological dose assessment, was

added to the final EIS.

Comment: Page 3-7 line 27 refers to the “PPE concept” to define the boundaries of liquid

radioactive effluents and system performance but no summary of the data is included. 

(DW-0438 87)

Response: The staff believes the citation should read “page 3-9 line 27" instead of “page 3-7

line 27.” The applicant’s Environmental Report provides tables of the bounding liquid and

gaseous effluents. References to where the tables can be found in the Environmental Report

are found in Section 5.9.2 of the EIS. The final EIS added tables of the bounding liquid and

gaseous effluents into Appendix H.

Comment: Maximum organ dose from liquid effluents is to the liver of a child. [page 5-62,

line 22, Table 5-10] (DW-0423 39)

Response: This comment is no longer applicable as the revised PPE liquid effluent source

term from the power level increase to 4500 MW(t) results in the maximum organ dose being to

the child bone. The text in the EIS reflects this change.

Comment: The dose of 18 person-rem/yr calculated using GASPAR II is for the gaseous

effluent pathway. [page 5-63, line 22] (DW-0423 40)
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NUREG-1811, Volume II 3-222 December 2006

Response: Section 5.9.3 in the EIS was revised to change “... liquid effluent..” to “...gaseous

effluent..”

Comment: The DEIS wholly incorporates the calculations and analyses of Dominion regarding

the expected routine level of radiation exposure to construction workers building new reactor

units and their appurtenant facilities at the NAPS. Has the NRC staff conducted independent

reviews to verify the accuracy of Dominion’s calculations? (DW-0437 55)

Response: The NRC staff conducted an independent review to evaluate the projected doses

to workers who may be involved in the construction of any additional units. The staff considered

the bases for Dominion’s calculation. As stated in Section 4.9.1 of the Draft EIS, Dominion

used thermoluminescent dosimeters (TLDs) and dose rate surveys at locations in and around

the NAPS protected area to estimate construction worker dose from direct radiation from NAPS

Units 1 and 2. The staff concluded that the use of TLDs was an acceptable method to estimate

doses to construction workers because it relies on actual measured dose within the protected

area. Use of information from the TLD measurements is expected to be conservative because

construction activities for the proposed ESP units would be conducted at a distance further from

Units 1 and 2 than the protected area boundary (~0.25 mi) (where the TLD measurements were

recorded). Dominion also estimated the contribution to worker dose from a fully loaded

independent spent fuel storage installation. The staff reviewed this calculation and concluded

that actual doses to construction workers would be bounded by the calculated doses. The staff

independently reviewed the Dominion approach to estimate the dose from direct radiation and

determined that it was acceptable for the purposes of this impact analysis. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: Chapter 7, Section 7.8 - The statement that the impacts of operating the new units

is ‘well below the estimated effects from natural radiation’ misses the point. The public has no

control over natural radiation, but the point of this DEIS is to evaluate the impacts of citing 2

new nuclear units so that an informed decision can be made as to its merit. (DW-1272 13)

(SE-0030 25)

Response: The primary mission of the NRC is to ensure that authorized activities are

conducted in a manner to provide adequate protection of public health and safety from the

effects of the radiological hazards posed by nuclear reactor, materials, and waste facilities. The

exposure limits for radiological protection are established by the NRC to protect workers and the

public from the harmful health effects of radiation on humans. The Draft EIS did evaluate the

radiological impacts of operating the proposed new units in Section 5.9.3 of the EIS. 

Specifically, it stated that site boundary dose to the maximally exposed individual from the

existing Units 1 and 2 and the two proposed ESP Units 3 and 4 combined were well within the

regulatory standards of 40 CFR Part 190. Section 7.8 of the EIS was revised to include this

information.
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 December 2006 3-223 NUREG-1811, Volume II

Comment: Chapter 3, Pg 3-9, Line 18 - Please explain why radioactive waste management

systems have not been identified. (DW-1272 6a) (SE-0030 19)

Response: As stated in Section 3.2.3, Radioactive Waste Management System, Dominion did

not specify radioactive waste management systems, but used a PPE concept as described in

the EIS. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: This is not a discrepancy with respect to Application Rev 6 (as referenced in

SDEIS) but the value [for the release point dilution factor in Table I-2] changed in Rev 8. 

(SE-0050 24)

Comment: The SDEIS table [Table H-1] shows the parameters used by the NRC in its

confirmatory calculation of liquid effluent doses using LADTAP II. In accordance with

Application Rev 7 and earlier, it shows a discharge flow of 10,000 gpm (22 cfs) and a dilution

factor of 10. These two parameters change in Rev 8 but, as indicated in Dominion’s letter to the

NRC transmitting Rev 8, the LADTAP II results are unaffected. (SE-0050 21)

Response: In Section 5.4.11 and Table 5.4-6 of Revision 8 to its ER, Dominion revised the

discussion on liquid effluent discharges to clarify the technical basis assumptions. Revision 8

refers to a plant effluent discharge rate of 100 gpm with a dilution factor of 1000, which yields a

dilution flow of 100,000 gpm. In previous revisions to the ER, Dominion considered a plant

effluent discharge rate of 10,000 gpm with a dilution factor of 10, which also yields a dilution

flow of 100,000 gpm. Because both of these descriptions result in the same dilution flow,

radionuclide concentrations at the discharge location would be the same, and therefore,

calculated doses to the public and biota would be the same. Accordingly, no changes were

made to this EIS as a result of these comments.

3.10.6 Other Issues

Comment: The ABWR should be included in this DEIS statement. [page 5-64, line 15]

(DW-0423 41)

Response: The commenter is referring to the Dominion analysis of alternatives (Study of

Potential Sites for the Deployment of New Nuclear Plants in the United States dated

September 27, 2002). This document does not specifically state that the Advanced Boiling

Water Reactor (ABWR) has an annual estimated occupational dose of 150 person-rem, but

references the Safety Analysis Report for the ABWR. Accordingly, no changes were made to

this EIS as a result of this comment.
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3.11 Uranium Fuel Cycle

3.11.1 Permanent Waste Storage and the Proposed Yucca Mountain

Repository

Comment: To create nuclear waste and put it on the earth is an unconscionable act. There is

no permanent, safe way to deal with it. The science to render it harmless is immature and

incomplete. (DT-0006 2)

Comment: The highly radioactive spent fuel from the projected two new nuclear reactors at

North Anna would most likely be stored on the site; where else would this high level nuclear

waste go since the Yucca Mountain repository, if ever built, has a capacity limited to the waste

from nuclear plants existing through 2012? (DW-0196 3 and DW-0744 3)

Comment: I do not see how any environmental impact statement is complete without

addressing waste and how that waste will one day be reintegrated into the environment. 

Because it can not be contained forever. The Yucca Mountain proposal is still just a possibility

(court cases are pending), and even if it were created as a national disposal it would soon fill. 

(DW-0165 3)

Comment: [Q]uestions about... the issues of waste generation and its safe, permanent

isolation...are ignored. (DW-MM2 5)

Comment: [Q]uestions about...issues of waste generation and its safe, permanent isolation

[have been ignored]. This is especially important to address considering additional waste

created by new reactors at North Anna would have to remain onsite for an indefinite period of

time. (DW-0401 5)

Comment: Another reactor or two at North Anna will each create annually between 100 and

150 metric tons additional irradiated fuel to the site. Despite the NRC’s Waste Confidence

Decision, the only site under consideration, Yucca Mountain in Nevada, is far from a done

deal... Even if Yucca Mountain is opened, the site cannot hold the high-level radioactive waste

that will be generated by existing reactors after 2010. Therefore, in addition to the waste

generated by existing reactors, waste created by new reactors at North Anna would also have

to remain onsite for an indefinite period of time... The environmental impacts of indefinite

storage must be thoroughly evaluated in the Final EIS. (DW-0437 34)

Comment: Nuclear power plant sites contain and store large amounts of the most deadly

substance known to man, nuclear waste. There is no known safe method of containing nuclear

waste. This waste will eventually leak and poison our beautiful lakes, oceans, and land,

destroying many ecosystems and causing many diseases. (DT-0008 6)
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 December 2006 3-225 NUREG-1811, Volume II

Comment: An authentic environmental impact statement must take into account waste. There

is no suitable site for nuclear waste, and as such, there is no suitable site for nuclear reactors. 

I don’t want the additional tons of radioactive [stuff] stored in my back yard. I don’t want it

stored in an American Indian reservation in Utah. I don’t want unsafe radioactive waste lasting

thousands of years and posing new terrorist targets to be in anyone’s back yard. You can do

better than this. Don’t create something you can’t make safe. (DT-0035 3)

Comment: And yet it’s very disturbing to me that the way we get all of our power, from our

lights in our living rooms to our freezers at Food Lion, is at a nuclear plant that’s continually

producing toxicwaste that we have no permanent, safe way to deal with... If our power source is

creating waste that’s going to be harmful to the earth for the next hundred thousand years, then

I think we need to find a new power source. (DT-0037 2)

Comment: There are many unresolved ...waste issues. (DW-0188 3)

Comment: The waste from nuclear power plants is an environmental poison and a deadly

health hazard. There is no safe place to store nuclear waste, and the deadly effects of it last for

tens of thousands of years. (DW-0193 3)

Comment: Waste by-products from nuclear fission of uranium and plutonium is incredibly toxic,

radioactive and long-lived, lasting for tens of thousands of years at least...How can you add to

an already huge, dangerous problem like this when you haven’t bothered to figure out a real

solution? (DW-0194 2)

Comment: The radioactivity from spent nuclear material continues. (DW-0384 3)

Comment: I want the NRC to wake up and see the horrible nightmarish junk we are leaving

behind for our children to deal with. (DW-0404 5)

Comment: I am writing to express my great concern about the possibility of the NRC granting

Dominion Power an Early Site Permit to construct new nuclear reactors at Lake Anna in Louisa

County, Virginia. I believe that to do so would be exceedingly premature, since one very

serious issue [waste] was not dealt with in Dominion Power’s Environmental Impact Statement

(EIS). I urge you not to grant Dominion Power an Early Site Permit to add new reactors to the

Lake Anna power plant until this crucial problem has been solved. (DW-0414 1)

Comment: The problem of what to do with spent fuel rods has not been adequately addressed

in the EIS. Radioactive waste remains radioactive, and thus a threat to the environment and to

human health for thousands of years. Radioactive waste can contaminate the soil, the water,

and the air. Studies show higher incidences of cancer among human populations living near

radioactive materials. Nobody wants a nuclear waste dump anywhere near where they live. 

The people living in Nevada don’t want radioactive waste at Yucca Mountain...The unsolved
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problem of how to handle nuclear waste is serious enough...to preclude the building of any new

nuclear reactors until we have a genuine solution. (DW-0414 2)

Comment: [W]e still do not have a sane or safe plan for handling nuclear waste from nuclear

plant. Until we can handle our waste properly, we should avoid making it. (DW-0482 2)

Comment: I wish to state that no more nuclear plants should be built until we find a way to

solve the tremendous waste problem it [leaves] us and generations far beyond us. 

(DW-0793 1)

Comment: There is still no viable solution to this waste problem, and it would be grossly

irresponsible for the NRC to grant ANY approval for ANY permit (no matter how early) in the

process of building new plants at North Anna; plants that would produce more waste for our

children and their children to deal with. Until waste and other important issues are fully

addressed, the NRC SHOULD NOT grant an ESP. (DW-0808 3)

Comment: The problem this toxic mass [nuclear waste] poses seems to me insoluble under

real world conditions; and yet it is one that grows worse daily, as the mass increases and the

containers age. (DW-0825 1)

Comment: My argument against building the plant is...Nuclear power creates waste, of which

no one has any idea on what to do with. ...the waste is toxic. (DW-1089 2)

Comment: [The ESP application does not consider] the fact that the U.S. still has no

permanent solution to the problem of storing nuclear waste materials. (DW-1140 2)

Comment: Numerous concerns have been raised by PEC and others over the lack of or

inadequate plans for storage, transportation and disposal of nuclear waste. (DW-1157 2)

Comment: Currently, there is no national policy on nuclear waste storage. Should the spent

fuel rods from North Anna be kept on site, or should they be shipped to another site, I believe

that they would pose a threat to the environment and local communities. (DW-MM1 7)

Comment: I am also worried about...the lack of a plan for spent reactor fuel. (DW-1151 5)

Comment: There are very many issues that are not getting adequate study, such as the waste

issue. We have tons of nuclear waste in our backyard, only less than 100 yards away from our

precious Lake Anna, and this waste is unlikely to be taken away anywhere because Yucca

Mountain repository is mired in lawsuits. It’s a political hot potato. (DT-0007 3)
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Comment: I don’t believe you when you say the issue of nuclear waste will not be an ongoing

and increasing problem. None of the waste from these new reactors will go to Yucca Mountain,

which is already full beyond its capacity. There is no other permanent high level waste dump

site even being considered at this point, much less built. So the highly toxic and dangerously

radioactive waste will stay in our county, yet the problem of nuclear waste transport from North

Anna actually gets worse day by day since the nuclear waste steadily increases and must

somehow, some day be removed. Expanding the plant by two reactors would double this

problem and increase the risk to all of us, many generations from now included. (DT-0017 3)

Comment: I don’t know where in the process that the spent fuel issue is going to be treated,

but I think it’s essential in your new staged process, but I think it is essential that issue be

treated within the context before an early site permit is given because it’s a major issue for the

site because, in effect, and as some other speakers have referred to, because of the problems

with Yucca Mountain, we are now instead of just -- nuclear reactors in general, and North Anna

in particular, will now instead of just becoming temporary holding areas before they ship the

waste off to a permanent repository, are going to become semi-permanent repositories. 

(DT-0021 3)

Comment: And so you have to look at the process of citing a reactor here now as a process of

generating a semi-permanent [spent fuel storage]; we don’t really know how long, but certainly

for many decades, many decades before there will be another solution, a repository for high

level radioactive waste. Right now that is not in the environmental impact statement. 

(DT-0021 4)

Comment: My questions about nuclear waste still remain. Since we all want a cleaner earth

and a cleaner environment, and yet we have this waste that we have to contain...No amount of

money, no amount of jobs, no amount of tax breaks for Nevada has convinced them that

nuclear energy is profitable. So if it’s not good enough for them, I don’t see how or why it is

good enough for us here...we need to see North Anna as a nuclear repository site. Envision

this because it’s very possible that nuclear waste will never leave Lake Anna. (DT-0026 1)

Comment: It means the search for new sacrificial zones and the prospect of the Lake Anna

site itself becoming a de facto permanent radioactive waste dump. (DT-0040 9) (DW-1154 14)

Comment: There is no approved plan for the disposal of highly radioactive spent fuel that will

be generated by new power plants. It will most likely be stored at North Anna indefinitely in

spent fuel pools and dry casks, and these will pose a serious health and security risk for the

people of Virginia. (DT-0047 6)

Comment: I read recently that nuclear waste generated in the state of Virginia will not be

permitted storage space in Yucca Mountain, Nevada (should that site be approved). I don’t like
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the thought of nuclear waste being stored anywhere, because I don’t think it’s ever 100% safe,

but I especially do not like the idea of having it in my backyard. (DW-0415 3)

Comment: [I]ts output would add the present mountain of nuclear waste of which we already

have trouble disposing. (DW-0306 4)

Comment: We have NO safe way of disposal of waste. (DW-0309 5)

Comment: [W]e are no closer now than we were 40 years ago to finding a safe and permanent

mode of nuclear waste disposal--radioactive waste that has accumulated by the thousands of

tons that will remain dangerously toxic for hundreds of thousand of years...and the temporary

storage methods now in use or being suggested for use generate multiple questions concerning

duration, stability, adequacy and guardianship of the stored material. (DW-0411 3)

Comment: The same problem of disposing of the spent fuel rods still exists today as it did

in 1997. There is no new technology for this. In fact, more and more states do not want

radioactive material shipped across state lines. (Yucca Mtn. does not want it). (DW-0413 3)

Comment: Nuclear waste storage and disposal – we don’t seem to have any permanent

options yet for existing nuclear waste stockpiles. (DW-0432 6)

Comment: And what are you going to do with the waste for the next 10,000,000 years?! 

(DW-0470 2)

Comment: We have been making nuclear waste for over 40 years and still do not know how to

get rid of it. And poisoning other people or other generations are not an option. Therefore we

are putting this cost on future generations while we use the energy. (DW-0528 2)

Comment: It is unconscionable that any person or any group of people on this planet would

ever be allowed to foist off onto future generations the problem of dealing with undisposable

dangerous radioactive waste. I realize the precedent has been established with waste from

military weapons and previous electricity generating plants, but that is no excuse to continue

down this non sustainable path. (DW-0648 1)

Comment: No additional permits for nuclear power generation should be issued for the North

Anna site until a permanent location for the disposal of high level nuclear waste generated by

the current and future generating plants has been approved and constructed. (DW-0800 1)

Comment: [T]here is no way to dispose of its waste, endangering our entire planet. 

(DW-0811 3)
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Comment: In my opinion, it is irresponsible to create more dangerous radioactive nuclear

waste when there is no safe disposal method or location. What is your plan for the radioactive

waste? (DW-0827 2)

Comment: Now they ask to build more reactors and they still have not built a permanent burial

site...Stop thinking of short term profits, and be responsible to our children, your grandchildren,

let us not leave a mess behind. (DW-0931 3)

Comment: Among my concerns are: Nuclear waste disposal is an ongoing problem that is

difficult if not impossible to solve. Where will it all go? This is a big country, but not big enough

that safe and suitable places can be found to bury the waste that will be generated in years to

come if these plants continue to be built. Waste from new plants will require new repositories. 

Meanwhile, all the highly-radioactive irradiated fuel from the plants will continue to be stored

on-site--not a good thing for Virginians, or anyone for that matter. (DW-0998 5)

Comment: What will be done about nuclear waste disposal? This certainly has an

environmental impact. Dealing with nuclear waste is still unresolved and since the ‘50s the

nuclear industry has not had a clue what to do with it. We have about 70,000 metric tons of

waste stored at slightly fewer than 100 sites around high-population areas of the United States. 

(DW-1181 3)

Comment: There is at this time no solution to the problem of nuclear waste, and constructing

new reactors will only worsen that problem. The proposed Yucca Mountain repository in

Nevada will not open until 2010 at the earliest, but even industry experts feel 2015 is a more

realistic best-case scenario. That doesn’t count the remaining scientific questions about the

suitability of the site, and the half-dozen lawsuits currently pending – any of which could send

the U.S. Department of Energy back to the drawing board. Even if the facility were to open as

scheduled, it’s not large enough to hold even the amount of waste expected to be generated by

currently-operating plants. Waste from new plants will require a new repository. Meanwhile, all

the highly-radioactive irradiated fuel from the plants will continue to be stored on-site. 

(DW-MM4 15)

Comment: There is no plan for the disposal of the waste from routine operations and eventual

decommissioning of the proposed reactor. What this means is that some community

somewhere will be asked and maybe forced to take this dangerous and long lasting waste. 

(DT-0040 6)

Comment: We do not have a safe depository for waste. (DW-0173 2)

Comment: [W]hat is more important is the cost of the waste to our society. Yucca Mountain

doesn’t have capacity for the waste, so where is it going to go? (DW-0181 4)
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Comment: Where would the waste go from two reactors since Yucca Mountain, if ever built,

has capacity only through 2012? (DW-0187 4)

Comment: Where would the waste go - Yucca Flats, still unbuilt will only hold current plant

waste to 2012? (DW-0195 3)

Comment: How can you even think about building new reactors when we don’t even have a

place for the waste that we have? Even if Yucca Mountain is built, - and that’s not a certainty -

that facility will only hold the waste that is currently in existence. (DW-0333 1)

Comment: [T]here remains no real plan for dealing with the vast amounts of highly radioactive

waste that will be produced with two new reactors. Where will all the waste go? (DW-0408 5)

Comment: Containment of nuclear wastes is a major problem and not a proven factor. 

(DW-0412 3)

Comment: My concerns about increasing Virginia’s and America’s reliance on nuclear energy

are based on ... the need for foolproof, long-lasting waste containment. (DW-0426 6)

Comment: I would hope that no additional plants would be built until Yucca Mountain has gone

from being a potential site for new waste to an approved, ready-for-use site, so we would not be

generating additional waste only to find we have nowhere to put it. (DW-0426 13)

Comment: I don’t believe you when you say the issue of nuclear waste will NOT be an

on-going and increasing problem. NONE of the waste from these new reactors will go to Yucca

Mountain, which is already full beyond its capacity - with already existing waste in the U.S. 

There is NO other permanent high level waste dump site even being considered at this point,

much less built -- and this process takes decades to complete. So the highly toxic and

dangerously radioactive waste from North Anna will STAY IN OUR COUNTY at an ever

increasing risk of disaster. (DW-0614 3)

Comment: And perhaps the most important argument against nuclear power is the generated

waste, which is piled up at every nuclear power plant. There is no safe place for this waste to

be stored, and if the Nevada storage site is eventually opened, there is not enough room for the

current supply of waste, let alone additional stockpiles. (DW-0641 5)

Comment: [T]here are no safe means to store spent fuel since the waste products of nuclear

reactors will pose a threat to our existence for hundreds of years. That danger is unimaginable! 

(DW-0653 5)

Comment: Where is the waste to be stored? (DW-0729 4)
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Comment: [T]he world still has not found a safe, effective way to deal with the huge quantities

of deadly radioactive waste that are produced by nuclear energy (Yucca Mountain even if it

were to be approved is breachable by virtue of its physical characteristics (seismic and salty)

and too small to hold all the waste we have produced and continue to produce). (DW-0741 2)

Comment: [T]here is no safe way to store or dispose of nuclear waste. (DW-0797 1)

Comment: There is nothing we can do with it [nuclear waste] but store it here at home or store

it in a nuclear landfill such as Yucca Mountain. If Yucca Mountain opens, it will not even hold all

the nuclear garbage we have stored around the United States. (DW-0823 2)

Comment: Nuclear Power should not be used because: Secure storage of the waste for tens

of thousands of years cannot even be imagined. (DW-0829 5)

Comment: This type of power is unsafe and produces waste that cannot be stored safely. 

Currently, as I understand it, there is no location for storage of spent fuel. (DW-0831 2)

Comment: For Sierrans the nuclear waste storage issue is unresolved, additional plants would

only exacerbate this national problem. (DW-0857 4)

Comment: A new reactor means... that the proposed reactor has no legal or scientifically

accepted place to send the “high-level” radioactive waste it would generate that is in excess to

the timeless poison already here with a doubtful future. (DW-1154 13)

Comment: We don’t want them [descendents] to get hurt by spent nuclear fuel. From a World

Watch Institute bulletin, I found that a major constituent of nuclear waste is Plutonium 239 that

can cause harm to living tissue for a quarter of a million years or 12,000 generations. 

(DT-0012 1)

Comment: The Yucca Mountain repository, if it ever truly opens, will have cost over $60 billion. 

Forbes Magazine wrote in February ‘85 -- I’ll just continue the quote that was mentioned earlier

-- “only the blind or the biased can now think that most of that money has been well spent.” 

That’s money spent on the nuclear industry. (DT-0036 4)

Comment: Saying that it’s clean ignores the fact that it creates hundreds of thousands of

pounds of highly radioactive waste that must be safely stored for tens of thousands of years. If

we are to use Yucca Mountain, all of these tons of waste must be transported across the

country, but any new reactors can’t use Yucca. It will be at capacity before it even opens. 

(DT-0036 6)

Comment: The EPA notes that Yucca Mountain is on an active seismic region with several

volcanic cones and at least thirty-three earthquake faults in the vicinity. With the half life we are
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NUREG-1811, Volume II 3-232 December 2006

dealing with, we are asking our descendants for many generations to come to manage our

waste and pay the price if it does leak. I do not want to place that burden on future Americans. 

Can we really be sure that Yucca Mountain is as sound as we think it is for thousands of years

to come? (DW-0426 14)

Comment: Additionally, the issue of nuclear power’s waste has not been resolved, one does

not need to be an expert to know there we do no have enough storage space (or any adequate

permanent storage space, Yucca Mountain) and that the transportation techniques are

imperfect. (DT-0061 3)

Comment: This DEIS has some serious deficiencies. It does not adequately discuss, analyze,

or acknowledge important and potentially important environmental impacts. It also does not

include discussion of the consequences of storing additional radioactive spent fuel wastes at the

site from addition of new reactors: in effect, North Anna is being turned into a semi-permanent

high level waste repository. [We also were unable to find any discussion of spent fuel storage

impacts in the portions of the SER available online.] Because of the deficiencies of the DEIS

and the potential for serious environmental consequences from the project, the Virginia Chapter

of the Sierra Club disagrees with the staff’s preliminary recommendation that the ESP should be

issued. (DW-0589 1)

Comment: The Draft EIS fails to evaluate the environmental impacts...of indefinitely storing the

additional irradiated fuel that will be generated by the proposed reactors onsite. In view of

problems with the Yucca Mountain repository, there is no guarantee if or when another

permanent repository ever will be available. Lake Anna would become a semi-permanent, if not

permanent high level waste repository. (DW-0589 7)

Comment: When I came in tonight I saw signs that apparently Dominion had put up saying

“clean power,” and to talk about nuclear power with nuclear waste the most dangerous

substance that we can possibly have on this earth, and it’s a substance that we don’t know what

to do with it, and to talk about that is clean makes me think I cannot believe anything that

Dominion Power has to say to me. (DT-0013 4)

Comment: I am against new power plants...because of unresolved waste disposal issues. 

Plutonium 239, a major constituent of irradiated spent fuel from nuclear power plants, has a half

life of 24,400 years, and is harmful to living tissue for 250,000 years, or 12,000 human

generations. Contemplating intentionally leaving a legacy of harm for 12,000 human

generations, in exchange for a small amount of electricity for 1 or 2 generations now, is unkind

and unreasonable. (DW-0669 2)

Comment: Then there is the issue of waste management, there is a finite area that can be

used for nuclear waste, I feel that other options must be looked at first. (DW-0802 4)
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Comment: There’s a lot of bureaucratese that was used to talk about it, but it boils down to

what the plant puts out is garbage. We don’t have those breeder reactors. It’s a nice dream. 

It’s not going to be realized for a long time, if ever. So in the meantime nuclear plant garbage is

highly concentrated, highly reactive, and will be dangerous for 10,000 or more years. 

(DT-0050 1)

Comment: The North Anna site is not appropriate for expansion. Plans for storage, transport

and long term management of nuclear waste are inadequate. (DT-0054 1)

Comment: The description of the high level waste storage facility, security of this facility and

the monitoring (frequency and type) are not addressed. (DW-1272 6b) (SE-0030 20)

Comment: No successful long-term solution for containing nuclear waste exists. NRC has

essentially ignored the issue of waste in the ESP process. (SE-0034 5)

Comment: The Draft EIS fails to evaluate the environmental impacts...Lake Anna would

become a semi-permanent, if not permanent high level waste repository. (SE-0038 8)

Comment: The reactors will create approximately 20 MT/year of nuclear waste. It is imprudent

to issue an ESP until detailed plans for safe waste management, transport, and disposal are in

place. This is not elaborated in Section 6 (SE-0045 35)

Comment: [W]aste and security are things that are basically taken off the table. ...each reactor

at North Anna produces about 20 metric tons of waste per year and about over 56,000 metric

tons already exist around the country and we have no near-term solution. I know that people

commonly say there's that mountain in Nevada. Aren't we going to take it there? I can tell you

by looking thorough at that the problem is it's not a good mountain. I mean there might be a

mountain somewhere, but that mountain is not a good mountain. So no time soon are we going

to have a safe place to secure this waste. (ST-0005 6)

Comment: There's no real plan for waste disposal. ...you propose to more than double the

amount of nuclear waste at Lake Anna, and no one has a secure long-term plan. ...Where is this

waste going to go? Who's going to pay for it? Who's going to protect it for the tens of

thousands of years? (ST-0036 6)

Comment: 3.11.1-S. The other end of it is even messier and sloppier, and it's still garbage

disposal. ...And yes, "garbage" can be a resource in future generations, but garbage is such a

euphemistic term for something that is one of the most poisonous substances on the face of the

earth. It is so poisonous, it is so nasty that it is the only power industry that has 24/7 security. 

(ST-0038 3)
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NUREG-1811, Volume II 3-234 December 2006

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the ESP]...Spent

nuclear fuel (where stored, terrorist attack protections, etc.) (SE-0022 28) (ST-0014 16)

Response: The NRC’s Waste Confidence Rule, found in 10 CFR 51.23, states:

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 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 such reactor and generated up to

that time.

In its Statement of Considerations (preamble) for the 1990 update of the Waste Confidence

Rule (55 FR 38472), the Commission addressed the impacts of the disposal of spent fuel

discharged from the current fleet of nuclear reactors operating under existing (including

renewed) operating licenses and from a new generation of operating reactors. Therefore,

the current rule covers new reactors and can be used in the staff’s review of an ESP or a

COL application. The rule was last reviewed by the Commission in 1999, when it reaffirmed

the findings in the rule (64 FR 68005, dated December 6, 1999). Furthermore, the Atomic

Safety and Licensing Board presiding over the proceeding on the Dominion application

affirmed that the Waste Confidence Rule and its subsequent amendments clearly include

waste produced by a new generation of reactors. (Dominion Nuclear North Anna, LLC,

Early Site Permit for North Anna ESP Site, LBP-04-18, 60 NRC 253, 269 [2004]). 

Accordingly, no changes were made to this EIS as a result of these comments.

3.11.2 Need for Reprocessing Spent Fuel

Comment: We did come to one agreement, some common ground, in short, to build a fuel

reprocessing plant. Now, I understand this does not fall within your purview. I argue that it

does. Presently the abundance of spent fuel is hazardous to my nation’s well-being. You are

charged with protecting me. Protect me from that. (DT-0006 6)

Comment: So first develop a [re?] processing plant. Get the technology right before you build

any more power plants. The power plants would be far more palatable to people like me. 

(DT-0006 7)
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Comment: Used nuclear fuel recycling should be implemented to provide energy for hundreds

of thousands of years. Unlike other energy generating processes that put waste directly into the

air, water, and on our surfaces, nuclear power wastes are contained, accounted for, and

managed. (DT-0014 7)

Comment: None of us are proud of the fact that there’s 70,000 metric tons of radioactive

nuclear waste stored on sites all over the nation. It’s not the way things were supposed to be,

but of course, the best plans often go awry...There was a very well thought out fuel cycle [with

fuel reprocessing] that was to be implemented, which was unfortunately derailed by fears,

uninformed fears, that occurred in political arenas in the late ‘70s. (DT-0039 1)

Comment: Nuclear power can and will be a renewable power source. The original vision was

that we would mine a sufficient amount of uranium to feed a nuclear fuel cycle, which would

eventually become self-perpetuating. The vision was that after a certain period of time we

would be able to stop mining natural uranium because we were developing technologies which

generated their own fuel. (DT-0039 2)

Comment: [C]ontinued government interest in reprocessing, combined with the failure to

establish a national repository for irradiated nuclear fuel, should compel the NRC to consider

the impacts of spent fuel reprocessing in the Final EIS. (DW-0437 35)

Comment: Nuclear fuel has been in the earth since it was created and continues to decay in

the environment today. By utilizing it in the nuclear power plant, some of it is turned into energy

and removed from the environment--a cleaning up of the planet. The nuclear waste that is

created by burning the nuclear fuel could be recycled into another nuclear fuel if that process is

ever approved. (DW-1007 6)

Response: During the Carter administration, the Nuclear Nonproliferation Act of 1978, P.L.

95-242, was enacted; it significantly impacted the disposition of spent nuclear fuel by deferring

indefinitely the commercial reprocessing and recycling of plutonium produced in the U.S.

commercial nuclear power program. While the ban on the reprocessing of spent fuel was lifted

during the Reagan administration, economic circumstances changed, reserves of uranium ore

increased, and the stagnation of the nuclear power industry provided little incentive for industry

to resume reprocessing. With interest in deploying new nuclear power plants in recent years,

during this Bush administration, the Energy Policy Act of 2005, P.L. 109-58, was enacted; it

authorized the DOE to conduct an advanced fuel recycling technology research and

development program to evaluate proliferation-resistant fuel recycling and transmutation

technologies that minimize environmental or public health and safety impacts. Consequently,

while Federal policy no longer prohibits reprocessing and interest is increasing, additional work

is needed before commercial reprocessing and recycling of plutonium produced in the U.S.

commercial nuclear power program is likely.
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Nevertheless, Table S–3 from 10 CFR 51.51 does include impacts from reprocessing. As

outlined in Section 6.1 of the EIS, the contributions in Table S–3 for reprocessing, waste

management, and transportation of wastes are maximized for either of the two fuel cycles

(uranium only and no recycle); that is, the cycle that results in the greater impact is used. As

discussed in the EIS, 10 CFR 51.51(a) requires that the applicant use Table S–3 as the basis

for evaluating the contribution of the environmental effects of the uranium fuel cycle for lightwater reactors. Section 6.1 of the EIS was modified to indicate that Federal policy does not

prohibit spent fuel reprocessing.

3.11.3 Expiration of Low-Level Waste Pact with Barnwell

Comment: The NRC is equally dismissive in its treatment in the EIS for the disposal of

so-called low level radioactive waste, and I think it’s important to get to the point here that

Virginia will lose its queue in disposal of this so-called low level radioactive waste at Barnwell,

South Carolina, year 2008. So effectively the current units will have all of this orphaned waste

and nothing is planned for the waste for the three and four. It’s not even contemplated. So how

is it that the EIS reduces this concern [waste] to small and acceptable when, in fact, it doesn’t

even fully evaluate the uncertainty associated with not having any place to put even the low

level radioactive waste. (DT-0040 5)

Comment: A new reactor means more radioactive waste with NO proposed permanent

disposal site after 2008 for Virginia’s so-called “low-level” radioactive garbage. (DW-1154 12)

Comment: Right now, this so-called “low level” radioactive waste from the North Anna reactors

is being shipped to South Carolina and Utah and dumped in soil trenches. Some is stored on

site but the waste is generally shipped to Barnwell, SC or Envirocare, UT for disposal. The

Lake Anna community should be aware that Utah citizens are fighting the expansion of that

dump there which takes a portion of the nuclear waste generated by nuclear power. 

(DW-1154 8)

Comment: NRC’s dismissive treatment in the EIS of the absence of disposal capacity for

so-called “low-level” radioactive contamination issues is even more egregious. (DW-1154 3)

Comment: [F]ederal regulations allow for burial of this waste in unlined ditches with only

100 years of institutional control. All of the six U.S. burial sites for so-called “low-level”

radioactive wastes have leaked and four are closed. There is no way to permanently isolate socalled “low-level” radioactive waste from the environment. (DW-1154 6)

Comment: How are environmental concerns and consequences created by Virginia’s

potentially orphaned radioactive waste stockpiles being casually dismissed? These issues are

conspicuously missing from the North Anna EIS. Please provide the analysis on how the
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so-called “low level” radioactive waste will be responsibly managed for new reactors in the

absence of a low level radioactive waste facility. (DW-1154 9)

Response: Starting in 2008, the Barnwell, South Carolina, low-level waste disposal facility will

only accept low-level waste from the Atlantic compact states (Connecticut, New Jersey, and

South Carolina). Virginia is in the Southeast compact. Because other waste generators

(e.g., hospitals that generate radioactive waste from medical treatment and diagnostic tests) in

the Southeast compact rely on the Barnwell disposal facility, an alternate waste disposal

location would need to be negotiated prior to 2008. 

NRC’s Generic Environmental Impact Statement for License Renewal of Nuclear Plants

(NUREG-1437 [Section 6.4.4.2]) is instructive in evaluating environmental impacts associated

with power reactors and can be used for other licensing purposes (e.g., ESP applications) as

well. In NUREG-1437, the staff concluded that there should be no significant issues or

environmental impacts associated with interim storage of low-level waste generated by nuclear

power plants with renewed licenses. Interim storage facilities would be used until these wastes

could be safely shipped to licensed disposal facilities. NUREG-1437 (Section 6.4.4.5) also

discusses an evaluation of the impacts of extending on-site storage of low-level waste. 

Extended storage was assumed for 20 years, the length of the license renewal period. 

Extended storage is also covered by the existing regulatory framework. Accordingly, no

changes were made to this EIS as a result of these comments.

3.11.4 Opposition to Generation of Additional Waste

Comment: It means more nuclear waste that will be dumped, incinerated or potentially

recycled into consumer goods. (DT-0040 10)

Comment: [A new reactor] means more nuclear waste that will be dumped, incinerated or

potentially recycled into consumer goods. (DW-1154 15)

Comment: [T]here is the radioactive material left to be disposed of. (DW-0151 3)

Comment: I don’t want more radioactive waste anywhere, let alone in my backyard. 

(DW-0165 6)

Comment: [We are opposed to nuclear expansion] until science has discovered a way to

neutralize the waste. It is patently immoral to poison our Earth to this degree. (DW-0192 2)

Comment: Nuclear waste is another problem. I do not want nuclear waste passing through my

town, and yet, I fear this is already happening across America to unsuspecting citizens. In

Utah, where nuclear energy supporters wish to send the waste, there is a strong opposition, and
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I would be opposed as well if it were designated for Virginia. Nuclear waste is not safe nor is it

clean, the standing argument for expansion of nuclear energy. (DW-0822 3)

Comment: We don’t need the toxic, radioactive waste these plants will bring. (DW-0967 2)

Comment: Nuclear waste is the worst kind of waste, and we don’t need any more of it. 

(DW-1069 3)

Comment: Disposal of the waste product generated by nuclear power should be enough to

make use of this power source only as a last resort. (DW-0407 5)

Comment: Please compel Dominion to use the money they would have used for building these

reactors to research safer methods to handle the byproducts of current production. (DW-0616)

Comment: [H]ave you considered the environmental impact of more nuclear waste? 

(DW-0846 3)

Comment: We still have not adequately cleaned up waste from previous plants. (DW-0867 2)

Comment: These are not “acceptable” or “small” consequences and it is irresponsible of NRC

to allow this new source of radioactive waste generation and contamination to be sited,

constructed or operated. (DW-1154 16)

Response: The NRC staff considered the generation and processes to ensure the safe

handling of additional radioactive waste. More waste would be generated, but the low-level

waste would be handled and disposed of in accordance with current Federal and State

regulations. Regarding disposal of spent fuel, the NRC’s Waste Confidence Rule, found in

10 CFR 51.23, states:

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 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 such reactor and generated up to that time.

In its Statement of Considerations (preamble) for the 1990 update of the Waste Confidence

Rule (55 FR 38472), the Commission addressed the impacts of the disposal of spent fuel
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discharged from the current fleet of nuclear reactors operating under existing (including

renewed) operating licenses and from a new generation of operating reactors. Therefore, the

current rule covers new reactors and can be used in the staff’s review of an ESP or a COL

application. The rule was last reviewed by the Commission in 1999, when it reaffirmed the

findings in the rule (64 FR 68005, dated December 6, 1999). Furthermore, the Atomic Safety

and Licensing Board presiding over the proceeding on the Dominion application affirmed that

the Waste Confidence Rule and its subsequent amendments clearly include waste produced by

a new generation of reactors. (Dominion Nuclear North Anna, LLC, Early Site Permit for North

Anna ESP Site, LBP-04-18, 60 NRC 253, 269 [2004]). Accordingly, no changes were made to

this EIS as a result of these comments.

Comment: [T]his is an environmental study, correct? Do you take into consideration your

waste products while you are in construction and through the next 20 or 30 years into a

landfill?...[radioactive and non-radioactive waste will be generated during the construction

process] because you are going to have low-level radiation at every reset -- like even when you

clean your floors, you have low-grade radiation going into our landfill. (ST-0003 1)

Comment: Regarding the production of more nuclear waste that was not present on the planet

before humans arrived, it is immoral to create this waste for people to deal with 75,000 years

from now, when we do not have a clue as to how to guarantee the safety of storage of waste for

that period of time. (SE-0010 3)

Response: The NRC staff considered the generation and processes to ensure the safe

handling of additional radioactive waste. More waste would be generated, but the low-level

waste would be handled and disposed of in accordance with current Federal and State

regulations. Accordingly, no changes were made to this EIS as a result of these comments.

3.11.5 Support for New Units

Comment: I prefer an energy source that makes solid waste that is easily identifiable,

quantifiable, and retrievable. And that energy source is nuclear. (DW-1148 11)

Comment: Currently, there is a national policy on nuclear waste storage that is being held

hostage by politics. (DW-0370 6)

Comment: I would like to add that as an engineer who has years of experience working and

performing research in the management of nuclear waste, I can say with confidence that the

problems of transportation and disposal are political and not technical. (DT-0020 5)

(ST-0012 4)
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Comment: [S]hould the spent fuel from North Anna be kept on site, or shipped to another site,

I believe that they would pose little threat to the environment and local communities. Spent fuel

cask technology is well-developed and well-regulated. There is little proliferation risk associated

with the spent fuel under current regulations. (DW-0370 7)

Comment: Disposal of radioactive waste is not an environmental or technical problem. Both

North Anna and Surry Power Stations safely store used fuel at their sites. (DT-0014 6)

Comment: The second thing that has struck me recently is the progress being made in waste

management. I worked on the Yucca Mountain project from 1993 until 2001, and those were

tough years. We grappled with a lot of issues about disposal of nuclear waste...It was a lot of

work, and that work is finally coming to fruition this year with the DOE scheduled to submit a

license application to the NRC before the end of 2005. (DT-0032 4)

Comment: [O]ne of the biggest complaints of the public with nuclear power is the waste that

creates, and I just wanted to take a minute to put it in the scope, put it in scope what this waste

is for all of you. ...All of the nuclear waste I would generate in my entire life time is the size of my

wallet after it's vitrified. (ST-0027 1)

Comment: The byproducts of nuclear power are the most manageable of energy waste

products, being totally contained, retrievable, and reusable. (SE-0025 3)

Comment: If we run out of space up at North Anna to put fuel, I have 30 acres down at

Goshen. You can live down there. I don't have any problem with that. (ST-0015 2)

Response: These comments provide general information supporting the belief that radioactive

waste can be disposed of safely. They do not provide information specific to this EIS.

Accordingly, no changes were made to this EIS as a result of these comments.

3.11.6 Other Comments

Comment: The issue of storing radioactive spent fuel rods. Well, this is my take on it. We’ve

heard some this evening and probably will hear more, but these rods are not really “spent.” 

They are just not efficient anymore. They’re still radioactively hot. So they must be stored in

pools of water to keep them cool. As more and more of these rods are stored, the pools get

crowded, and the danger of exposed rods increases. Exposed rods can spontaneously ignite,

and the resulting fire spreads radioactive particles into the air. Also, low water levels increase

this danger. The Spotsylvania County Planning Board is right to be concerned about this, and

so are we. (DT-0009 2)
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Response: When fuel rods are removed from a reactor, they are moved into a nearby spent

fuel storage pool via a transfer canal to allow for radioactive decay of short-lived radionuclides. 

The pool contains racks into which the spent fuel assemblies are placed and remain

underwater. The racks are designed such that fuel assemblies can only be placed in a specific

configuration to prevent inadvertent nuclear criticality. The racks also contain neutron

absorbing materials to maintain the fuel assemblies in a subcritical condition. A postulated

accident that could lead to loss of cooling and in turn could lead to a fire of the zirconium

cladding, could occur under unique circumstances, but ignition would not be spontaneous. It

takes a considerable period for spent fuel to reach the point where the cladding can ignite. After

the fuel has been out of the reactor for several years, it no longer generates heat that could lead

to ignition. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The draft EIS lacks a consideration of the environmental and public health impacts

resulting from military applications of depleted uranium (DU), a byproduct of the enrichment

process of the fuel cycle. (DW-0437 36)

Comment: [T]here is not a complete consideration of the impacts of managing this substance

as a waste. There is no repository established for the permanent disposition of depleted

uranium, but the impacts of such a hypothetical facility should be considered. (DW-0437 37)

Response: While the fuel cycle results in depleted uranium, there is no relationship between

the proposed action and any decision on how to use depleted uranium. Therefore, the

environmental and public health impacts resulting from military applications of depleted uranium

and deposition of depleted uranium waste are beyond the scope of the EIS. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: The draft EIS estimates that, for the reference reactor-year (a 1000-MW(e) LWR),

1.09 Million MT of raw ore would be required to produce 1200 MT of yellowcake for ultimate use

as fuel after conversion, enrichment, and fabrication (DEIS, Section 6.1.2.5). Over time, as

worldwide uranium ore supplies are depleted, requiring exploitation of less pure deposits of ore,

would this ratio of ore to yellowcake increase? If so, would the environmental impacts of mining

and milling become greater? (DW-0437 38)

Response: If less pure ores are used, the ratio of raw ore to yellowcake would increase and

the associated environmental impacts would increase proportionally. This also assumes that no

new high purity ore deposits are found and no fuel is reprocessed. The environmental impacts

in the EIS were taken from Table S–3 of 10 CFR 51.51(a), which assumed conventional

underground and strip mining of uranium ore. Two factors that will offset this increased impact

are (1) the increased reliance on in situ leach mining for uranium and (2) increased reliance on

foreign sources for uranium. In situ leach mining has fewer environmental impacts compared to

underground and strip mining of the ore because (1) the dusty ore crushing process is not

needed and (2) extensive waste tailings are not generated. All steps in the in situ leach mining
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operation have the uranium in a less dispersible liquid form. Foreign-origin uranium accounted

for 83 percent of the uranium purchases for U.S. civilian nuclear power plants in 2005

(EIA 2006). Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Chapter 6, Pg 6-10, Line 33 - Please justify that the thermal effects from the use of

all units would be negligible. (DW-1272)

Response: As discussed in the EIS, thermal impacts were derived from NUREG-1437 which in

turn were derived from Table S–3 of 10 CFR 51.51(a) and WASH-1248 (Environmental Survey

of the Uranium Fuel Cycle). The principal use of water in the uranium fuel cycle is to remove

waste heat from the power stations supplying electrical energy to the enrichment facilities. 

Impacts evaluated in the EIS assumed use of gaseous diffusion plants to enrich the uranium. 

Assuming use of the gaseous diffusion plants, water thermal discharges are only 4 percent of a

1000-MW(e) LWR-scaled model using cooling towers. The use of centrifuge uranium

enrichment technology would result in smaller thermal effects. Accordingly, no changes were

made to this EIS as a result of this comment.

Comment: Equally as startling is the move by the nuclear industry, NRC, EPA, and other

federal agencies to deregulate radioactive contaminated materials - that is to pretend it is not

radioactive at all and dump it in regular landfills, hazardous (not radioactive-licensed) landfills,

incinerate it with regular trash, and worse yet redefine it as a retrievable resources to be

recycled into everyday consumer goods. (DT-0040 8 and DW-1154 11)

Response: Nuclear reactor licensees are authorized to dispose of licensed material in

accordance with NRC’s regulations under 10 CFR Part 20. The commenter is likely referring to

a rulemaking activity under the title “Controlling the Disposition of Solid Materials,” Rulemaking

Identifier Number (RIN) 3150-AH18. Future generic rulemaking on controlling the disposition of

such solid materials is beyond the scope of this EIS. Accordingly, no changes were made to

this EIS as a result of this comment.

Comment: In addition to the highly radioactive irradiated fuel, there is a steady stream of

radioactive liquids, solids, gasses, sludges emitting from reactors that remain radioactively and

biologically hazardous for hundreds, thousands, literally millions of year. ...All of these are now

“low-level” radioactive wastes. As NRC has acknowledged these same radionuclides are

routinely released from nuclear power reactors into the surrounding environment. Others are

captured in filters, sludges, resins, evaporator bottoms that can give a lethal dose of radiation in

just 20 minutes, yet still categorized as “low-level.” Isn’t it peculiar that as long as these poisons

stay in the fuel rods they are considered “high level” radioactive waste. But when they leak out

of the fuel rods (a common occurrence) into the water that circulates throughout the reactor,

when they are filtered from that water, when they get into the pores of the concrete base mat
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and containment dome, when they concentrate in pipes, they are suddenly called “low-level”

radioactive waste. The same plutonium contamination that is “high level” in the fuel rod is

dubbed “low-level” when it leaks out. (DW-1154 5)

Comment: Now, some of this uncertainty has to be taken into account about the excess to

Yucca Mountain. It has been referenced here, but we did a “back of the envelope” calculation,

and with North Anna 1 and 2 alone, the excess to Yucca Mountain with a 60-year license is

1162 metric tons excess to Yucca Mountain. With the addition of North Anna 3 and 4, and

that’s with a 40-year license on those two units, it goes up to -- well, that’s 2346. So we’re

talking about an excess here of 3508 metric tons...isn’t it peculiar that as long as these poisons

stay in the fuel rods, that they are considered high level, but when they leak out of the fuel rods,

which is a common occurrence, into the water that circulates around the fuel and throughout the

reactor and they’re filtered from that water and they go into the pores of the concrete base mat

and they irradiated and activate the metal that surrounds that. Then they become so-called low

level radioactive waste. The same plutonium contamination that is high level in the fuel is

dubbed low level when it leaks out, and these are the kinds of uncertainties that should not be

accepted and, in fact, this community needs to stand with the communities around the country

that are tired of being dumped on by the operation of these reactors. (DT-0040 4)

Response: Wastes are categorized according to the half-lives and concentrations of the key

radionuclides. In accordance with 10 CFR Part 61, low-level waste is classified as A, B, C, or

greater than Class C, with more stringent disposal methods going from A to C. Licensed

low-level waste disposal facilities must protect the general population from release of

radioactive material, protect workers, protect inadvertent intruders after institutional controls

cease, and ensure disposal site stability. In accordance with a 1989 rulemaking (54 FR 22578),

the NRC requires that greater than Class C waste be disposed in a deep repository unless

disposal elsewhere has been approved by the Commission. Accordingly, no changes were

made to this EIS as a result of these comments.

Comment: On the topic of waste disposal ... [page 6-15], the report states, “For high-level and

transuranic wastes, the Commission notes that these are to be buried at a repository, such as

the candidate repository at Yucca Mountain, and that no release to the environment is expected

to be associated with such disposal, although it has been assumed that all of the gaseous and

volatile radionuclides contained in the spent fuel are released to the atmosphere before the

disposal of the waste.” I am alarmed that volatile radionuclides will be released into the

atmosphere as a matter of standard practice. (DW-0426 17)

Response: A certain quantity of gaseous and volatile radionuclides contained in the spent fuel

may be released during storage in the spent fuel pool. These releases are part of the routine

releases reported to the NRC; the spent fuel is monitored. Accordingly, no changes were made

to this EIS as a result of this comment.
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Comment: The impacts also have the potential to affect a much greater area in the case of

facility performance failure/problems and waste generation and disposal. (DW-0817 5)

Response: The EIS evaluated the environmental impacts of postulated accidents in

Section 5.10 for facility operation and Section 6.2 for transportation. Facility operation accidents

included both design-basis accidents and severe accidents. While the effects of transportation

accidents, based on Table S–4 (10 CFR 51.52), were evaluated for high-level wastes and spent

fuel en route to a high-level waste repository, postulated accidents at a Federal waste repository

were not evaluated. Accidents at a repository would be evaluated as part of another licensing

action and are outside the scope of this EIS. Accordingly, no changes were made to this EIS as

a result of this comment.

Comment: I’d like to address the source of the uranium ...[page 6-4], “Another change is the

elimination of the U.S. restrictions on importation of foreign uranium. The economic conditions

of the uranium market now and in the foreseeable future favor full utilization of foreign uranium

at the expense of the domestic uranium industry. These market conditions have forced the

closing of most U.S. uranium mines and mills, substantially reducing the environmental impacts

in the U.S. from these activities.” This statement raises two concerns. First, if we build

additional facilities at North Anna, we are exacerbating our dependence on foreign fuel, merely

replacing oil with uranium. This will not allow us the upper hand we strive to have in foreign

policy. (DW-0426 8)

Comment: [Refers to comment WC–0427 8] Second, the statement says that using foreign

sources of uranium substantially reduces the environmental impacts in the United States. This

means that we are simply shipping environmental problems to other countries for other people

to deal with. If the negative environmental impacts of uranium mining are not something we

wish to impose on our own citizens, we should not feel comfortable imposing them on other

members of the human race. This is callously conveying disrespect for the health and quality of

life desired and deserved by all human beings. Additionally, it will lead to another reason for

people in other countries to resent the United States of America, creating more antagonism, and

therefore more difficulties in foreign policy. (DW-0426 9)

Comment: My concerns about increasing Virginia’s and America’s reliance on nuclear energy

are based on the effect of mining for uranium on the environment and on foreign policy. 

(DW-0426 3)

Response: Dependence on foreign sources of uranium is linked to market forces and the price

of uranium. If uranium prices remain the same or decrease, U.S. suppliers likely will not be able

to compete with foreign providers. If uranium prices increase, there will be a point at which U.S.

suppliers believe they can be price competitive. Uranium mining has its own unique worker

protection issues. If the U.S. suppliers can be price competitive with the additional interest in

new plants and with operators of existing plants renewing their operating licenses, then in
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resuming mining operations, they must comply with U.S. occupational protection standards. 

Foreign sources of uranium have to comply with their own national occupational protection

standards. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: [B]oth ends of the nuclear industry are sloppy and messy. The mining part of it

creates a kind of pollution that's kind of deadly downstream, and is kind of bad for the miners. 

(ST-0038 2)

Response: Uranium mining is regulated separately from nuclear power plants. OSHA has

authority over worker protection issues, and mine tailings are regulated by the EPA through the

Resource Conservation and Recovery Act (RCRA–Public Law 94-580, October 22, 1976). 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: According to DEQ’s Waste Division, the Draft EIS/SDEIS addressed solid waste

issues and sites to some extent, but did not address hazardous waste issues or sites, or include

a search of waste-related data bases. [Two websites were provided in this comment letter from

VDEQ.] (DW-0439 22) (SW-0017 61)

Comment: The draft EIS indicates that solid waste would be handled in compliance with

appropriate state and federal regulations (page 3-10, Section 3.2.4). (DW-0439 23)

Comment: Chapter 3, Pg 3-10, Line 15 - Enough information is available to definitively [The

SDEIS should] state the State and Federal regulations that apply [to nonradioactive effluent and

solid waste releases]. (DW-1272 8) (SE-0030 22)

Response: Hazardous wastes are discussed in general terms in Section 3.2.4 of the EIS. 

Health impacts are discussed in Section 4.8 for construction and Section 5.8 for operations. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: DEQ's Waste Division did a cursory review of its data files and did not find any

[solid or hazardous] waste sites that would affect, or be affected by, the proposed project. 

(SW-0017 61b)

Response: This comment provides confirmation that the proposed ESP would not affect or be

affected by solid waste or hazardous waste sites. Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: The draft EIS further states for the high level radioactive waste that, quote, “There

is some uncertainty with respect to the regulatory limits for the off-site releases.” And they go

on to say that we assume that these limits are developed. And I would point out the word

“assume.” And they go on to say that the waste confidence decision with that assumption that a

repository can and likely be developed which will comply with such regulations. Now, they say
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NUREG-1811, Volume II 3-246 December 2006

that the consequence will be acceptable and small, but I submit that while this may look good

on paper, it is not based in reality. The EIS fails to quantify the uncertainty which they have

identified, which continues to plague this industry and the nuclear waste question since the first

couple, maybe cannot be considered small or acceptable when talking about the permanent

contamination of our air, land, water, and gene pool. (DT-0040 3)

Comment: The draft EIS further states that for high-level waste and the irradiated fuel

disposal, “there is some uncertainty with respect to regulatory limits for offsite releases of

radioactive nuclides for the current candidate repository site. ...Staff goes on to say that despite

this uncertainty they are able to conclude that the impacts to this community and communities

into the distant future are “acceptable” and “small.” This might look good on paper to some, but

unfortunately it is not based in reality. The EIS fails to quantify the “uncertainty” which

continues to plague the nuclear waste question since the first cupful was generated over a half

century ago. “Maybe” can not be considered “small” or “acceptable” when talking about the

permanent contamination of our air, land, water, and gene pool. Please quantify the identified

uncertainty in the DEIS. (DW-1154 2)

Response: The primary mission of the NRC is to ensure that authorized activities are

conducted in a manner to provide adequate protection of public health and safety from the

effects of the radiological hazards posed by nuclear reactor, materials, and waste facilities. The

exposure limits for radiological protection are established by the NRC to protect workers and the

public from the harmful health effects of radiation on humans. The regulatory limits for offsite

releases from a Federal repository will be established by the EPA and the NRC as part of

rulemaking activities. Since the rulemaking is not yet complete, the regulatory limits have not

been finalized. Rulemaking RIN 3150-AH68 is titled “Implementation of a Dose Standard After

10,000 Years” and will not be completed by the time this EIS is issued. Accordingly, no

changes were made to this EIS as a result of these comments.

Comment: Section 6.0 should include an analysis of nuclear waste disposal. (DW-0438 168)

Response: Section 6.1.1.6 of the Draft EIS entitled “Radioactive Wastes” includes an analysis

of nuclear waste disposal. Accordingly, no changes were made to this EIS as a result of this

comment.

3.12 Transportation of Waste

Comment: Let’s say you do find a safe place to bury the waste. Then you have to transport it

out of North Anna and other plants by rail...I have no faith that there won’t be a nuclear spill at

some point...There’s only one way to handle it: DON’T DO IT! And certainly don’t add to the

risk by building more plants that create the waste! (DW-0194 3)
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Comment: And how is it possible to transport the waste from the site in a safe and inexpensive

way? All forms of transport are also possible terrorist targets, not to mention the possibility of

an unfortunate accident! (DW-0408 7)

Comment: My concerns about increasing Virginia’s and America’s reliance on nuclear energy

are based on ... risks relating to transportation of radioactive material to and from the plant. 

(DW-0426 5)

Comment: The problem of nuclear waste TRANSPORT from North Anna ACTUALLY gets

worse each day, since the nuclear waste steadily increases and MUST sooner or later be

somehow removed. This proposal to expand the plant by two reactors will double this currently

hidden problem and increase the risk to everyone in this room, their children, and many

generations beyond. DON’T make it worse than it already is. (DW-0614 10)

Comment: One of the nuclear engineers who spoke in favor of the permit said in a dismissive

tone that concerns over the transporting of highly radioactive nuclear waste across the country

were a political issue, not a scientific issue. ...Its political nature does not diminish its terrible

damage. (DW-0410 3)

Comment: If transported by rail or truck across the United States, there is the ever-present

possibility of an accident...A rail accident is an even greater risk because nuclear waste

shipping containers are not required to undergo full physical safety testing for collisions, and the

ability of the containers to withstand a high impact rail collision (especially one involving fire) is

therefore not fully known. (DW-0196 5 and DW-0744 5)

Comment: Such an accident [transportation of waste accident] would leave a legacy of

cancers and other debilitating diseases in affected communities. (DW-0196 6 and DW-0744 6)

Comment: This section [Section 6.2] and the accompanying Appendix G of the Draft EIS do

not give adequate weight and consideration to the possibility and consequences of severe

accident scenarios resulting from the transportation of spent nuclear fuel. The possibility of

extreme accidents, while slight, exists, as evidenced by recent incidents such as the Baltimore

train tunnel fire of 2001 and the more recent accident in Graniteville, South Carolina in January,

where a violent train crash and release of chlorine killed nine people, sent hundreds to the

hospital, and required thousands to evacuate their homes. (DW-0437 39)

Comment: I would think that the recent train crash and subsequent chlorine spill in South

Carolina would make some people stop and think about putting a nuclear power plant in North

Anna. What if that train was carrying nuclear waste? The people in Graniteville have been able

to return to their homes (after only about a week) and only about 9 were killed. Had that been

nuclear waste being transported the area would be uninhabitable for decades or centuries. 

(DW-0729 2)
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NUREG-1811, Volume II 3-248 December 2006

Comment: Our concerns are for insurance and bonding against costs of a major nuclear

accident and the dangers of transportation of this spent fuel. Our concerns are for security and

safety of our members and citizens of Virginia. Washington, D.C. is only 90 miles down wind

and less than forty from Richmond, Fredericksburg, and Charlottesville where many of our

members reside. (DW-0857 5)

Comment: No credence can be put into Section 6.2.4 and the conclusion that the impacts are

SMALL given the starting statement of “considering the uncertainties in the data and

computational methods.” (DW-0438 167)

Response: The NRC and U.S. Department of Transportation (DOT) regulate the transport of

radioactive materials in the United States. The NRC is primarily responsible for establishing

performance requirements for transportation packages (Type B and fissile material packages,

including spent fuel shipping casks) containing higher-risk radioactive material packages. The

DOT establishes design requirements for all other radioactive material packages, including

Type A, industrial, and excepted packages. The DOT also establishes other transportation

requirements, including classification of materials, external radiation levels, route selection,

communications (e.g., marking, labeling, placarding), vehicle safety, and driver training and

qualifications. Waste transportation packages are designed to withstand a series of tests that

simulate normal conditions of transport and hypothetical accident conditions.

The NRC conducted several studies to evaluate the risks associated with the transportation of

radioactive material. The NRC issued Final Environmental Statement on the Transportation of

Radioactive Material by Air and Other Modes, NUREG-0170, which was published in 1977, to

support the 10 CFR Part 71, “Packaging and Transportation of Radioactive Material”

rulemaking. Based on the NRC staff’s recommendations in NUREG-0170, the Commission

concluded that the transportation regulations are adequate to protect the public from the risks

associated with the transportation of radioactive materials, including spent fuel. The NRC

sponsored another study in the 1980s titled Shipping Container Response to Severe Highway

and Railway Accident Conditions, NUREG/CR-4829, which was published in 1987, also known

as the “Modal Study.” Based on the results of NUREG/CR-4829, the NRC staff concluded that

NUREG-0170 overestimated spent fuel accident risks by about a factor of three. In the 1990s,

the NRC initiated a spent fuel study titled Reexamination of Spent Fuel Shipment Risk

Estimates, NUREG/CR-6672, which was published in 2000. NUREG/CR-6672 focused on the

risks of a modern spent fuel transport campaign from reactor sites to possible interim storage

sites and/or permanent geologic repositories. This study concluded that accident risks were

much less than those estimated in NUREG-0170 and that more than 99.99 percent of

transportation accidents are not severe enough to cause a release of radioactive material from

a NRC-certified spent fuel cask. While very severe accidents could cause cask damage, the

studies show that releases of material would be small and pose little risk to the local

population/public. The most severe accidents might cause greater releases, but their likelihood

is so remote that the NRC considers the risk to public health to be low.
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The NRC has sponsored studies to analyze the consequences of specific accident scenarios on

rail and truck transportation casks carrying spent fuel. For example, the NRC undertook an

investigation of a July 2001 accident that involved a freight train carrying hazardous materials

that derailed and caught fire while passing through the Howard Street railroad tunnel in

downtown Baltimore, Maryland, to determine the possible regulatory implications of this

particular event for the transportation of spent fuel by railroad. NRC assembled a team of

experts from the National Institute of Standards and Technology (NIST), the Center for Nuclear

Waste Regulatory Analyses (CNWRA), and the Pacific Northwest National Laboratory (PNNL)

to determine the thermal conditions that existed in the Howard Street tunnel fire and to analyze

the effects of this fire on various spent fuel transportation cask designs. The staff concluded

that the likely spent fuel transportation casks analyzed would withstand a fire with thermal

conditions similar to those that existed in the Baltimore tunnel fire event. No release of

radioactive materials would result from exposure of the casks analyzed to such an event.

NRC review and certification of transportation package designs, fabrication in accordance with

NRC-approved quality assurance programs, shipment controls, implementation of security

measures, and inspections help assure the safe and secure transport of spent fuel and other

high-risk radioactive materials in the United States. Based in part on NRC’s regulatory

oversight of radioactive materials in transport, the transportation of high-risk sources such as

spent nuclear fuel and radioactive wastes has an exemplary safety record in the United States. 

Since 1964, there have been more than 2700 shipments of spent nuclear fuel in the United

States, and although a few accidents involving these spent fuel shipments have occurred, there

was no release of radioactive materials. The NRC conducts periodic evaluations to determine

the effectiveness of transportation requirements and whether there is any need for new

regulations, policies, or technical improvements to ensure continued protection of public health

and safety, and the environment.

Changes were made to Section 6.2 and Appendix G of the EIS as a result of these comments.

Comment: What is the rationale for not using the PPE in the transportation analysis (Page 3-4

line 37)? Mixing methodologies weakens the conclusions that can be drawn. (DW-0438 83)

Response: Dominion chose not to develop a PPE for transportation. Rather, Dominion

conducted a detailed analysis of the environmental effects of transportation of fuel and waste to

and from the reactor in accordance with 10 CFR 51.52(b). NRC regulations do not preclude the

approach taken by Dominion and, furthermore, a PPE for transportation is not required by NRC

regulations. Dominion’s analysis was judged by the NRC staff to be reasonable, yet bounding,

and confirmatory reviews conducted by the NRC staff concluded that Dominion’s results were

similar to those developed by the staff. Accordingly, no changes were made to this EIS as a

result of this comment.
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3.13 Decommissioning

Comment: Decommissioning experience at reactors around the country reveals that

radioactivity will remain at the sites long after the reactors are shuttered and the operating

company has left town with its liability. A new reactor will further contaminate this area. How

much is cleaned up depends on the political clout of the community and a place to send the

radioactive contamination. (DT-0040 7)

Comment: [T]he final decommission cost is outrageous. (DW-0198 3)

Comment: I am also concerned about the costs of cleanup of these power plants if the

companies that own them go bankrupt - which will happen eventually. This will mean that

taxpayer money will be used to clean up the irresponsibility of another industry. Don’t you think

one Superfund was enough? (DW-0807 2)

Response: These comments are not related specifically to the decommissioning impacts of the

North Anna ESP units. The environmental impacts from decommissioning a permanently shut

down commercial nuclear power reactor are discussed in Supplement 1 to NUREG-0586,

Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, which was

published in 2002. For most environmental issues, the impacts from decommissioning activities

are considered small. NRC requirements establish a framework to ensure that

decommissioning of all nuclear reactor facilities will be accomplished in a safe and timely matter

and that funding will be available for this purpose. Each licensee is required by the provisions

of 10 CFR 50.75 to establish a Decommissioning Trust Fund to assure that sufficient funds will

be available to cover the cost of radiological decommissioning. NRC monitors the accumulation

of funds in the trust fund. Industry experience to date indicates that licensees have obtained

sufficient money to conduct decommissioning. Accordingly, no changes were made to this EIS

as a result of these comments.

Comment: Section 6.3 mentions 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? (SE-0045 36)

Response: Decommissioning has been completed at a small number of sites as a part of the

decommissioning process. Examples are the Fort St. Vrain Nuclear Generating Station and the

Shoreham Nuclear Plant. NRC requirements establish a framework to ensure that

decommissioning of all nuclear reactor facilities will be accomplished in a safe and timely matter

and that funding will be available for this purpose. Each licensee is required by the provisions

of 10 CFR 50.75 to establish a Decommissioning Trust Fund to assure that sufficient funds will

be available to cover the cost of radiological decommissioning. NRC monitors the accumulation
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of funds in the trust fund. Industry experience to date indicates that licensees have obtained

sufficient money to conduct decommissioning. Accordingly, no changes were made to this EIS

as a result of these comments.

3.14 Postulated Accidents

3.14.1 General Comments Based on Potential Accident Risks

Comment: Even a “minor” accidental discharge could have serious effects due to the densely

populated suburbs of Washington. (DT-0054 4)

Comment: I understand that the technology to extract electricity from nuclear energy has been

designed so that the risk of an accident is calculated to be very low. However, the results of

such an accident would be so devastating that to me it falls in the category of risks that are not

worth taking. (DW-0426 2)

Comment: A major nuclear accident could leave an area the size of Pennsylvania uninhabitable for decades. The area around the Chernobyl nuclear plant, site of a major accident in

1986, is still closed to public access and radiation levels are still high. (DW-MM4 12)

Comment: As a resident of Lancaster, PA, at the time of the near-meltdown of the Three Mile

Island Nuclear Plant in 1979, I am more than usually sensitive to hazards of nuclear power and

what can happen in a population when an accident occurs. Believe me, the risk far outweighs

the benefits. (DW-0877 2)

Comment: Three Mile Island, Chernobyl, there is always a lurking possibility that it could

happen again. Humans make errors and so do their machines, look at the disasters of our

space program. (DW-0822 2)

Comment: I do not want to take the off chance that we could have another Three Mile Island or

a Chernobyl with the killing of thousands of animals and people and contaminating the

landscape for thousands of years to come. (DW-0398 3)

Comment: I was in college at a Penn State branch campus of Mont Alto (50 miles from TMI)

I know how everyone reacted--scared. (DW-0931 2)

Comment: Please do not raise the risk of a Chernobyl event in Virginia. (DW-1091 2)

Comment: Should we not forget Three Mile Island, or worse, Chernobyl? (DW-802 5)
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Response: The comments concerning Three Mile Island and Chernobyl have been considered

in the body of severe accident analysis guidance. These comments are general in nature and

provide no new information relevant to the EIS. Accordingly, no changes were made to this EIS

as a result of these comments.

Comment: A common-language summary of section 5.10.2 is required. (SE-0045 33)

Comment: The section on emergencies [Section 5.10] and radiation impacts [Section 5.9] 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. ...Given that "radiation experts

conservatively assume that any amount or 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. (SE-0045 7)

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. (SE-0045 37)

Response: In the EIS, the staff has attempted to explain the evaluations of radiation impacts

and severe accidents in terms that can generally be understood. However, these are complex

subjects, which the staff understands are challenging for readers outside the industry. The staff

believes that preparing a true “plain language” version of these sections would invariably

introduce technical inaccuracy and related problems. Accordingly, no changes were made to

this EIS as a result of these comments.

Comment: We all benefit and take on some risk by living that close to a nuclear power plant. 

Adding third and fourth reactors does increase, and I realize the risk is low, the risk of

something catastrophic happening there. Any time you have four independent operating things,

your risk increases twofold versus two independent operating things. I realize that risk is

minuscule and that the issues that we've had worldwide have been slim to none. (ST-0001 5)

Response: The core damage frequencies and population dose risks estimated for the

postulated new reactors are small compared to the precision of the core damage frequencies

and population dose risks estimated for the existing reactors. Thus, although the risks increase,

the total risk of four units is not significantly greater than the risk associated with the current

units. To make this point more obvious, the core damage frequency and population dose risk

for the current reactors at the North Anna site has been added to Table 5-22.

Comment: Section 5.10 should include a worst case analysis for low-probability events. 

(SE-0045 32)
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Response: Section 5.10 of th EIS evaluates the impacts of events with an extremely low

probability of occurrence. The severe accidents evaluated in Section 5.10.2 include worst case

events. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Please clarify the statements in page 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? (SE-0045 30)

Response: ICRP Publication 60 (ICRP 1991) lists a normal probability coefficient for estimating

fatal cancers, nonfatal cancers, and hereditary effects from population radiation doses. This

coefficient is 730 occurrence per 10,000 person-Sv. This sentence has been deleted from the

text because it applies to background radiation.

3.14.2 Design-Basis Accident Calculation

Comment: Time-dependent X/Q values are not included in ER Section 2.7.2 and the DEIS

Table 5-14 values were not provided by Dominion. The ER accident analysis is based on a

single 50-percentile X/Q value for each location (EAB and LPZ). There is no time-dependency

associated with 50-percentile X/Q values. [page 5-70, lines 5-6, 11, Table 5-14]. (DW-0423 43)

Response: The first sentence in the comment is correct. The EIS has been revised to state

that only the 0 to 2 hr exclusion area boundary (EAB) and 0 to 8 hr low population zone (LPZ)

atmospheric dispersion factor (X/Q) values were provided by Dominion in ER Section 2.7.4 and

found to be acceptable by the NRC staff. The 8 to 24 hr, 1 to 4 day, and 4 to 30 day LPZ X/Q

values were derived by the NRC staff in its independent analysis of the meteorological data

provided by Dominion.

NRC guidance related to evaluation of design basis accidents indicates that the evaluation

should be based on the five time periods listed above (one for the EAB and four for the LPZ)

and that the X/Qs should be specific to each time period. Dominion did not follow that

guidance. Instead Dominion used the 0 to 8 hr X/Q values for all periods at the LPZ as a

conservative estimate; while this may be true, it could inappropriately establish a higher

bounding analysis outcome. Typical values should be used for NEPA purposes rather than

conservative values. Accordingly, the results of the staff’s X/Q analyses are presented in the

EIS and are used to calculate the doses for design basis accidents in Tables 5-15, 5-16, and

5-17. The EIS text was revised to clearly state that the design basis accident doses are based

on the results of the staff’s analysis.

Comment: It is not clear what is meant by “the scaling was performed on doses and not on the

source term.” If this implies that the activity releases in the ER are not scaled to 4386 MWt,

then that is not correct. [page 5-71, line 7]. (DW-0423 44)
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Response: The ER states “... the ABWR doses are scaled up from a power level of

4005 MW(t) (102 percent of 3926 MW(t), as specified in the design certification) to 4386 MW(t)

(102 percent of 4300 MW(t), the power proposed for a new ABWR unit at ESP site).” The

doses calculated for design certification were scaled up by the ratio of the power levels to derive

the doses presented in the ER rather than recalculating the source term for the higher power

level. The EIS was changed for clarification.

Comment: [H]as Dominion or the NRC contemplated accident scenarios and their potential

affect on a construction workforce that could be as large as 5000 people? (DW-0437 56)

Response: Neither Dominion nor the staff have evaluated the potential impacts of postulated

accidents at NAPS Units 1 and 2 on the construction workforce for new units at the site. 

However, prior to the start of construction, the emergency plan for NAPS Units 1 and 2 would

need to be updated to account for the presence of the construction workforce. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: The SDEIS table [Table 5-14] shows the results of NRC’s confirmatory calculations. 

Although it is not a quote from the ER, the exponent of the dose value is incorrect. The dose

should be 6.85 x 10-8 Sv. (SE-0050 20)

Response: The value in question has been corrected in Table 5-17 [corresponding to

Table 5-14 in the SDEIS] of this EIS.

Comment: This [set of PPE table numbers] is not a discrepancy with respect to Application

Rev 6 and associated RAI responses (as referenced in SDEIS) but the tables [Appendix I-8

Table I-2, line 10, source term atmospheric values] were revised in Rev 7. (SE-0050 23)

Response: This comment from Dominion references a change to be made to the PPE as a

result of a source term value revised in Revision 7 of its application. The new ER table

references have been added to Appendix I of this EIS.

3.14.3 Severe Accidents

Comment: When I read a summary of this [severe accidents], it said the risk is small, and I

said this is a pretty simplistic. This is kind of like a yellow code or an orange code or one of

these codes that we heard so much about last summer. It’s pretty simplistic. Where do they

come up with this? And then I read further, and it said, well, the risk is less than one year in a

million that there would be an accident in a reactor like this, and I said this doesn’t make

sense...if your data doesn’t make sense, look at your data again. If your analysis doesn’t fit with

reality, take another look. Look for obvious mistakes. Reexamine your assumptions. And the
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assessment that a severe accident is likely in less than one in a million years does need

reexamination. The biggest problem with probabilistic risk assessments is when you overlook

factors that, in fact, are real and don’t think are factors that prove to be important risks. 

(DT-0010 2)

Comment: [W]hat are the compounding effects on safety and the environment of the proximity

of other reactors? The description of the affected environment correctly emphasizes the

presence of NAPS Units 1 and 2 on the site (paragraph 2-1); however the possible interactions

between existing reactors with the proposed reactors do not appear to be addressed where they

would need to be, for example in Chapter 5.10.1, Design-Basis Accidents, in Chapter 5.10.2,

Severe Accidents; or Chapter 6, Fuel Cycle, Transportation and [De]Commissioning, especially

Section 6.1.1.6, Radioactive Wastes. What, for example, will be the effect of these additional

reactors on the safety of the two existing reactors? (DW-0685 2)

Comment: The assessment that a severe accident in the proposed reactors is likely in less

than one in a million years needs re-examination. It is widely recognized that the biggest

problem with probabilistic risk assessments is when you overlook factors that are real and don’t

think of factors that prove to be important risks...Any system of risk analysis that overlooks

human error is overlooking an important part of reality. Lack of attention to human error in the

consideration of nuclear reactors is a threat to our security and a danger to our well-being. 

(DW-0685 7)

Comment: [I]t seems that the methods used to determine the possibility of severe accidents

are simply not adequate to answer the most relevant questions, either in the short-term

operation of the proposed reactors, or especially in respect to the long-term management of

hazards created, either within the foreseeable future decades, or within the centuries and

millennia over which the waste must be secured. (DW-0685 10)

Comment: Much more than a missing pressure gauge and unexpected challenges in cooling

the reactor core, the major cause of all major nuclear accidents, the major, inescapable, clearly

identified cause, including Three Mile Island, Chernobyl, the reactors that have gone bad in

Japan is human error. Not only human error has been the cause, but overlooking human error

was identified as a persistent pattern by both the NRC and the nuclear industry in the forced

core meltdown analysis of Three Mile Island Reactor 2...I can’t find human error as a factor

specified in this probabilistic risk assessment. Why human error should be left out mystifies me. 

(DT-0010 3)

Response: The accident at Three Mile Island Unit 2 changed the character of NRC’s analysis

of severe accidents. Investigations of the accident and research following the accident have led

to the development of the detailed methods cited in this EIS and used to estimate core damage

frequencies and consider their uncertainties. Tables 5-18, 5-19, and 5-20 of this EIS provide

core damage frequencies rigorously estimated for the ABWR and AP1000 reactor designs as

part of the design certification process. Accident frequency estimation is described in Severe
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NUREG-1811, Volume II 3-256 December 2006

Accident Risks: An Assessment for Five U.S. Nuclear Power Plants, NUREG-1150, which was

published in 1991. Accident frequency estimation explicitly considers both pre-accident and

post-accident human errors. As a result of these comments, Section 5.10.2 of the EIS has been

clarified to indicate the source of the core damage frequencies in the tables and to state that

human error was one of the uncertainties that has been considered in estimating the

frequencies.

Comment: In regard to severe accidents, I want to call your attention to an apparent flaw in the

reasoning behind Table 5-20, Comparison of Environmental Risks from Severe Accidents....

Here, you are making predictions of the frequency of severe accidents likely in new reactors by

comparison to other reactors. The reactors you have selected to use for your comparison are

“current plants undergoing operating license renewal.” From the wording of this table and its

footnote B, the American reactor with the most severe accident, and therefore the reactor most

important to consider in this risk assessment, Three Mile Island Reactor # 2, has been excluded

from your analysis. I hope you have not actually made this mistake in your analysis, and that,

instead, you have simply mislabeled the table and mis-stated your criteria in footnote B. 

(DW-0685 8)

Response: Table 5-22 [formerly Table 5-20] does not predict accident frequencies; it

compares estimates of core damage frequencies made for the reactors considered at length in

the EIS with core damage frequencies that have been estimated for current generation reactors. 

Three Mile Island Unit 2 is not among the current generation reactors included in preparation of

Table 5-22 because it is no longer in operation. Nevertheless, the accident at Three Mile Island

Unit 2 has been factored into the core damage frequency estimates for all of the reactors. That

accident changed the character of NRC’s analysis of severe accidents. Investigations of the

accident and research following the accident have led to the development of the methods used

in estimating the core damage frequencies cited in this EIS. The comment does not provide

new information. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: I believe an application concerned specifically and exclusively with the site and its

relevance to future construction and operation permits cannot be accepted without thorough

consideration of possible interaction effects in case of accidents. (DW-0685 6)

Response: Existing requirements provide assurance that the probability of simultaneous

accidents at multiple units would be substantially less (e.g., more than an order of magnitude)

than the probability of accidents involving a single unit. For example, 10 CFR Part 50, “General

Design Criterion 5, Sharing of structures, systems, and components,” requires that structures,

systems, and components important to safety not be shared unless it can be shown that such

sharing will not significantly impair their ability to perform their safety functions, including, in the

event of an accident in one unit, an orderly shutdown and cooldown of the remaining units. 

Also, any application for design certification or for a COL under 10 CFR Part 52 must contain a

probabilistic risk assessment (PRA). 
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The consequences associated with an accident involving multiple units (e.g., a multiunit,

core-melt accident) could reasonably be expected to be only marginally greater than for a single

unit event. For example, given the same accident release characteristics for both units, the total

releases from two reactor cores (and associated accident consequences) would be, as a

first-order-of-magnitude approximation, about twice that for a single unit. The substantially

lower frequency of a multiple unit accident would more than offset the potentially greater

consequences of the multiple unit accident. Thus, the risk associated with multiple,

simultaneous accidents would be a negligible contributor to the overall risk from all units on the

site. Accordingly, the staff did not address multiunit simultaneous accidents as part of the ESP

review and no changes were made to this EIS as a result of this comment.

Comment: Page 5-2 line 35 mentions that air quality impacts of “routine” releases would be

limited. The document does not include a good analysis of the “non-routine” releases. It would

be helpful to understand the potential magnitude of these releases even if they have a low

probability of occurrence. (DW-0438 124)

Response: The releases discussed under air quality are the non-radiological releases from

generators and boilers. The staff has not considered “non-routine” release from these sources. 

The staff considers “routine” radiological releases in Section 5.9 and “non-routine,” low

probability radiological releases in Section 5.10 of the EIS. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: [N]o assessment of worst case releases is included. (DW-0438 32)

Comment: Section 4.9.4 gives a mean forecast. What about potential upset conditions? 

Shouldn’t a worst case analysis be included for low-probability events? (DW-0438 117)

Comment: Sections 5.9 and 5.10 do not provide sufficient analysis on the impact of upset

conditions. Even though these are low probability occurrences the impacts would be large. 

(DW-0438 160)

Response: The “worst case” analysis concept in NEPA analyses was eliminated by the

President’s Council on Environmental Quality (CEQ) in 1986 (see 51 FR 15618). Federal

agencies governed by CEQ regulations (the NRC is not one of those agencies) are still

expected to evaluate the reasonably foreseeable significant adverse impacts of an action. The

“rule of reason” was to ensure that “... common sense and reason are not lost in the rubric of

regulation.” The legal bases for the CEQ’s determination to eliminate “worst case” analyses

included cases involving the NRC’s predecessor; i.e., the Atomic Energy Commission. 

Therefore, NRC’s environmental review practices include an analysis of reasonably foreseeable

significant adverse impacts. Section 5.9 of the EIS deals with environmental impacts of normal

operations. Section 5.10 of the EIS deals with postulated accidents. The accidents considered

cover design basis accidents that range from relatively high probability of occurrence with
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NUREG-1811, Volume II 3-258 December 2006

relatively low consequences to severe accidents of relatively low probability of occurrence with

high consequences. The environmental impacts of severe accidents are also considered. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Sections 5.5.3.4 and 5.5.3.5 should assess the impact on recreation and local

housing if there is a nuclear accident at the facility. (DW-0438 156)

Response: Sections 5.5.3.4 and 5.5.3.5 of the EIS discuss the impacts of normal plant

operation on recreation and housing, respectively. The impacts of postulated accidents are

discussed in Section 5.10. Impacts discussed in that section are generally related to health

effects, i.e., doses, to compare with site safety criteria found in 10 CFR 50.34(a)(1) and

NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear

Power Plants. NRC regulations and the defense-in-depth philosophy behind the regulations are

intended to ensure that engineered safety features are adequate to minimize the offsite

consequences of design basis accidents. Accordingly, no changes were made to this EIS as a

result of this comment.

Comment: “The probability of a severe accident without the loss of containment” mentioned on

page 5-74 line 22 is just slightly less than the probability of winning the Lotto South jackpot. 

(DW-0438 163)

Response: The comment does not provide any information relevant to the EIS and was not

evaluated further. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Additional reactors can only worsen this problem [lake levels], increasing the

chance of an accident at the plant. (DW-0614 5)

Response: Lake level as a site safety or as an operational issue is fundamentally different than

its consideration as an environmental issue. The addition of reactors is likely to increase the

frequency and duration of periods of low water. However, the lake level in Lake Anna does not

affect the water supply needed to shut down the reactors nor to cool the reactors while they are

shut down; consequently, it is not relevant to the accident analyses. Accordingly, no changes

were made to this EIS 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. (SE-0045 34)

Response: The staff determined that the impacts of severe accidents are SMALL. However,

because a specific design has not yet been selected, it is not yet possible to determine whether

there are any cost-beneficial alternatives to mitigate severe accidents. (Even with SMALL

impacts, it is sometimes possible to find cost-beneficial changes to further reduce the impacts.) 
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Therefore, if an applicant for a construction permit or combined license references this ESP, it

would have to evaluate severe accident mitigation alternatives, and the staff would have to

review the issue and resolve it. Accordingly, no changes were made to this EIS as a result of

this comment.

Comment: If the cooling water supply for the nuclear reactors is depleted by draining Lake

Anna, then hopefully another TMI [Three Mile Island] event could not occur at North Anna where

the reactor continued to heat the reactor coolant. ...Although the NRC issued two new

regulations as a result of TMI, neither regulation appeared to take into account the lack of water

from the primary cooling source with a small watershed providing the cooling waters for the lake

that was estimated to take 2 to 3 years to fill. ...It is essential that both the NRC and VDEQ

consider the above scenario prior to approving an Early Site Permit or a Federal Consistency

Certification for a 3rd nuclear reactor that would depend on any additional water from Lake

Anna. (SE-0033 3)

Comment: What happens if everything, everything, everything doesn't work the way it is

supposed to and those towers can't be cooled the way it seems very important to everybody

that they be cooled? (ST-0006 1)

Response: Dominion has proposed using Lake Anna as the source of normal cooling water for

proposed Unit 3. Unit 4 would use a system of dry cooling towers. However, neither of the

proposed units relies on these normal cooling systems in the event of an accident. If the normal

systems were available, they would be used. But if they were not available, an emergency

cooling system would cool the plant down. The source of cooling water for the emergency

system is called the ultimate heat sink (UHS) and is discussed in Section 3.2.2 of this EIS. 

Accordingly, no changes were made to this EIS as a result of these comments.

3.15 Mitigation Measures and Controls

Comment: Please define the term “best management practices,” which occurs throughout the

draft EIS. (DW-0437 70)

Response: A Best Management Practice (BMP) is one or more recommended site

management, maintenance, or monitoring activities usually based on an approach that has

been shown to work effectively for the purpose intended. The EPA uses BMPs to specify

standards of practice where regulations may not be sufficiently descriptive and states that a

BMP should be as inexpensive as possible and the equipment or technology should be readily

available. Two EPA websites providing further information are

http://www.epa.gov/region02/waste/leadshot/ and

http://www.epa.gov/region02/waste/leadshot/brochure.pdf. A definition of BMPs was added as

a footnote in Section 4.3.1 of the EIS.
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Comment: The mitigation measures mentioned on page 4-37 line 35 [regarding minimization of

fugitive dust and odors from paving disturbed areas, water suppression, and reduced material

handling] should be stipulated to by the applicant. “Developing a plan” at a later stage as

mentioned in Section 4.10 is not adequate. (DW-0438 113)

Comment: The mitigation measures listed on page 5-84 should be stipulated to. 

(DW-0438 164)

Comment: The measures outlined in Section 4.10 are a good start but additional detail is

required now to understand the likely site impacts. (DW-0438 118)

Response: A COL applicant would be required to meet VDEQ regulations for minimizing

fugitive dust and odors, and the staff assumed such compliance (see Section 4.10). In its

comments on the Draft EIS, VDEQ staff stated the following requirements with respect to

Virginia (comment DW-0439 5): 

During construction, the applicant shall keep fugitive dust 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. In addition, burning of construction or demolition material must meet

requirements of regulations for open burning (VAC 5-40-5600 et seq.), and the applicant

must determine if a permit for open burning is required by Louisa County (comment

DW-0439 6).

Appendix J was added to the final EIS and includes commitments, assumptions, and proposed

license conditions.

Comment: DEQ encourages NRC and the applicant to implement pollution prevention

principles in all construction activities. This includes reducing wastes at the source, re-using

materials, and recycling waste materials. Generation of hazardous waste should be minimized,

and hazardous waste should be handled appropriately in keeping with the [federal and state

rules; Resource Conservation and Recovery Act and Virginia Waste Management Act]. 

(DW-0439 26) (SW-0017 64)

Comment: 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. We have several pollution prevention recommendations that may be helpful in

constructing or operating this project if it goes forward: 1) Consider development of an

Environmental Management System (EMS). An effective EMS will ensure that the proposed

facility is committed to minimizing its environmental impacts, setting environmental goals, and
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achieving improvements in its environmental performance. DEQ offers EMS development

assistance and recognizes facilities with effective Environmental Management Systems through

its Virginia Environmental Excellence Program. (DW-0439 50) (SW-0017 65)

Comment: 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. (DW-0439 52)

Comment: Consider contractors’ commitments 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. (DW-0439 53)

Comment: Choose sustainable materials and practices for infrastructure and building

construction and design. These could include asphalt and concrete containing recycled

materials, and integrated pest management in landscaping, among other things. (DW-0439 54)

Comment: Integrate pollution prevention techniques into facility maintenance and operation, to

include the following: inventory control (record-keeping and centralized storage for hazardous

materials), product substitution (use of non-toxic 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 preventive maintenance. 

(DW-0439 55)

Comment: During construction (and pre-construction activities, and site redress

implementation if that is the case), 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: 1) Use, where

possible, of water or chemicals for dust control; 2) Installation and use of hoods, fans, and fabric

filters to enclose and vent the handling of dusty materials; 3) Covering of open equipment for

conveying materials; and 4) Prompt removal of spilled or tracked dirt or other materials from

paved streets and removal of dried sediments resulting from soil erosion. (DW-0439 5)

(SW-0017 67)

Comment: In addition, if project activities include the burning of construction or demolition

material or land-clearing debris, this activity must meet the requirements of the Regulations for

open burning (9 VAC 5-40-5600 et seq.), and it may require a permit. ... The Regulations

provide for, but do not require, the local adoption of a model ordinance concerning open

burning. The applicant should contact appropriate local officials to determine what local

requirements, if any, apply to open burning. [Example model ordinance provisions are

provided.] (DW-0439 6) (SW-0017 68)

Comment: If the activities to be pursued under the Early Site Permit involve one or more of

those listed here, the applicant must apply to DEQ for a permit. Except in compliance with a
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VWP permit, no person shall dredge, fill, or discharge any pollutant into, or adjacent to surface

waters, or otherwise alter the physical, chemical, or biological properties of surface waters,

excavate in wetlands, or ... conduct the following activities in a wetland: 1. New activities to

cause draining that significantly alters or degrades existing wetland acreage or functions;

2. Filling or dumping; 3. Permanent flooding or impounding; or 4. New activities that cause

significant alteration or degradation of existing wetland acreage or functions. ...It should be

noted that certain water withdrawals are exempt from permitting (see the State Water Control

Law, Virginia Code section 62.1-44:15.5.G). The proposed Unit 3 does not appear to qualify for

this exemption, according to DEQ's Division of Water Resources (Hassell/Ellis/Irons, 9/8/06). 

(DW-0439 8) (SW-0017 42)

Comment: Erosion and Sediment Control; Stormwater Management. (a) Erosion and

Sediment Control Plans. If any activities pursuant to the Early Site Permit will disturb

10,000 square feet or more, the property owner is responsible for submitting a site-specific

Erosion and Sediment Control Plan to the affected County for review and approval pursuant

to the local Erosion and Sediment Control ordinance, according to the Department of

Conservation and Recreation. All regulated land disturbing activities associated with the

project, including on- or off-site access roads, staging areas, or spoil or borrow areas, must

be covered by an approved Plan. The Plan, in turn, must be prepared and implemented in

accordance with the Virginia Erosion and Sediment Control Law (Virginia Code

section 10.1-563), the Virginia Erosion and Sediment Control Regulations (see 4 VAC 50-30-30,

4 VAC 50-30-100), and the Virginia Erosion and Sediment Control Handbook, which aids the

project proponent in meeting the legal and regulatory requirements. ... (b) Stormwater

Management Plans. Depending on local requirements, a separate Stormwater Management

Plan may also be required for land-disturbing activities. Stormwater Management Plans must be

prepared and implemented in accordance with the Virginia Stormwater Management Law

(Virginia Code Section 10.1-603.3) and the Virginia Stormwater Management Regulations

(4 VAC 3-20-90 through 3-20-141). General information on recent changes to stormwater

management requirements is available at the Department of Conservation and Recreation’s

web site. (DW-0439 27)

Comment: In response to the discussions of terrestrial impacts (SDEIS, page 4-8, section

4.4.1) and unavoidable adverse impacts (SDEIS, page 10-4, section 10.1), DGIF recommends

avoiding and minimizing adverse impact upon wetlands and streams to the maximum extent

possible. Particulars [related to] i. Compensation for unavoidable wetland and stream impacts. 

ii. Stream enhancement or preservation-only mitigation. iii. Conduct of in-stream activities [are

offered in the VDEQ SDEIS comment letter.] (SW-0017 58)

Comment: To minimize adverse effects to the aquatic ecosystem, DCR recommends that the

applicant implement an erosion and sediment control plan in areas excavated along the creek. 

DCR also recommends that the applicant protect emergent vegetation adjacent to the creek. 

(SW-0017 72)
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Response: The pollution prevention and other mitigation recommendations above were

provided as guidance by VDEQ to Dominion for prospective construction and operation of

additional units at NAPS. The staff agrees with many of the recommendations. Dominion

summarizes the measures and controls it would take to limit adverse impacts during

construction of a new nuclear power plant in Section 4.6 and Table 4.6-1 of its ESP application

and during operation in Section 5.10 and Table 5.10-1 of its application. The staff assumes that

Dominion would comply with all applicable regulatory requirements (see Section 4.10). 

Appendix J includes commitments made by Dominion that the staff relied upon during the

preparation of the EIS. Accordingly, other than the addition of Appendix J, no changes were

made to this EIS as a result of these comments.

Comment: [T]he mitigations listed in Section 10 are insufficient. Items such as “consider”

plume abatement measures are just one example. Plume abatement should be implemented. 

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. (SE-0045 44)

Response: Dominion summarizes the measures and controls it would take to limit adverse

impacts during construction of a new nuclear power plant in Section 4.6 and Table 4.6-1 of its

ESP application and during operation in Section 5.10 and Table 5.10-1 of its application. The

staff assumes that Dominion would comply with all applicable regulatory requirements (see

Section 4.10). Appendix J includes commitments made by Dominion that the staff relied upon

during the preparation of the EIS. Accordingly, no changes were made to this EIS as a result of

this comment.

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. 

(SE-0045 45)

Response: The minute, localized climatic changes related to the operation of the Unit 3 cooling

towers would be undetectable, and mitigation is not warranted. Accordingly, no changes were

made to this EIS as a result of this comment.

Comment: Impacts upon [herring, shad, and smallmouth bass] fisheries and other aquatic

resources can be minimized by use of the dry tower to reduce consumptive water losses. 

Accordingly, DGIF recommends that the Maximum Water Conservation (MWC) mode be

implemented in keeping with the following rules.

• In March and April, the MWC mode should be implemented when flows are less than

225 cfs. Flows are in the lower quartile, and water conservation savings can result in

significant habitat savings and return flows to near existing conditions. These flows are
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particularly important for herring, shad, migratory striped bass, and resident sucker and

minnow spawning.

• In May, the MWC mode should be implemented when flows are less than 175 cfs. These

flows are important for smallmouth bass nesting. The addition of Unit 3 would reduce flows

by 30% from pre-Lake conditions.

• In June, the MWC mode should be implemented when flows are less than 120 cfs. This

value is close to the average value and will enhance smallmouth bass spawning success,

and subsequent catch for anglers. 

From July through October, the MWC mode should be implemented when flows are less than

90 cfs. High flows are important for the habitat requirements of resident fish species that do

best in wet years. Without water conservation in wet years, those optimal habitat conditions

cannot be achieved. Wet years are also important for producing strong year classes of

American shad in the Pamunkey River. (SW-0017 47)

Response: This guidance by VDGIF for cooling system operation is acknowledged. Should

the ESP and a COL be granted, the applicant will want to take this information into

consideration in developing its cooling strategy. Accordingly, no changes were made to this EIS

as a result of this comment.

3.16 Cumulative Impacts

Comment: [W]hat are the compounding effects on safety and the environment of the proximity

of other reactors? The description of the affected environment correctly emphasizes the

presence of NAPS Units 1 and 2 on the site (paragraph 2-1); however the possible interactions

between existing reactors with the proposed reactors do not appear to be addressed where they

would need to be, for example ...Chapter 6, Fuel Cycle, Transportation and [De]Commissioning,

especially Section 6.1.1.6, Radioactive Wastes. (DW-0685 2b)

Comment: Neglecting to address the potential interaction-effects [including safety from the

proximity of other reactors] at this site in this Environmental Impact Statement raises the

question of what has really been accomplished in this 724-page draft report, which could not

have awaited a more complete proposal to be considered. (DW-0685 5)

Response: Cumulative impacts are discussed in Chapter 7 of this EIS. The potential

interaction effects of new units at the North Anna ESP site with the existing NAPS Units 1 and 2

is a site safety interface issue that would be considered in the design of the reactors to ensure

that an accident at one of the existing units would not adversely impact the operation of the new

units. However, the likelihood of severe accidents at an existing unit or at any new unit are

small. The likelihood of simultaneous severe accidents at more than one unit is extremely

unlikely and does not warrant environmental evaluation. The Commission expects that the risk

associated with severe accidents for new reactor designs would be small compared to the risk
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associated with current reactor designs. For the purposes of comparison, from Table 5-22, the

core damage frequency (CDF) for NAPS Units 1 and 2 is calculated to be 3.5 x 10-5 yr-1 and for

a surrogate ESBWR at NAPS is calculated to be 2.9 x 10-8 yr-1. The corresponding population

dose risk is calculated to be 2.5 x 10-1 person-Sv R(reactor) year-1 for NAPS Units 1 and 2 and

3.3 x 10-5 person-Sv R yr-1 for each additional surrogate ESBWR. Because the 1 and 2 reactors

would not be interconnected with any new units, addition of two units would not change the risk

profile by even one percent. Consequently, the staff expects that the potential consequences of

a postulated accident at any new unit is bounded by that from any existing unit. Therefore,

adding the risk from two new units to the risks from the existing units would result in a total risk

for the site that is only slightly more than the risk for the current units. The impact of an

accident at potential new units is bounded by the impact of a potential accident at the existing

units. Section 7.9 was added to address cumulative impacts of the fuel cycle, transportation,

and decommissioning.

Comment: Dominion provided DEQ’s Division of Water Resources (DWR) with the output of a

simulation model with which Division staff is able to make some comparisons of true pre- and

post-project conditions. Prior to the lake, the North Anna River at the dam site had an average

flow of about 286 cubic feet per second (cfs). This is based on the flow records from 1929 to

1971 at the Doswell gauge, proportionately reduced to reflect the smaller drainage area at the

dam. According to the NRC water budget analysis, the two existing units account for 50 cfs in

evaporation and the third unit would account for 26 cfs in evaporation. The cumulative impact

on the average flow of just the power plants (not including lake evaporation) is therefore

estimated to be 76 cfs or 26% of the historic average flow. Such a large loss of the normal flow

to consumptive uses is unprecedented in Virginia and other mid-Atlantic states. The U.S.

Geological Survey (USGS) estimates that the average percentage of surface water lost to

consumptive use in the mid-Atlantic states is 1.6% of average flow. (USGS, 1984, National

Water Summary). (DW-0439 15) (SW-0017 22)

Comment: The Department of Game and Inland Fisheries and DEQ’s Division of Water

Resources requested the applicant to perform an Index of Hydrologic Alteration (IHA) analysis

of pre- and post-project flows below the dam (see Draft EIS, page F-122 through F-125 and the

tables on pages F-126 through F-133). The two state agencies had pre-dam conditions in mind

when they addressed “pre-project” conditions in their earlier discussions with the applicant. 

However, the tables on pages F-126 through F-133 do not evaluate conditions and therefore

cannot be considered complete. Table 1 ([Draft EIS] pages F-126 and F-127) demonstrates

significant shifts in frequency of lower flows and needs to be expanded to address conditions

prior to the creation of the lake. The Division of Water Resources and the Department of Game

and Inland Fisheries clarify that by “pre-project,” it meant no dam and no reactors; by “postproject,” it meant the lake and three once through cooling units. This Indicators study was

requested in order to assess the cumulative impact of the existing and proposed project

activities on the North Anna River. (DW-0439 13) (SW-0017 20)
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Comment: [As stated in the letter by the Department of Water Resources,] the “pre-project”

conditions should be based on the condition of the area before the lake and dam were

constructed in the 1970s. Table 1 in Appendix F ([Draft EIS] pages F-126 and F-127) is one

example of this; it demonstrates significant shifts in frequency of lower flows and needs to be

expanded to address conditions prior to creation of the lake. (DW-0439 32) (SW-0017 33)

Comment: A cumulative analysis of impacts of the project does not start, in our judgment, with

the existing lake conditions (i.e., the lake and two reactors) and then add, incrementally, the

effects of operation of the proposed third reactor (so that the “post-project” condition is the lake

and three reactors). However, the Nuclear Regulatory Commission has accepted this

approach, which means that a finding of no more than “moderate” impacts of the third unit (page

5-10, Section 5.3.2, lines 7-13) is not surprising even if cumulative impacts have not been

analyzed. (DW-0439 14) (SW-0017 21)

Comment: The NRC analysis is implicitly predicated on the assumption that the current

environmental impacts of Units 1 and 2 are themselves an acceptable environmental baseline,

when such operations have already resulted in excessive temperatures in the main body of

Lake Anna (i.e. well outside of the cooling lagoons), and produced many days of reduced flows

into the lower reaches of the North Anna River. A more credible baseline for analysis, and for

estimating cumulative environmental impacts, would be the temperatures, flows and fauna in

the North Anna river system before the river was impounded to form Lake Anna. (SE-0040 11)

Comment: (related to Draft 439-13/14 p. 10) The cumulative impact analysis should start

before the existing two reactors were put into operation and the impacts analyzed with the

sequential addition of Units 1 and 2 followed by the addition of Unit 3. (SW-0017 12)

Comment: We have two existing units. ...Has the evaporation rate of warmer water, because

we have higher temperatures in the summers, been studied? Have downstream flows been

evaluated? Has the effect of decreased downstream flows, higher evaporation rates, previous

to constructing or even thinking of constructing a third unit been evaluated in the course of the

last few years? What's this doing to our flora, our fauna in the downstream of the York River

water shed, which impacts our bay? (ST-0002 7)

Response: The NRC staff, in the EIS, evaluated the incremental impact on the environment of

the proposed action when added to other past, present, and reasonably forseeable future

actions. This evaluation conforms to the CEQ guidance set forth in a “Memorandum to Heads

of Federal Agencies” dated June 24, 2005. The CEQ guidance states, in part:

The environmental analysis required by NEPA is forward-looking, in that it focuses on

the potential impacts of the proposed action that an agency is considering. Thus, review

of past actions is required to the extent that this review informs agency decisionmaking

regarding the proposed action... Based on scoping, agencies have discretion to

determine whether, and to what extent, information about the specific nature, design or
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 December 2006 3-267 NUREG-1811, Volume II

present effects of a past action is useful for the agency’s analysis of the effects of a

proposal for agency action and its reasonable alternatives.

Agencies are not required to list or analyze the effects of individual past actions unless

such information is necessary to describe the cumulative effect of all past actions

combined. Agencies retain substantial discretion as to the extent of such inquiry and the

appropriate level of explanation. (Citation omitted.) Generally, agencies can conduct an

adequate cumulative effects analysis by focusing on the current aggregate effects of

past action without delving into the historical details of individual past actions.

As described below, the NRC staff evaluation is consistent with the CEQ guidance.

An evaluation of the cumulative effects of building and operating two new units at the North

Anna ESP site on the area’s resources, in general, and the North Anna River, in particular, by

its nature, begins with the existence of Lake Anna and existing NAPS Units 1 and 2. Adding the

incremental effects of construction and operation of the new units to the effects of Lake Anna

and the currently existing NAPS Units 1 and 2 results in a description of the cumulative impacts

on the area’s resources and the river. In particular, the aggregate effects of the construction

and operation of the dam on the North Anna River are reflected in the differences between

current conditions and pre-dam conditions, the most important of which were:

& Lake Anna did not exist

& Flow rates in the North Anna River varied greatly by season

& Aquatic life in the North Anna River was severely impacted by pollution from Contrary

Creek

The existing flow rates and thermal conditions described in the EIS include the impacts of not

just the existing NAPS Units 1 and 2, but all past and present effects on the North Anna River,

including the effects of the dam. Therefore, there is no reason for the NRC staff to delve into

the historical details pertaining to installation of the dam.

Nonetheless, as a result of the comments, the staff explored whether using pre-dam condition

as the starting point for cumulative impacts analyses was reasonable. The creation of Lake

Anna, however, has altered the environment such that an analysis of impacts starting with predam conditions would be meaningless in the decision-making process. Specifically, neither the

granting of the requested action before the NRC nor its denial would result in restoration of the

North Anna river to pre-dam conditions. Further, the dam would not be removed and Lake Anna

would not be destroyed even if the existing units were decommissioned (assuming no new units

are built). In short, the dam has utility independent of the existing units and any ESP that might

be granted. Accordingly, the NRC staff concludes that the pre-dam condition is not an

appropriate starting point for the analysis. Notwithstanding the above, in response to these and

other comments, the NRC staff has changed the Final EIS Section 7.3 to more clearly describe
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NUREG-1811, Volume II 3-268 December 2006

the cumulative impacts on the area’s resources, including the North Anna River, resulting from

construction and operation of new units at the North Anna ESP site.

Comment: Although Section 5.4.2.3 concludes that entrainment impacts would be SMALL, the

cumulative effects of impingement, entrainment, radiation, and other aquatic hazards should be

assessed and described (Section 5.4.2.7). (DW-0438 147)

Response: The NRC staff considered the potential cumulative effects of entrainment,

impingement, and other operational effects. For the purposes of this analysis, past actions

were those related to fish at the time of the baseline case; i.e., current conditions. Future

actions are considered to be those that are reasonably foreseeable through the end of

decommissioning the proposed Unit 3. Therefore, the analysis considers potential impacts

through a complete operating term, including a license term, any renewal operating license

term(s), and the allowable time for the plant owner to complete decommissioning. The

geographical area over which past, present, and future actions could contribute to cumulative

impacts is Lake Anna and the river downstream of the dam. The proportions of the Lake Anna

aquatic organism populations that may be impinged, entrained, or otherwise impacted during

operation of the existing two units using once-through cooling systems, one proposed unit using

a closed-cycle, combination wet and dry cooling system, and one proposed unit using a dry

cooling system is not expected to result in any change in the balance of animal and plant

species. The cumulative impacts from power plant operations to Lake Anna would be SMALL. 

Based on this comment, the description in the EIS was expanded.

Comment: Cumulative impacts of the current and future units on downstream hydrology and

biology need to be quantitatively evaluated before any determination can be made that effects

of the proposed addition of reactors to the site are “small” (page 5-10, Section 5.3.2, line 9). 

Two options exist to reduce the significant impacts on downstream resources, according to the

Department of Game and Inland Fisheries [DGIF]: 1) Change the trigger level of elevation

(248 ft) to some lower elevation that has a recurrence interval of once every 8.7 years, or

2) Have Unit 3 operate under dry cooling conditions, as is proposed for Unit 4. (DW-0439 12)

Comment: (related to Draft 439-12 p. 13 and #11 on p. 8) Cumulative impacts of the current

and future units on downstream hydrology and biology need to be quantitatively evaluated

before any determination can be made that effects of the proposed addition of reactors to the

site are "small." ...Three options exist to reduce the significant impacts on downstream

resources, according to the Department of Game and Inland Fisheries:

& Change the trigger level of elevation (248 feet) to some lower elevation that has a

recurrence interval of once every 8.7 years;

& Increase storage by raising the lake level seasonally; or

& Have Unit 3 operate under dry cooling conditions, as is proposed for Unit 4. (SW-0017 11)
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Response: The NRC staff agrees that lowering the trigger level would reduce the frequency

and duration of low flows downstream of the dam. The reservoir could be operated to maintain

normal flow conditions downstream. However, such changes in reservoir operating policy

would result in more frequent and deeper drawdowns in the lake, and the VDEQ Lake Anna

Level Contingency Plan would need to be revised for operating the dam in this manner. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Even though the proposed water withdrawal has decreased with the new cooling

methods, yet the withdrawals remain significant with this small watershed. At a minimum NRC

and VDEQ must provide an analysis of the cumulative impact taking into consideration worstcase scenario that includes the 2001-2002 drought. (SE-0022 10)

Response: The staff’s analysis of the impacts related to water resources considered a range of

conditions including the 2001 - 2002 drought. The staff used the period from June 2000 through

April 2003 as the critical period in its analysis as discussed in Section 5.3 and Appendix K of

this EIS. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The introduction to Cumulative Impact section states on Page 7-1 line 22 that “if a

resource is regionally declining or imperiled, even a SMALL individual impact could be important

it if (sic) contributes to or accelerates the overall resource decline.” This situation certainly

applies to regional transportation and roads, yet this is ignored in the DEIS. (DW-0438 169)

Response: Transportation impacts by their very nature are cumulative. Among the issues of

concern is whether the addition of construction workforce traffic would significantly degrade

traffic conditions or air quality. The NRC staff estimated that most of the construction workforce

would come from workers living in the region within 50 miles of the site. Therefore, the regional

workforce is already contributing to traffic congestion. Two additional factors add context to the

impact analysis. First, it is highly unlikely that all of the workers would use the same commuting

routes, and second, the workers would be distributed among two or three shifts. Thus, any

impact would be distributed both spatially and temporally. Additional mitigative measures are

discussed in the EIS and Dominion’s ER. A discussion of transportation issues has been added

to Chapter 7.

The Virginia Transportation 2025 (VTRANS 2025) report describing the plans of the Virginia

Department of Transportation was released after the transportation sections of the Draft EIS

were written. The EIS has been updated to reflect the construction plans of the Virginia

Department of Transportation.
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3.17 Alternatives

3.17.1 No-Action Alternative

Comment: In Table 10-3 the impacts listed for the No-Action Alternative should be “NONE” not

“SMALL.” (DW-0438 173)

Response: NRC has established a standard of significance for impacts using Council on

Environmental Quality (CEQ) guidance (40 CFR 1508.27). Impacts that range from none to

small are categorized as being of SMALL significance in accordance with the significance

categorization scheme used in 10 CFR Part 51, (see, for example, 10 CFR Part 51, Subpart A,

Appendix B). The staff does not use an impact level of “NONE.” Accordingly, no changes were

made to this EIS as a result of this comment.

Comment: It is clear in the DEIS that the no-action option was not seriously considered. The

document basically summarizes it this way: There is no real environmental impact to an early

site permit because an early site permit doesn’t allow for the building of a nuclear reactor,

therefore, a no action option is equally harmful to choosing a site. If this indeed is true, that an

ESP doesn’t allow for any environmental damage, why did you have one completed and waste

taxpayer money and paper to prepare such a document. Either an ESP has an environmental

impact or it doesn’t. If it does, then you must more seriously consider the no action alternative. 

(DW-0630 6)

Response: While issuing an ESP has no significant environmental effects (or no significant

environmental effects that could not be redressed), the Commission, in 10 CFR 52.17 and

10 CFR 52.18, directed that an ESP ER and ESP EIS, respectively, focus on the environmental

effects of construction and operation of a reactor or reactors that have characteristics that fall

within the postulated site parameters. Following this process allows for early resolution of

environmental impacts and timely resolution of any significant issues that may arise. The

disclosure of the environmental impacts is required for the NRC to fulfill its NEPA

responsibilities. As discussed in Section 8.1 of the EIS, there are no environmental impacts

associated with the No-Action alternative (i.e., not issuing the ESP). Therefore, in accordance

with the staff’s definition of impact levels, the impacts of the no-action alternative are SMALL for

all impact areas. However, as discussed in the EIS, the no-action alternative also does not

allow any of the benefits of the ESP, the underlying purpose for the action, to be realized. 

Section 8.1 was modified for clarification. The No-Action alternative to construction and

operation of a new or multiple new units would be evaluated in the EIS prepared in connection

with a COL or CP/OL application.

Comment: No where that I can find in this huge document does it explore the environmental

impact of NOT building new nuclear capacity. The need for future energy supplies, by even the

most conservative estimates does not show that we will need less energy in the future. Since
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the alternative, viable forms of base-load energy generation are far more detrimental to the

environment, failing to build new nuclear generation would have serious negative environmental

consequences. Therefore, the environmental impacts of failing to build a non-carbon emitting

energy source should be considered as part of the Final EIS. (DW-0820 2)

Response: The need for power and alternative energy sources that may be considered to

meet the demand would be considered at some time in the licensing process if an applicant

seeks to construct and operate a new nuclear power plant. The NRC regulations under

10 CFR 52.18 specify that the EIS prepared for an ESP need not include an assessment of the

benefits, including the need for power, of the proposed action and the Commission has

determined that alternative energy sources could be deferred to the time of the COL application

[www.nrc.gov/reactors/new-licensing/esp/generic-esp-issues.html]. The benefits assessment of

constructing and operating one or more nuclear units would be evaluated in the EIS prepared in

connection with an application for a COL or a CP.

3.17.2 System Design Alternatives

Comment: [A]mong 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. (SE-0045 39)

Comment: The list of alternatives did not include life extension of the existing two plants,

retirement of those plants, detailed analysis of the use dry coolers on Unit #3, or the retrofit of a

cooling tower on Units #1 and 2. (SE-0049 4)

Response: Retrofitting the existing units to dry cooling is beyond the scope of this review and

is not considered. This EIS did not consider life extension for the existing plants or retirement of

those plants. Evaluation of the existing plants was conducted during the license renewal

process of their operating licenses. Units 1 and 2 are licensed to operate through 2038 and

2040, respectively, so license renewal (extension) does not represent an additional option to

meet power demands in the near term. Retiring the operating units was also evaluated in the

license renewal process, but would exacerbate the need for power in the region and is not a

viable option. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Shouldn’t Chapter 8 include an assessment of a zero discharge option as is used in

many other power plants? (SE-0045 16)

Response: No. The NRC evaluated the impacts to radiological discharges using PPE values

to perform an alternative site review. The NRC staff has proposed a permit condition in the
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NUREG-1811, Volume II 3-272 December 2006

Safety Evaluation Report that would require an applicant referencing an ESP design to equip

any new unit’s radwaste systems with features to preclude any and all accidental releases of

radionuclides into any potential liquid pathway (NRC 2006b). Accordingly, no changes were

made to this EIS as a result of this comment.

3.17.3 Alternative Sites

3.17.3.1 General Alternative Sites Comments

Comment: [In] general, it would be helpful to provide all data for the North Anna and

alternative sites in common tables so that the public can see the basis information the staff is

using to reach its conclusions. (DW-0399 9)

Response: Tables with the data for all four sites are provided in Chapter 9 summarizing the

impact levels. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The lack of significant variance among the alternatives in Table 9-1 make the

impact analysis process and quantification scale suspect. (DW-0438 172)

Comment: One of the sites has fewer impacts than the site at North Anna and yet the DEIS

recommends that the ESP be granted to Dominion. I fail to understand how this could be the

case. If the point of the EIS is to determine if North Anna is the least damaging place to allow

for an ESP, why would you recommend approval when there is an alternative site that would

have fewer deleterious effects. (DW-0630 7)

Comment: The NRC’s Site Comparison Methodology is Flawed and Obscures Important

Environmental Advantages of Alternative Sites. We are far from persuaded by the NRC staff

determination that another site is not “obviously superior” on environmental grounds to the

North Anna site...Since the NRC staff employs inherently fuzzy qualitative – “SMALL,”

“MODERATE,” and “LARGE” – rather than quantitative criteria to compare environmental

impacts at the alternative sites, this allows important differences between sites to be obscured

by choosing “MODERATE” to describe harmful impacts at the Proposed Site that are actually

environmentally significant, while “offsetting deficiencies” at alternative sites. (SE-0040 14)

Response: The NRC’s guidance on site selection (NUREG-1555; NRC 2000) is intended to

result in the selection of strong candidate sites for potential nuclear power plants. Dominion

states in its ER that it followed this guidance in its site selection process in which it identified

North Anna as its preferred site and Surry, Portsmouth, and Savannah River as its alternative

sites. As described at pages 8-1 and 9-1 of the EIS, the NRC uses a two-part examination to

determine whether any alternative ESP site is obviously superior to the proposed site. The

NRC defines an environmentally preferred alternative site at p. 9.3-1 of NUREG-1555, Vol. 1 as

“a site for which the environmental impacts are sufficiently less than for the proposed site so
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that environmental preference for the alternative site can be established.” The first stage

evaluates whether there are any environmentally preferable alternative sites. If one or more of

the alternative sites is determined to be environmentally preferable, the staff would conduct

further analysis to determine if the site(s) were obviously superior to the proposed site. Tables

9-1 and 9-2 in the EIS compare the staff’s characterization of the environmental impacts of

construction and operation at the North Anna ESP site to the three alternative ESP sites.

While there are some differences in the environmental impacts of construction and operation at

the four sites, the staff concludes that none of these differences is sufficient to determine that

any of the alternative sites is environmentally preferable to the proposed North Anna site. In

addition, NEPA principles do not require that a nuclear plant be constructed on the single best

site or the “least damaging place” for environmental purposes. Rather, NEPA requires that

alternative sites be considered and that the effects on the environment of building the plant at

the alternative sites be carefully studied and factored into the ultimate decision. Other

considerations, however, may outweigh the environmental preferability of an alternative site

over the proposed site. Accordingly, no changes were made to this EIS as a result of these

comments.

Comment: Page 1-5 states that an EIS must include an evaluation of alternative sites to

determine whether there are any obvious superior alternatives. Although Chapter 9 determines

that there are none, it also does not show that the Lake Anna site is clearly superior to many of

the alternatives. (SE-0045 41)

Response: The staff is required to determine whether any of the alternative sites is obviously

superior to the proposed site (see 10 CFR 52.18). The staff is not required to determine

whether the proposed site is obviously superior to the alternative sites, and it did not make any

attempt to do so. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Dominion states that North Anna was ranked the highest when compared to the

four possible locations. Please provide the criteria for the “weighting factor”? (SE-0004 6)

Response: The full explanation for the ranking on which Dominion based its ESP application is

documented in, “Study of Potential Sites for the Deployment of New Nuclear Plants in the

United States,” conducted under the U.S. Department of Energy Cooperative Agreement No.

DE-FC07-021D1431, and available at

http://np2010.ne.doe.gov/ESP_Study/ESP_Study_Dominion.pdf. These are briefly described in

Section 8.3.2 of this EIS. Accordingly, no changes were made to this EIS as a result of this

comment.

3.17.3.2 Brownfield Alternative Sites

Comment: In respect to potential brownfield alternative sites (Chapter 8.3.3), not enough

information is given to indicate that this option has been adequately explored. (DW-0685 14)
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NUREG-1811, Volume II 3-274 December 2006

Response: The CEQ advises that when there are potentially a very large number of

alternatives, only a reasonable number of examples, covering the full spectrum of alternatives,

must be analyzed and compared in an EIS (46 FR 18027; March 23, 1981). The staff has

determined that the site selection process and the proposed site and its three alternative sites

were analyzed in detail in the EIS; a site that already hosts one or more nuclear power reactors

can be considered a “brownfield” site. The staff concluded that the slate of alternative sites

considered represented a reasonable number of sites and was consistent with the staff’s review

guidance in NUREG-1555, Section 9.3 (NRC 2000). Section 8.3.3 of the EIS points out that a

brownfield site that did not host major industrial activities already would likely result in large land

area disturbances to construct the plant and related infrastructure such as a new transmission

line. This construction would likely have significant land use, ecological, and aesthetic impacts

compared to new construction at sites with existing nuclear power plants or other nuclear

facilities. Therefore, the staff did not further evaluate the need for additional brownfield sites

that did not already support an industrial complex because the environmental impacts would

likely be greater than developed sites. Accordingly, no changes were made to this EIS as a

result of this comment.

3.17.3.3 Surry Plant Site

Comment: DEQ’s Division of Water Resources believes that the Surry site is “superior” (as

described in the Draft EIS) to the North Anna site based on the following reasons: (1) the

limited water resources in the North Anna River watershed; (2) the amount of those resources

that are already being consumed by lake evaporation and the forced evaporation from the

existing two reactors; and (3) the competition for those resources downstream. It appears that

water availability would not be an issue on the tidal James River at Surry. The draft EIS says,

“The consumptive use of water to support mechanical draft cooling towers would be

undetectable relative to the supply in the estuary.” (DW-0439 18)

Comment: Division of Water Resources believes that the Surry site is "superior"...Based on the

information provided in the Draft EIS, the two most important disadvantages of the Surry site

(aesthetics and impingement and entrainment) are not substantiated. The Surry site seems

"superior" (as described in the DEIS) to the North Anna site for the following reasons: "the

limited water in the North Anna watershed;" the amount of water already being consumed by

lake evaporation from the existing two reactors; and " the competition for water resources

downstream. ...It appears that water availability would not be an issue on the tidal James River

at Surry. According to the Division of Water Resources, the Draft EIS says, "The consumptive

use of water to support mechanical draft cooling towers would be undetectable relative to the

supply in the estuary." (SW-0017 2)

Comment: [B]ased on the information provided, two of the most important disadvantages of

the Surry site (impingement and entrainment, and aesthetics), are not substantiated, while the

main disadvantage of the North Anna site (water availability) appears extremely problematic. 

DEQ’s Division of Water Resources and the Department of Game and Inland Fisheries would
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 December 2006 3-275 NUREG-1811, Volume II

have no concerns about this project if both the fourth and third reactors at North Anna were air

cooled. (DW-0439 21) (SW-0017 32)

Comment: Has the NRC’s tailored alternatives analysis unreasonably failed to identify one of

Dominion’s alternative sites – such as the existing Surrey Plant on the lower James River – as

“obviously superior” to the proposed North Anna site, when both the impacts of heat dissipation

and water withdrawal at the Surrey site, and possibly other sites, are clearly less than they are

at North Anna? (SE-0040 16)

Response: Water use is only one of the impacts that is used in the assessments of

alternatives. Impingement, entrainment, and aesthetics at the Surry site are discussed in

Section 8.5 of the EIS. The staff believes that although the Surry site would have fewer

operational impacts in drought years than the proposed North Anna site, the incremental

difference in impacts are not sufficiently less to render the Surry site an environmentally

preferred site.

All four sites (the proposed site and the three alternative sites) appear to have strong potential

for future nuclear development. The proposal of North Anna rather than Surry for an ESP was a

decision made by Dominion, not the NRC. Dominion’s basis for this decision likely was the

result of an analysis conducted by Dominion Energy, Inc. and Bechtel Power Corporation as

documented in their Study of Potential Sites for the Deployment of New Nuclear Plants in the

United States (Dominion and Bechtel 2002). This report ranks the four sites along with a site at

the Idaho National Laboratory. North Anna received the highest merit score based on

economic, engineering, environmental, and sociological factors. The Surry site was ranked

slightly lower in each of these four categories. In Section 8.5 of this EIS, the staff analyzed the

environmental impacts of constructing and operating additional units at the Surry site. Additions

to Section 8.5 were made to this EIS as a result of these comments.

Comment: At two meetings with DEQ staff (prior to the submission of the Commonwealth’s

comments on the Draft EIS, March 3, 2005), NRC officials were asked why North Anna rather

than Surry was being proposed for an early site permit. On both occasions, NRC staff cited

aesthetics and the fact that the plant might be visible from Jamestown. However, the draft EIS,

in its discussion of aesthetics (pages 8-32 and 8-33), does not indicate that there is any problem

with aesthetics at Surry. In fact, the Draft EIS states that the Surry plant’s “current structures

are not visually obtrusive from any vantage point, even from across the James River. However

Units 1 and 2 are visible from the highest amusement rides at Busch Gardens” (Draft EIS

page 8-32). The concerns about aesthetics are not supported by statements in the Draft EIS. 

(DW-0439 19) (SW-0017 30)

Response: All four sites (the proposed site and the three alternative sites) appear to have

strong potential for future nuclear development. The proposal of North Anna rather than Surry

for an ESP was a decision made by Dominion, not the NRC. Dominion’s basis for this decision

likely was the result of an analysis conducted by Dominion Energy, Inc. and Bechtel Power
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NUREG-1811, Volume II 3-276 December 2006

Corporation as documented in their Study of Potential Sites for the Deployment of New Nuclear

Plants in the United States (Dominion and Bechtel 2002). This report ranks the four sites along

with a site at the Idaho National Laboratory. North Anna received the highest merit score based

on economic, engineering, environmental, and sociological factors. The Surry site was ranked

slightly lower in each of these four categories. The staff’s independent analysis of the

environmental impacts of constructing and operating additional units at the Surry site is

described in Section 8.5. After receiving comments to the Draft EIS, the staff revisited the Surry

site and met with the Colonial National Historic Park Service. This visit led to additions to

Section 8.5.5.3 (Aesthetics and Recreation) including this text: “Based on the high level of

historical significance attributed to the Jamestown historical features and the fact that current

views of the Surry Power Plant range from full to partial, from both the island and the Colonial

Parkway, even more visible plant structures and the added cooling towers and condensation

plumes would constitute a major visual intrusion from this significant historic property....In the

context of an ESP with a building height of 234 ft at the Surry site, the visual impacts to Colonial

NHP and the Jamestown National Historical Site would be considered clearly noticeable and

would be sufficient to possibly destabilize the viewshed.” 

Comment: Impingement and entrainment issues ... would be a greater problem at the Surry

site than at Lake Anna. This is because the James River is an estuary at the Surry site. 

However, the alternatives section of the Draft EIS states that reactors at Surry would be cooled

with cooling towers (page 8-15, Section 8.5). As such, the impingement and entrainment

problem would be less than if once-through cooling were to be used. On April 4, 2001, Dr. John

Olney of Virginia Institute of Marine Resources wrote to Mr. Tony Banks of Dominion Power on

the subject of impingement and entrainment at Surry while commenting on the re-licensing of

the plant. In the letter Dr. Olney states, “Further, the available information on abundance and

distribution of fishes at the site suggests that there is a low probability that water withdrawals at

the plant are causing declines in federally managed species.” Since Dr. Olney does not

express concerns about a large once-through cooling water withdrawal, it appears that a cooling

tower withdrawal, orders of magnitude smaller, would also not be a concern. (DW-0439 20)

(SW-0017 31)

Response: The water withdrawal for the proposed ESP units at the proposed or alternative

sites would be in addition to the water withdrawal for any existing units. With regard to the

Surry site, the staff analyzed impingement and entrainment and determined that the impact

would be SMALL. The staff characterized the aquatic ecosystems impacts for plant operation

as SMALL at both the Surry and North Anna ESP sites (see Table 9-2 of the EIS). Accordingly,

no changes were made to this EIS as a result of this comment.

3.17.3.4 Savannah River Site

Comment: The assessment in the report did not credit the extensive environmental and

geotechnical database that exists at the SRS. ...The very high level of environmental

assessment and characterization of SRS was not accurately credited. SRS has been described
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as one of the most characterized sites in the Department of Energy (DOE) complex [additional

detail of reports provided]. ... A review of the Draft Environmental Impact Statement for an Early

Site Permit (ESP) at the North Anna ESP Site, NUREG-1811 shows that several factors within

its scope did not adequately consider available information that if properly credited would

demonstrate that all environmental impacts associated with the Savannah River Site are either

small or beneficial. (DW-0416 1)

Comment: Delete the statement, “The alternative sites have not undergone a comparable level

of detailed study.” The statement is not appropriately crediting the very high level of

environmental assessments and characterizations that exist for the SRS. In the case of the

Savannah River Site, the environmental impacts have been well characterized and are indeed

SMALL. ... Also for SRS, offsite impacts would be limited to currently existing transmission right

of ways, and the impacts are expected to be small. (DW-0416 15)

Response: The statement quoted from page 9-1 of the EIS reflects the review process for

consideration of alternative sites. By design, the alternative site evaluation is a high-level

evaluation and is limited to a reconnaissance level review, whether or not more detailed

information was available and developed for other purposes. The preferred site must undergo a

detailed evaluation and the NRC staff performed such a detailed evaluation of the North Anna

ESP site. While the Savannah River Site (SRS) has undergone significant characterization by

the Department of Energy for other purposes, the staff review of alternative sites considered the

project as the construction and operation of new commercial reactors and associated

transmission lines. This does not discount the viability of SRS as a site to host nuclear power

plants; however, consistent with the NRC’s environmental review practices, the SRS was not

determined to be “obviously superior” to the NAPS ESP site. Accordingly, no changes were

made to this EIS as a result of this comment.

Comment: I am surprised that one of the conclusions of the Staff is that “there are no

environmentally preferable or obviously superior sites”. My review of the data presented in

NUREG-I811 reaches a different conclusion. It appears to me that the Staff is overlooking a

number of factors which are indeed different among the various sites and, if considered, are

discriminators which would identify the Savannah River Site as an obviously environmentally

preferable site. (DW-0399 3)

Response: This comment does not provide specific information regarding SRS information

sources that the staff should have consulted during preparation of the EIS or how the staff’s

review did not conform to Section 9.3 of the ESRP (NUREG-1555). The staff used

reconnaissance-level information that was relevant to the alternative analysis presented in the

EIS. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The statements of generic impacts quoted below cannot be supported without

further analyses - the results of which may show a clear preference for one or another of the

proposed sites. Each of these impacts is dependent upon the nearby population density and
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NUREG-1811, Volume II 3-278 December 2006

distribution, and should therefore be different for each site. The Savannah River Site, with its

large controlled access area, relatively isolated location, and low nearby population density may

have a distinct advantage. [page 9-4, lines 28-32] (DW-0416 16)

Comment: Note that if corrections of nearby population density are needed, then impacts of

both routine and accident releases will need to be recalculated. (DW-0399 8)

Comment: These factors (air quality, health impacts, and radiation exposures) are not

inherently the same at each site under consideration. While emissions may be assumed equal

at all sites, the impact of air pollution and radioactive emissions is dependent on the exposure of

the population to these emissions. This exposure is governed primarily by two factors:

population density in the area surrounding the plant site, and distance to the plant boundary. 

The four sites are obviously different in nearby population density and distance of the proposed

reactor to the site boundary. I would suspect that the Savannah River Site has both the longest

distance to the boundary and the lowest nearby population of the sites under consideration;

therefore would have the lowest impact. The EIS should be modified to evaluate the impact of

these emissions at each site and consider both the nearby population and distance, as well as

local meteorological effects. (DW-0399 4)

Comment: The assessment did not credit the relatively isolated location of SRS and the low

nearby population density relative to the other candidate sites when discussing generic

environmental impacts to all sites. The generic environmental impacts listed in the report (air

quality, nonradiological and radiological health impacts and environmental impacts from

postulated accidents) are dependent on the nearby population density and distribution, and

should, therefore, be different for each site. (DW-0416 6)

Response: The staff considered population density and distribution in its analysis of impacts at

North Anna and the alternative sites. The staff concluded that the environmental impacts of the

construction and operation of new reactors at the North Anna ESP site would be of small

significance for issues discussed in Section 8.4. Assuming the same releases at the Savannah

River Site or the other alternative sites, the staff concluded that the significance of the

environmental impacts at those sites would also likely be small. The staff concluded that there

would be little gained by conducting a more detailed analysis of the alternative sites, because

the significance of environmental impacts at the North Anna site are already small. The

purposes of NEPA are not served well by expending resources trying to differentiate between

alternatives based on issues that have environmental impacts that are of small significance. 

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: I am surprised that the numerous examples of other environmental impacts of the

proposed action at the North Anna site were not more closely compared with potentially lesser

impacts at alternative sites. For instance: 1) Conversion of land to housing developments

(page 4-2), 2) Alteration of two ephemeral streams and possibly one-or more wetlands (4-5),

3) Dredging resulting in suspension of sediment (4-5), 4) Depression of the water table (4-6),
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5) Degraded water quality (4-12), 6) Fishery habitat changed (4-12), 7) Resuspension of heavy

metals from Contrary Creek (4-12), 8) Increased turbidity and reduced light penetration in Lake

Anna (4-13), 9) Overcrowding of Lake Anna and lessened recreational experience (4-28),

10) Doubling the time Lake Anna levels will be low, impacting recreational use (5-8),

11) Economic consequences to the three counties surrounding the lake. The more immediate

impacts would be to the marinas and commercial businesses that earn revenue... (5-44). Each

of these should be considered and compared to a similar assessment for the alternative sites

before the Staff draws a conclusion that there are no environmentally preferable or obviously

superior sites. (DW-0399 6)

Comment: Impacts to nearby public service facilities also need to be considered and are likely

to be a differentiator among the facilities under consideration. The EIS notes that construction

and operation of a new reactor at the proposed site will result in 1) Traffic congestion

(page 4-19 & 4-23), 2) Reduced housing-availability/increasing-rents (4-29), 3) Public water and

server “concerns” (4-30,) 4) Needed expansion of police and fire capability (4-32), 5) Increased

demand for social services (4-32), 6) Significant impact on already overcrowded schools (4-33),

7) Concern with water and sewer infrastructure in Louisa and Orange counties (5-45), and

8) Additional burden on already overcrowded Louisa county schools (5-47). The impact of the

proposed action needs to be evaluated for its impact at each of the proposed sites to determine

the differences that exist. I might point out that the employee population at the Savannah River

Site has decreased by almost 15,000 people since the early 1990s and the existing public

infrastructure may be much more capable of absorbing Dominion’s construction and operational

workforce with minimal impact. (DW-0399 5)

Response: Section 8.7 of the EIS contains the staff’s analysis of the Savannah River site. In

Table 8-6 of the EIS, the staff characterized impacts during construction as SMALL to

MODERATE for ecological impacts on terrestrial ecosystems and threatened and endangered

species. In Table 8-7, the staff characterized impacts during operation on threatened and

endangered species as SMALL except with regard to transmission lines, in which case impacts

were characterized as SMALL to MODERATE. The staff characterized the impacts during

construction and operation as SMALL for water use and quality and as SMALL to LARGE

BENEFICIAL for socioeconomic issues. None of these characterizations render the Savannah

River Site unsuitable for new nuclear power plants nor is it obviously superior to the North Anna

ESP site. The introduction to Chapter 9 of the EIS points out that the staff’s analysis of

alternative sites is not as detailed as the analysis of the proposed site; it is that way by design. 

The introduction goes on to point out that a proposed North Anna ESP site may be rejected in

favor of an alternative site not when the alternative is “marginally better” than the proposed site,

but only when it is “obviously superior.” NEPA does not require that a nuclear power plant be

constructed on the single best site for environmental purposes. Rather, NEPA requires that

alternative sites be considered and that the effects on the environment of building the plant at

the alternative sites be carefully studied and factored into the ultimate decision. The staff has

done just that in this EIS. While there are some differences in the environmental impacts of

construction and operation at the North Anna and SRS sites, the staff concludes that non of
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these differences is sufficient to determine that the SRS site is environmentally preferable to the

proposed North Anna site. Accordingly, no changes were made to this EIS as a result of these

comments.

Comment: Construction and operation impacts for some environmental impacts were

overstated as “small to moderate” because the author(s) assumed that the detailed routing of

the transmission line right-of-ways are not known at this time. Power from the SRS will be

transmitted using existing right-of-ways on and off the site and; therefore, the environmental

impacts would be “small.” (DW-0416 2)

Comment: Construction and operation impacts for transmission lines were overestimated and

would be SMALL. Although transmission lines on the Savannah River Site may need to be

upgraded, the transmission lines would use existing right-of-ways, and any construction impacts

would be minimal. Offsite, 500-kV transmission lines and switchyards already exist at Plant

Vogtle (adjacent to the site and directly across the Savannah River). The 500-kV transmission

lines at Plant Vogtle connect to the regional grid so that no additional right-of-ways would be

needed. Construction, if any, would merely add additional capacity to the existing lines and a

switchyard at the SRS depending on the power being transmitted. Assuming the power from

the SRS may be transmitted to a location 60 miles to the west is not realistic because right-ofway and permits may be excessive and time consuming to obtain. This assumption creates

unnecessary conservatism in the environmental impacts presented in the report for the SRS. 

(DW-0416 3)

Comment: In contrast to the many environmental and societal impacts (albeit small or

moderate, and potentially mitigable) NUREG-1811 describes for constructing a reactor at North

Anna, the only identified environmental impact of locating the proposed reactor at SRS is the

potential for land clearing if a new transmission line right of way is required. Since SRS is

already tied to the regional grid with four primary feeders in differing directions, it is highly

unlikely a new right of way will be needed. Except in the area immediately adjacent to the new

reactor to reach an existing line, extensive clearing should not be necessary. Even if some

clearing is needed, SRS is expected to be a government reservation in perpetuity, and on-site

clearing would have no public impact. (DW-0399 10)

Comment: Delete the current paragraph [page 9-6, lines 19-25] and replace with: “The

adverse impacts of construction at the Savannah Rive[r] Site alternative are SMALL for all

impact categories. Beneficial impacts ranging from SMALL to MODERATE were noted in the

community characteristics category, primarily as a result of beneficial economic impacts in

Barnwell County.” The current paragraph is based on two observations, which are invalid in

light of further information. First, the staff concludes that new transmission right-of-ways may

be needed, necessitating new construction and possible adverse impacts. In fact, the SRS site

selection process would ensure that the location of any new facility would be accessible to

existing rights-of-ways, and any upgrades would have negligible impact. (DW-0416 17a)
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Comment: Delete the current paragraph [page 9-7, lines 11-16] and replace with: “The

adverse impacts of operations at the Savannah River Site alternative ESP site are SMALL for all

impact categories. Beneficial impacts ranging from SMALL to MODERATE were noted in the

community characteristics category, primarily as a result of beneficial economic impacts in

Barnwell County.” The current paragraph is based on the observation that new transmission

right-of-ways may be needed, necessitating new construction and adversely impacting

operations and maintenance. In fact, the SRS site selection process would ensure that the

location of any new facility would be accessible to existing right-of-ways, and any upgrades

would have negligible impact. Offsite, existing 500-kV transmission right-of-ways would be

used as is, or would require an upgrade in capacity only; operation impacts would be minimal. 

Assuming the power from the SRS may be transmitted to a location 60 miles to the west is not

realistic because right-of-way and permits may be excessive and time consuming to obtain. 

This assumption creates unnecessary conservatism in the environmental impacts presented in

the report for the SRS. [The following six comments are associated with this comment.] 

(DW-0416 18)

Comment: Change the impact of operation on threatened and endangered species to “SMALL”

(from “SMALL to MODERATE”) [on page 8-67, line 11] (DW-0416 9)

Comment: Change the T&E Species impacts for the Savannah River Site to “SMALL” (from

“SMALL to MODERATE”) [page 8-81, Table 8-6, line 14; page 8-82, Table 8-7, line 14;

page 9-3, Table 9-1, line 14; and page 9-4, Table 9-2, line 16] (DW-0416 13)

Comment: Change the impact of construction on terrestrial resources (including threatened

and endangered species) to “SMALL” (from “SMALL to MODERATE”) [on page 8-67, line 6] 

(DW-0416 8)

Comment: Change the Terrestrial ecosystems impacts for the Savannah River Site to

“SMALL” (from “SMALL to MODERATE”) [page 8-81, Table 8-6, line 12 and page 9-3,

Table 9-1, line 12] (DW-0416 12)

Comment: Change the transmission system impacts to “SMALL” (from “SMALL to

MODERATE)” [on page 8-63, lines 30 and 37] (DW-0416 7)

Comment: Change the Transmission corridors impacts for the Savannah River Site to

“SMALL” (from “SMALL to MODERATE”) [on page 8-81, Table 8-6, Line 6 and page 9-3,

Table 9-1, line 7] (DW-0416 11)

Comment: Delete “and the Savannah River Site has significant unknown impacts associated

with the transmission line rights-of-way (could be anywhere from SMALL to MODERATE)”

[page 9-7, lines 25-26]. This phrase is based on the observation that new transmission right-ofways may be needed, necessitating new construction and adversely impacting operations and

maintenance. In fact, the SRS site selection process would ensure that the location of any new
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NUREG-1811, Volume II 3-282 December 2006

facility would be accessible to existing right-of-ways, and any upgrades would have negligible

impact. Offsite, existing 500-kV transmission right-of-ways would be used as is, or would

require an upgrade in capacity only; operation impacts would be minimal. Assuming the power

from the SRS may be transmitted to a location 60 miles to the west is not realistic because

right-of-way and permits may be excessive and time consuming to obtain. This assumption

creates unnecessary conservatism in the environmental impacts presented in the report for the

SRS. (DW-0416 19)

Response: It is the staff’s view that the new reactors would require at least 230-kV or 500-kV

transmission lines. Therefore, the new plant’s transmission lines would have to be routed into a

transmission system with the proper voltage, either on site or offsite. The SRS is a power

consuming location, not a power producing location; consequently, the transmission system on

the site consists of only 115 kV transmission lines. In any case, additional transmission lines

leaving SRS would be needed. The NRC staff evaluated the proposal provided by Dominion. 

The siting study provided by Dominion (Dominion and Bechtel 2002) included the option of tying

into an existing 500-kV transmission line located 60 mi west of SRS. Although the siting study

indicates that right-of-way and permit acquisition could involve a significant effort for this routing

alternative, it did not eliminate the alternative from consideration and, therefore, it cannot be

discounted. The comments provide no new information that would lessen the uncertainty

associated with this routing alternative. Therefore, the staff affirms its initial determination that

the impacts could be SMALL to MODERATE, depending on the specific routing of the

transmission lines. Accordingly, no changes were made to this EIS as a result of these

comments.

Comment: Transportation impacts were overstated in community characteristics as “small to

moderate” because the assessment did not credit the site as having an infrastructure on and off

the site that has already accommodated a workforce of 25,000. This maximum workforce of

25,000 employees is approximately 40% below the projected workforce required for the facility.

The environmental impact would be “small.” (DW-0416 4)

Comment: Transportation impacts were overestimated and would be SMALL. The

assessment did not credit the fact that the existing infrastructure on and in the vicinity of the site

is designed and constructed to accommodate a much larger workforce than will exist at the site

during the construction and operation phase of the proposed nuclear plant. The assessment

does not credit the fact that, even with the 38% increase, the site workforce would still be ~40%

below its 1993 peak of ~25,000 employees. (DW-0416 5)

Comment: [Delete the current paragraph (page 9-6, lines 19-25) and replace with]: “The

adverse impacts of construction at the Savannah River Site alternative are SMALL for all impact

categories. Beneficial impacts ranging from SMALL to MODERATE were noted in the

community characteristics category, primarily as a result of beneficial economic impacts in

Barnwell County.” The current paragraph is based on two observations, which are invalid in

light of further information. Second, the staff concludes that the construction workforce would
Comments Within Scope

 December 2006 3-283 NUREG-1811, Volume II

substantially increase the SRS workforce thereby moderately impacting transportation. In fact,

the SRS workforce, including the construction work force, would be significantly less than recent

SRS staffing levels and would be easily accommodated by existing transportation infrastructure. 

(DW-0416 17b)

Comment: Change the transportation impacts of the construction workforce to “SMALL” (from

SMALL to MODERATE”) [on page 8-73, line 13] (DW-0416 10)

Comment: Change the Community Characteristics impacts for the Savannah River Site to

“SMALL” (from “SMALL to MODERATE”) [page 8-81, Table 8-6, line 18 and page 9-3,

Table 9-1, line 19] (DW-0416 14)

Response: The staff based its impact level of SMALL to MODERATE on expected traffic

congestion during construction in the event of a 38 percent increase from existing employment

levels at SRS. While congestion exists on some of the roadways both onsite and offsite in the

vicinity of SRS, the comment notes that the roadways surrounding the site successfully

accommodated a larger workforce at peak employment in 1993. Dominion’s siting study

(Dominion and Bechtel 2002) in Part 2 (Section 5.7.3) notes that SRS has implemented

changes to remedy congestion at site access points and that with traffic mitigation measures,

the construction and operation of new nuclear power facilities at the preferred location within

SRS will result in “minimal” impacts on existing traffic patterns, workforce commuter traffic, and

rail/truck delivery of materials. The staff reevaluated the issue of transportation. Given the

mitigative measures already in place, the staff concludes that a level of SMALL is more

representative of the transportation impact level. This change is also reflected in the community

characteristics category, which is now represented as SMALL in the EIS.

Comment: The EIS states that population dose within 80 km (50 mi) of those alternative sites

that are closer to major population centers (e.g., Savannah River) could be higher than for the

proposed North Anna EDP [ESP] site; (page 8-12). I would like to see the data supporting this

statement, as I do not believe the population within 50 miles of SRS exceeds that of the North

Anna site. The 50 mile population of the North Anna region is reported as 1,538,156 in 2000

and expected to grow to 2,160,921 in 2020 (page 4-20). NUREG 1767, EIS on the Construction

and Operation of a Proposed Mixed Oxide Fuel Fabrication Facility the Savannah River Site

issued in January 2005 lists the population of the SRS Region of Influence as 475,095 in 2000

and 489,000 in 2002 (projected). The Region of Influence may not be exactly the same as

50 miles but it is similar. Please review this information in the draft. (DW-0399 7)

Response: The statement on page 8-12 of the Draft EIS actually related to the population and

associated doses within a 16-km (10-mi) radius of SRS rather than a 80-km (50-mi) radius. The

statement was removed from the EIS as a result of this comment. However, note that for both

North Anna and SRS, the impacts of population doses would be SMALL.
Comments Within Scope

NUREG-1811, Volume II 3-284 December 2006

3.18 References

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, “Early Site Permits,

Standard Design Certifications, and Combined Licenses for Nuclear Power Plants.”

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

Criteria.”

40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of Environment, Part 141,

“National Primary Drinking Water Regulations.”

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

1508, “Council on Environmental Quality, Terminology and Index.”

46 FR 18027. “Forty Most Asked Questions Concerning CEQ’s NEPA Regulations.” Federal

Register. Council on Environmental Quality, March 23, 1981.

54 FR 22578. “Disposal of Radioactive Wastes.” Federal Register. US Nuclear Regulatory

Commission, May 25, 1989.

55 FR 38472. “Consideration of Environmental Impacts of Temporary Storage of Spent Fuel

After Cessation of Reactor Operation.” Federal Register. Vol. 55, No. 181,

September 18, 1990.

59 FR 35461. “Regulation of Advanced Nuclear Power Plants; Statement of Policy.” Federal

Register. US Nuclear Regulatory Commission, July 12, 1994.

64 FR 68005. “10 CFR Part 51, Waste Confidence Decision Review: Status.” Vol. 64, No. 233. 

December 6, 1999.

69 FR 52040. “Policy Statement on the Treatment of Environmental Justice Matters in NRC

and Licensing Activities.” Vol. 69, No. 163. August 24, 2004.

70 FR 76165. “Approval and Promulgation of Air Quality Implementation Plans; Virginia;

Redesignation of the City of Federicksburg, Spotsylvania County, and Stafford County Ozone

Nonattainment Area to Attainment and Approval of the Area’s Maintenance Plan.” Federal

Register. Vol. 70, No. 246, December 23, 2005.

Bald and Golden Eagle Protection Act. 16 USC. 668.
Comments Within Scope

 December 2006 3-285 NUREG-1811, Volume II

Dominion Energy, Inc. and Bechtel Power Corp (Dominion and Bechtel). 2002. Study of

Potential Sites for the Deployment of New Nuclear Plants in the United States.

U.S. Department of Energy Cooperative Agreement No. DE-FC07-02ID14313. Available at

http://np2010.ne.doe.gov/ESP_Study/ESP_Study_Dominion.pdf

Dominion Nuclear North Anna, LLC (Dominion). 2006a. North Anna Early Site Permit

Application – Part 3 – Environmental Report. Revision 9, Glen Allen, Virginia.

Dominion Nuclear North Anna, LLC (Dominion). 2006b. Letter from E. Grecheck (Dominion) to

NRC regarding receipt of coastal zone management act certification, November 22, 2006.

Endangered Species Act (ESA) of 1973. 16USC 1531, et seq.

Energy Policy Act of 2005. P.L. 109-58.

Energy Information Administration (EIA). 2006. Uranium Marketing Annual Report (for 2005).

Accessed at http://www.eia.doe/gov/cneaf/nuclear/umar/urar.html on November 12, 2006.

Gowan, C., G. Garman, and W. Shuart. 1999. Design criteria for fish screens in Virginia:

recommendations based on a review of the literature. Prepared for the Virginia Department of

Game and Inland Fisheries, Richmond, VA.

Louisa County. 2006. Code of Ordinances County of Louisa, Virginia. “Chapter 51 Noise.” 

Accessed at http://library2,municode.com/mcc/DocView/1248064 on October 27, 2006.

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

NatureServe. 2006. NatureServe Explorer: An Online Encyclopedia of Life (Web Application). 

Available at http://www.natureserve.org/explorer.

Nuclear Nonproliferation Act of 1978. P.L. 95-242.

Spotsylvania County. 2006. Code of Ordinances County of Spotsylvania, Virginia. “Chapter 14

Offenses–Miscellaneous.” Accessed at http://library2.municode.com/mcc/DocView/12105/1/109

on October 27, 2006.

U.S. Fish and Wildlife Service (FWS). 2005. Letter from J. Wolflin (FWS) to P.T. Kuo (NRC)

concurring with biological assessment at the proposed North Anna Nuclear Power Station ESP

site, May 20, 2005.
Comments Within Scope

NUREG-1811, Volume II 3-286 December 2006

U.S. Nuclear Regulatory Commission (NRC). 2000. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants Main Report. “Section 6.3 – Transportation, Table 9.1

Summary of findings on NEPA issues for license renewal of nuclear power plants, Final Report.” 

NUREG-1437, Volume 1, Addendum 1, Washington, D.C.

U.S. Geological Survey (USGS). 2000. Ground Water Atlas of the United States. Edited by

James A. Miller, Reston, Virginia.

U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

for License Renewal of Nuclear Plants. NUREG-1437, Volumes 1 and 2, Washington, D.C.

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

Reviews for Nuclear Power Plants. NUREG-1555. Office of Nuclear Reactor Regulation,

U.S. NRC. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. Draft Environmental Impact Statement for

an Early Site Permit (ESP) for the North Anna ESP Site. NUREG-1811, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2006a. Memorandum and Order Granting

Summary Disposition and Terminating Contested Proceeding, ASLBP No. 04-8922-02. 

October 24, 2006.

U.S. Nuclear Regulatory Commission (NRC). 2006b. Safety Evaluation Report fo an Early Site

Permit (ESP) at the North Anna ESP Site, NUREB-1835 Supplement 1, September 2006. 

Accession No. ML063170371.

United States Securities and Exchange Commission (USEC). Annual Report Pursuant to 

Section 13 or 15 (d) of the Securities Exchange Act of 1934, for the Year Ended

December 31, 2004. 

(http://www.usec.com/v2001_02/Content/Investors/2004pdf/USEC2004AnnualReportFinancial.pdf)

Virginia Department of Health (VDH). 2005. Letter from R. B. Stroube (VDH) to R. Burnley

(VDEQ) regarding heat effects of immersion in ambient waters. September 15, 2005.

Virginia Department of Historic Resources (VDHR). 2006. Letter from R.W. Kirchen (DVHR) to

J. Cushing (NRC) regarding the 2006 archaeological survey at the North Anna ESP site,

October 20, 2006.

Virginia Electric and Power Company (VEPCo). 2005. Annual Radiological Environmental

Operating Report North Anna Power Station - January 1, 2004 to December 31, 2004. 

Richmond Virginia.
Comments Within Scope

 December 2006 3-287 NUREG-1811, Volume II

Virginia Electric and Power Company (VEPCo). 1986. Section 316(a) Demonstration for North

Anna Power Station: Environmental Studies of Lake Anna and the Lower North Anna River.

Virginia Power Corporate Technical Assessment, Water Quality Department, Richmond,

Virginia.
December 2006 4-1 NUREG-1811, Volume II

4.0 ESP Process, NEPA Compliance, and Comments

Supporting or Opposing the ESP

In this chapter, the U.S. Nuclear Regulatory Commission (NRC) staff responds to comments

received on NRC’s administrative process for treating early site permit (ESP), combined

construction permit (CP), operation license (OL), and combined license (COL) applications, and

on matters regarding compliance with NRC regulations. Commenters expressed concern with

the NRC processes for considering ESP applications and COL applications that reference an

ESP. Several commenters questioned the scope of the environmental review that would be

required for a COL application that references an ESP. In particular, one commenter

questioned how issues relating to plant construction and operation could be finalized for the

20-year duration of an ESP, because the environment might change and alter the conclusions

drawn in the environmental impact statement (EIS). Several commenters indicated that more

time was needed for public meetings, and sought a clearer understanding of how the ESP

process works. Commenters stated that the Draft EIS issued by NRC in December 2004

(NRC 2004) and the Supplement to the Draft EIS (referred to as the SDEIS) (NRC 2006) failed

to consider all the issues and deferred some issues to the COL stage. One commenter

remarked that the ESP process encouraged judgment that was inherently flawed. Other

commenters made the general statement that the Draft EIS did not address all the issues.

Several comments were related to the level of detail of design information included in the ESP

application submitted by Dominion Nuclear North Anna LLC (Dominion). By way of background,

an applicant for an ESP need not provide a detailed design of a reactor or reactors and the

associated facilities that might be built at the proposed ESP site. Rather, in lieu of detailed

design information, an ESP applicant may reference a plant parameter envelope (PPE) as a

surrogate for a specific plant design. That is, the applicant may provide bounding values of

design parameters for a plant that might be built at the site and assess the environmental

impacts associated with those bounding values.

Analysis of environmental impacts based on a PPE approach permits an ESP applicant to defer

the selection of a reactor design until the CP or COL stage. Several comments were received

that questioned whether the PPE contained enough design information for other-than-light-water

reactors, especially as it applied to postulated accidents and gas-cooled reactors. The U.S.

Environmental Protection Agency (EPA) recommended that the NRC consider issuing an

additional EIS when such information becomes available.

Comments were received expressing general support of or opposition to the NRC’s ESP

process. Some commenters stated that the Title 10 of the Code of Federal Regulation (CFR)

Part 52 licensing process involving an ESP and a COL is undemocratic. Some commenters

challenged the division of the ESP and the COL licensing processes. Some commenters

expressed lack of trust in the government. Some commenters expressed concern that
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-2 December 2006

unresolved issues might lead to abuses of the process. Some commenters expressed

dissatisfaction with the location and conduct of public meetings associated with the application.

Commenters requested that certain additional matters be addressed in the EIS including a

review of Dominion’s Environmental Report (ER) (Dominion 2006); a discussion of energy

alternatives; an assessment of the benefits of the proposed action; a discussion of mitigation

steps; irreversible and irretrievable impacts, relative costs, and benefits of alternatives; and a

more developed purpose and need.

4.1 ESP Process

Comment: I am writing first because I am very concerned that this ESP process is so

disjointed that it is very difficult for the public to follow either the process itself or the actual

specific details of the North Anna proceedings. It almost appears to be designed to be

confusing. (DW-0431 1)

Response: With respect to environmental matters, the NRC’s ESP process is as follows: The

NRC regulations governing an ESP application require that an applicant for an ESP must

provide the NRC with an ER that meets the requirements of 10 CFR 51.45 and 51.50. As

described in 10 CFR 52.17, the contents of an application must focus on the environmental

effects of construction and operation of a reactor or reactors that might be built at the proposed

site, even though an ESP does not authorize such construction and operation. Additionally,

Section 52.18 requires that the staff prepare an EIS on the application that focuses on the same

matters. Both the ER and the EIS must include an evaluation of alternative sites to determine

whether there is any obviously superior alternative to the site proposed. Certain issues,

however, such as the benefits of the action and alternative energy sources, may be deferred to

a later licensing stage, and other issues may not have sufficient information to be resolved at

the ESP stage. Issue resolution is a licensing matter, not a National Environmental Policy Act

of 1969 (NEPA) matter.

For the ESP, the NRC prepares an EIS that resolves numerous issues based on existing

environmental site characteristics, as well as values of power plant design parameters set forth

in the application. These issues are subject to issue preclusion in a proceeding on an

application referencing the ESP (i.e., such an issue would not be subject to litigation in a later

licensing proceeding). If an applicant chooses the PPE approach, as Dominion has done here,

the application postulates bounding values for these plant design parameters.

NRC licensing regulations allow an ESP applicant to defer an issue (e.g., the benefits

assessment) as Dominion elected to do, but requires that a COL applicant referencing such an

ESP address the issue in its application. An application for a CP or COL referencing an ESP

must also demonstrate that the design of the proposed facility falls within the parameters
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-3 NUREG-1811, Volume II

specified in the ESP. In addition, an application referencing an ESP should indicate whether

the site is in compliance with the terms of the ESP. Such an application should also identify

whether there is new and significant information on any issue resolved in the ESP proceeding.

The environmental review performed in connection with a COL application referencing an ESP

will tier off the ESP EIS. If no new and significant information is identified on an issue, then the

COL EIS will summarize the conclusion reached in the ESP EIS and state that new and

significant information was not identified with respect to that issue. If new and significant

information is identified, then a conclusion will be reached based on the analysis of the new and

significant information. Accordingly, no changes were made to this EIS as a result of this

comment.

Comment: [With] respect to the no-action alternative (Chapter 8.1), at what point in this

process, and for what reasons, could it be decided not to grant Dominion the authorization to

construct and operate additional nuclear reactors at North Anna? (DW-0685 13)

Response: As described in Chapter 2 of this volume, the NRC conducts a two-pronged review

of an ESP: the safety review and the environmental review. An ESP can be denied based on

either safety or environmental issues. From an environmental perspective, should the

Commission determine that an alternative site is obviously superior to the proposed North Anna

ESP site, then the Commission could deny the ESP application. Denial of the application

(i.e., selection of the no-action alternative) would avoid the impacts associated with site

preparation and preliminary construction activities allowed pursuant to 10 CFR 52.25(a). While

10 CFR 52.17(c) and 52.18, respectively, require that the ESP ER and EIS focus on the

environmental effects of construction and operation of a reactor, or reactors, at the proposed

site, an ESP would not authorize such construction and operation. Rather, a CP or COL

application referencing the ESP could authorize construction and operation, and an EIS on the

CP or COL application would include a discussion of the no-action alternative in relation to the

effects of reactor construction and operation. In addition, if new and significant information is

identified with respect to matters resolved in the ESP proceeding, the Commission could reach

a different conclusion in the CP or COL proceeding. Accordingly, no changes were made to this

EIS as a result of this comment.

Comment: I have a problem with the ESP, a fundamental problem with it. It’s a fixed and static

permit that’s going to be there for 20 years for a completely fluid situation. It doesn’t seem that

you would want something fixed when what it’s regulating is changing. Let’s look on both the

environmental and safety basis. How many things have changed in the last 20 years and will

change significantly in the next 20? For example, the population growth right around the lake,

the water usage, the road usage for evacuations, all of these things have changed. They don’t

know how they’re going to change again. We’ve seen an explosion at the lake, and we don’t

know what’s going to happen. If it continues like this, we’re going to be confronted with

continuous problems, and here they want to give a blank permit for 20 years. (DT-0015 1a)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-4 December 2006

Comment: I feel really frustrated with this process. The fact that we’re giving Dominion the

protection of a 20-year bank on a site and so much changes in 20 years. (DT-0035 1)

Comment: EPA has concerns that the twenty-year horizon allotted under the proposed ESP

does not have any protective assurance that unforeseen population growth and/or additional

stressor on the air or water resources will be accounted for. Typically an action that has not

occurred within three years of an EIS requires at a minimum a supplemental EIS. (DW-0422 4

and SE-0030 5)

Comment: [B]y creating a twenty year window for the action, the ESP process makes

conclusions about the Site and its environment, that are likely not to be true soon after the ESP

is approved. The window is too large given the narrow amount of data that is being provided to

the public and interested local governments. (DW-0594 2b)

Comment: [E]ven if the whole picture [ESP process] were clear and complete, it would only be

so based upon today’s data, and not the facts, whatever they may be, at the time the decision is

made to build the additional facility(s). (DW-0431 2)

Comment: Putting off some of the issues, as other people have referred to, to the time of the

COL, the construction license, could be disingenuous, and you have a new process you’re

doing here, the staged process that’s being tried out. Now, that could have some benefits to it

doing it that way, but if it’s used in a manner that varies certain issues, if you get a site permit

before you’re really addressed all the important issues that go into site suitability, that could be

viewed as undermining that whole process. (DT-0021 7)

Comment: My general comment is about the relevance of this Environmental Impact

Statement for an Early Site Permit at the North Anna Site, since this is a new type of EIS and its

purpose is not fully clear; and, if we accept the value of the assessment of the Early Site Permit,

with the acceptability of this particular analysis. Many issues needed in a complete EIA are

deferred in this EIS for an Early Site Permit, and it is difficult for me to see the benefit of what

appears to me to be an incomplete assessment. (DW-0685 1)

Comment: As described in NEI’s [Nuclear Energy Institute] February 10, 2005 letter

(ML050530439), for any issues deferred from ESP to COL, the NRC could issue a supplemental

EIS documenting its evaluation. [pages 8-1 and 9-8, line 42 and line 14] (DW-0423 45)

[page 9-8, line 17] (DW-0423 48)

Response: For an ESP, the NRC prepares an EIS that can resolve numerous issues based on

existing and projected environmental site characteristics, as well as bounding values of power

plant design parameters postulated in the application. These issues are subject to issue

preclusion in a proceeding on an application referencing the ESP (i.e., such an issue would not

be subject to litigation in the later licensing proceeding). NRC regulations allow an ESP
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-5 NUREG-1811, Volume II

applicant to defer an issue (e.g., the benefits assessment) as Dominion has elected to do, but

also require that a COL applicant referencing such an ESP address the issue in its application. 

An application referencing an ESP must also demonstrate that the design of the facility falls

within the parameters specified in the ESP. In addition, the application should indicate whether

the site is in compliance with the terms of the ESP.

For example, in this EIS, the staff presented population growth estimates and reached certain

conclusions based on those estimates. If the Commission issues the requested ESP and it is

later referenced in a CP or COL application, the staff would consider then-current (new)

population information to determine whether that information is significant. If that new

population information is significant, the staff will revisit the conclusions in the ESP EIS that are

based on population growth estimates. If the new information is not significant, then the

conclusions documented in the ESP EIS that are based on population growth remain valid with

respect to the estimates, and the COL or CP EIS will tier off the conclusion reached in the

ESP EIS.

To summarize, if the Commission issues the requested ESP and it is later referenced in a CP or

COL application, then that application should identify whether there is new and significant

information on any issue resolved in the ESP proceeding. In its review of a CP or COL

application, the staff will consider any new and significant information that has been identified. 

Absent new and significant information, issues resolved in an ESP proceeding need not be

reconsidered at the COL stage even though the ESP is valid for a 20-year period.

EPA stated that “Typically an action that has not occurred within three years of an EIS requires

at a minimum a supplemental EIS.” However, in this case, issuance of an ESP completes the

proposed action. If an ESP is granted and an application to construct a nuclear power reactor

on the North Anna ESP site referencing the ESP is submitted, the staff will prepare an EIS on

that application. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Page 1-1 states that the safety characteristics and emergency planning are to be

analyzed separately from the EIS process. NEPA clearly states that an EIS is required for “any

major federal action significantly affecting the quality of the human environment.” Since safety

and emergency planning are elements of the human environment, a NEPA EIS should address

these points directly. The EIS is intended to be a primary source of impact information (both

positive and negative). Besides the legal shortcomings of the current approach, how can the

public and local governments be well-informed about the project if the basic data, analysis, and

conclusions are spread across a variety of proceedings? This unfairly disenfranchises

stakeholders. (DW-0438 5)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-6 December 2006

Comment: The Executive Summary page xxi, line 38 states that the ESP application (and thus

by extension an EIS on an ESP) must address “site safety, environmental impacts, and

emergency planning.” Complete information on all three of these points is lacking in the EIS. 

(DW-0438 3)

Comment: And let’s address risk for a moment. We can’t talk about waste. We can’t talk

about terrorism because it’s not addressed in your EIS. We can’t talk about significant

mitigation design alternatives, which is required by law because they don’t have a design. 

(DT-0033 3)

Comment: Why are citizens told that they cannot raise issues on nuclear reactor security and

nuclear waste? (DT-0038 3 and DW-0187 6)

Comment: Why are we not allowed to make any comments on the safety and waste issues??? 

(DW-0431 6)

Comment: Dominion is leading a consortium that plans to apply for a combined construction

and operation license (COL) in 2008. Thus, if granted an ESP, Dominion could be permitted to

begin an extensive construction operation while numerous, important issues, such as the need

for power and the indefinite storage of additional waste onsite, have not been addressed. 

Simply declaring that NRC is not required to look at these issues does not make them go away. 

(DW-0437 4)

Comment: It’s fundamentally wrong in this permitting thing to exclude security and terrorism,

the ultimate waste disposal, the waste storage on site, alternative sources, and the need for

power. (DT-0015 1b)

Comment: [T]he ESP process takes away citizens rights to get a complete look at the

proposed action. The ESP EIS only looks at certain things, the Safety Report (which was barely

made available to the public) looks at others, the COL will look at others. This is not the way

the National Environmental Policy Act and its implementing regulations require the system to

work. Citizens and government reviewers need to be able to get a look at the big picture of a

proposed action in order make informed judgments and provide input. For example: Exclusion

of considerations like terrorism and nuclear material transport are major flaws in the process. 

DW-0594 2a)

Response: The Atomic Energy Act of 1954, as amended, and the Energy Reorganization Acts

of 1974, as amended, establish the specific mission of the NRC to protect the public health and

safety in permitting the utilization of nuclear material. NEPA directs all Federal agencies to

ensure that environmental values are considered in fulfilling the missions. The NEPA process

focuses on potential environmental impacts resulting from the proposed action rather than on

issues related to safety. That said, certain issues that are analyzed as part of the safety review
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-7 NUREG-1811, Volume II

are relevant to the environmental review because they could potentially result in environmental

impacts; this is why, for example, the environmental effects of postulated accidents are

considered in the EIS.

Some issues have been resolved generically by the Commission, such as the environmental

impacts of the uranium fuel cycle, the impacts of managing waste, and transporting spent fuel

and waste; consequently, because they have been resolved and codified in NRC rules and

regulations, they need not be analyzed further unless the rules do not apply to a particular

situation, such as for other-than-light-water reactors.

Some issues, such as terrorism and security, are not discussed in the EIS because the

Commission has determined that NEPA does not require such a discussion. See Private Fuel

Storage, L.L.C. (Independent Spent Fuel Storage Installation), CLI-02-25, 56 NRC 340 (2002). 

Since that decision, the Court of Appeals for the Ninth Circuit ruled that an evaluation of

terrorism was required in an environmental assessment for an independent spent fuel storage

installation at a reactor site. See San Luis Obispo Mothers for Peace v. NRC, 449 F.3d 1016

(9th Cir. 2006). In its decision, the Court of Appeals did not agree with the rationale for the

Commission’s decision that the impacts of terrorism need not be considered under NEPA. 

However, inasmuch as the licensee in the Mothers for Peace case has filed a petition for a writ

of certiorari with the United States Supreme Court, the Ninth Circuit’s decision may yet be

modified or reversed. Given the ongoing nature of these developments, the Commission has

not altered its position regarding evaluation of the environmental impacts of a terrorist attack. 

Finally, the Mothers for Peace decision applies only in the Ninth Circuit. Accordingly, the NRC

staff position on this matter is still controlled by the Commission decisions ruling that the

impacts of terrorism need not be addressed in the context of NRC environmental reviews under

NEPA. The rationale for these decisions is set forth below.

First, the Commission does not currently have a method or theory with which to perform a

meaningful analysis of the environmental impacts of terrorism with respect to a particular facility. 

Second, in the absence of specific information indicating that a terrorist attack on a specific

facility is likely to occur, NEPA does not require consideration of postulated terrorist attacks. 

Third, the public aspect of the NEPA processes conflicts with the need to protect certain

sensitive information because (1) a review of terrorism under NEPA would involve examination

not only of how terrorist attacks could cause maximum damage but also how they might best be

thwarted, and (2) confidentiality in this area protects against the risks that terrorism poses to

public health and safety.

Emergency planning is a fundamental element of the Commission’s defense-in-depth safety

philosophy. The NRC will not issue a license to operate a nuclear power reactor unless it finds

that there is reasonable assurance that adequate protective measures can and will be taken in

the event of a radiological emergency (see 10 CFR 50.47). This is a safety finding under the

NRC’s Atomic Energy Act responsibilities. Safety issues are generally outside the scope of the
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-8 December 2006

environmental review because the NEPA process focuses on the environmental impacts of the

proposed action rather than on issues related to safety. This is discussed in greater detail in the

introductory remarks to Chapter 5 of Volume II of this EIS.

Accidents involving radioactive material can have environmental impacts. Consequently, the

impacts of postulated accidents are analyzed in Section 5.10 of Volume I of this EIS. Under

NEPA, the analyses are to reflect “reasonably foreseeable” consequences even though the

likelihood of accidents is low. In its evaluation of severe accidents, for example, the staff

considered incident response principles. The stylized analysis using the MACCS2 code takes

into account a delay time prior to simulating the relocation of the affected segment of the

population. These analytical assumptions are not intended to be linked to specific elements of

detailed and site-specific emergency plans for a nuclear power reactor, but are intended to

reflect the reasonable expectation that action will be taken to protect the public.

Other issues are not addressed in this EIS, such as the benefits assessment (e.g., need for

power), alternative energy sources, and severe accident mitigation alternatives, because they

may be more appropriately considered at the time an applicant selects a design and requests a

CP or COL. Except for selected activities considered in a site redress plan, if approved,

construction cannot begin until a CP or COL is issued. A CP or COL cannot be issued until all

environmental issues have been evaluated.

Safety issues and emergency preparedness are addressed in the North Anna ESP Safety

Evaluation Report (ADAMS Accession No. ML052710305) issued in September 2005

(NRC 2005a). This report is available on the NRC’s website at www.nrc.gov. Any safety issues

that are raised during the environmental review are forwarded to the appropriate NRC safety

project manager for consideration and appropriate action. In view of the above, no changes

were made to this EIS as a result of these comments.

Comment: [Referring to Dominion’s Site Safety Analysis Report in the ESP] [M]uch of the data

used in these evaluations and analysis seem to be the same data used during earlier planned

construction at the North Anna Power Station. With the increased technology available, the

most current data should be analyzed for a project of this magnitude that could have potential

significant effects on the safety protection and welfare of a large area the population in this

region during this time of heightened awareness toward security. (DW-0191 11)

Response: The rationale for the two-pronged ESP reviews was provided in the previous

response. Siting and environmental information used to characterize the site and to evaluate

impacts comes from a variety of sources. With today’s technologically advanced tools, the NRC

environmental review team used resources available from the Internet and Geographical

Information Systems to complement site-specific information provided by Dominion. As outlined

in its denial of a petition for rulemaking, the Commission stated its expectation that, to the extent

practicable, applicants for ESPs and COLs would “... rely on previously filed siting and
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-9 NUREG-1811, Volume II

programmatic information, as is permitted under existing NRC regulations. ... Existing

information may be referenced; however, applicants need to demonstrate the information is

technically applicable to the prospective licensing action.” (68 FR 57383). Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: The purpose of an early site permit is supposedly, quote, to assess whether a

proposed site is suitable for a nuclear reactor. Yet the draft EIS for the North Anna ESP fails to

consider or to fully acknowledge numerous environmental issues that indicate the site is not

suitable for additional reactors. (DT-0019 1)

Response: The comment lacks specificity in what environmental issues were not considered

or fully acknowledged in the staff’s evaluation. The scope of issues involved in the EIS for an

ESP was discussed in RS-002 (ML040700094) (NRC 2004), and it relies on the NRC’s

Environmental Standard Review Plan for Environmental Reviews of Nuclear Power Plants

(ESRP), NUREG-1555 (NRC 2000). This EIS is consistent with the review standard. 

Therefore, the comment was not evaluated further, and no changes were made to this EIS as a

result of this comment.

Comment: The ESP process itself encourages judgment which is inherently flawed. The

Supreme Court addressed a similar two-step regulatory process in 1961 regarding the AEC

[Atomic Energy Commission] permit for the Fermi reactor. Though the court approved, Justices

William O. Douglas and Hugo Black in their dissent wrote “When millions have been invested,

the momentum is on the side of the applicant, not on the side of the public.” Douglas and Black

further criticized the Commission’s approval of the reactor permit before resolution of safety

issues as “a lighthearted approach to the most awesome, the most deadly, the most dangerous

process ever created.” [Power Reactor Development Company. International Union of

Electrical, Radio and Machine Workers, AFL-CIO et al. 367 US 396 (1961)] (DT-0034 10)

Response: The dissenting opinion of Justices Douglas and Black addressed the Atomic

Energy Commission (AEC) 10 CFR Part 50 licensing process allowing a nuclear power plant to

be built pursuant to a construction permit (CP) before considering a request for an operating

license (OL) for that plant. The Justices were explicit in their disbelief that the AEC could review

the OL application without regard to the investment committed to the plant under the CP. See

PRDC, 367 U.S. at 417. The majority of the Court did not find fault with the AEC’s procedures. 

Under the 10 CFR Part 52 alternate licensing process, however, the final licensing decisions on

siting and design are made before the plant is built. The ESP process resolves siting and

certain environmental issues early. Rather than being similar to the old CP/OL process

criticized by Justices Douglas and Black, Part 52 could not be more different. The comment

provides no new information, and accordingly, no changes were made to this EIS as a result of

this comment.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-10 December 2006

Comment: Page 5-1, line 13 states that the operating period for the proposed project would be

40 years. Is the applicant prepared to stipulate that? If not, would another EIS be required for

an extension of the COL? (DW-0438 122)

Response: The NRC issues permits and licenses for fixed terms established by statute or

regulation; the NRC is also authorized to renew permits and licenses. The COL will contain

terms and conditions consistent with the relevant statute or regulation, including a limit on

duration. As outlined in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for

Nuclear Power Plants, an operating licence may be renewed for a period of 20 years. The NRC

prepares an EIS for the renewal of an operating license. Accordingly, no changes were made

to this EIS as a result of this comment.

Comment: The NRC and applicant should stipulate that there will be no extension of the

20 year ESP window under any circumstances. Otherwise, statements like those on

page 4-47, line 2 are worthless and the DEIS analysis becomes even more detached from

actual conditions. (DW-0438 12)

Response: NRC regulations (10 CFR 52.29) permit an applicant to apply for the renewal of an

ESP. The duration of the renewal may be for not less than 10 years or more than 20 years. 

Any renewal request is another licensing action; an environmental review would be conducted

as part of the staff’s evaluation of a renewal request. Accordingly, no changes were made to

this EIS as a result of this comment.

Comment: In the EIS meeting at the Louisa County Middle School, the NRC gave the North

Anna Nuclear Plant site a clean bill of health and said it met all the criteria they were instructed

to deal with. And that’s where the biggest problems are. The White House recently changed

the criteria so a nuclear plant EIS does NOT include dealing with nuclear garbage and does

NOT include any security questions. (DW-0823 1)

Response: The NRC presented the preliminary results of its analysis of environmental impacts

at the public meeting (February 17, 2005). The comment is factually incorrect; the White House

has not changed any of the NRC regulations. The ESP process is covered in 10 CFR Part 52,

promulgated in 1989 using the NRC’s rulemaking process, which includes public participation. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The DEIS should include a statement of the amount of government funds that are

available for the North Anna ESP process. (DW-0438 166)

Response: The amount of government funds available for the North Anna ESP process has no

bearing on the NRC environmental review and, therefore, is not included in this EIS. 

Accordingly, no changes were made to this EIS as a result of this comment.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-11 NUREG-1811, Volume II

Comment: And can you identify for me the sections in the draft environmental impact statement that were listed or close to listed without clear attribution from the early site application

directly into the DEIS? (DT-0001 1)

Comment: I mentioned the problem of plagiarism, and I did ask our librarian, the professional

librarian, whether there was plagiarism [with regard to words from Dominion ER related to

aquatic ecology and migrant labor] in this report, and you can correct me if I am wrong...I would

like to know whether you actually start with the permit application in the computer and edit it in

certain parts or whether the draft environmental impact statement is a fresh look at the

environmental impacts of the proposed plants. In the one place where -- there are no citations

[to the ER] here. (DT-0001 6)

Comment: As a local resident, I was unimpressed that the NRC team had done a decent job in

their draft proposal (some of the language was plagiarized from other sources!). I am highly

unclear and suspicious of the relationship between Dominion and the NRC of a government

clearly committed to revamping the nuclear industry in the U.S. as a whole – and is clearly

prepared to do anything or tell any lie to get their way (e.g., their certainty that “weapons of

mass destruction” existed in Iraq led us into an expensive, illegal, murderous, ruinous war). 

(DW-0830 2)

Response: Dominion’s ER was submitted under oath or affirmation as part of the application for

an ESP. Applicants use the body of NRC regulatory guidance (e.g., Regulatory Guides, Review

Standards, and Standard Review Plans) and take advantage of approaches and methods that

are acceptable to the NRC to analyze environmental impacts. The staff relied upon the ER as a

source of basic information about the plant parameters, the site, the region, and the

environment; this is by design, and the ER submitted by the applicant is intended to be the

starting point for the staff’s independent review. The applicant and the NRC are not required to

have alternate positions on the significance of environmental impacts; nevertheless, at times

there are different conclusions reached based on different methods and assumptions. 

Subsequent to the acceptance of the application, the staff visited the site; consulted with local,

State, and Federal agencies; and conducted its own independent review. The EIS is the result

of the staff’s review and properly includes material from various sources including the ER. In

the end, the NRC is responsible for the reliability of all of the information used in its EIS. If, as

part of its independent review, the NRC determines that information presented in the ER is

useful and the NRC confirms its accuracy, then the NRC may use the information and analyses

in its EIS. The EIS has been reviewed and revised, as appropriate, to ensure that sources of

information are clearly identified and ER authorship is properly attributed.

Comment: An EIS is supposed to be prepared by an independent multi-disciplinary team. To

what extent did the NRC commission any independent environmental reviews above the data

presented in Dominion’s ER? This is not clear from Appendices A and B and the cited

references. (DW-0438 174)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-12 December 2006

Response: Appendix A contains a list of the contributors to the Draft EIS and specifies their

areas of expertise. The areas of expertise cross the physical, biological, social, and radiological

disciplines comprising a multi-disciplinary team. Where independent analyses were determined

to be necessary to support the NRC conclusions, they are described in the EIS including

Appendix G, which provides the supporting documentation related to the impacts of

transportation. In addition, more details of the water budget assessment (Appendix K) and

radiological dose calculations (Appendix H) were added to the EIS.

Comment: We also have one generic comment concerning identification of parameters used in

the environmental review. The NRC staff has provided an ESP template indicating that the

parameters that are used in the Environmental Report and that form the basis for the EIS will be

identified (listed) in the ESP. Presently, these parameters are scattered throughout the EIS

making it difficult to determine which parameters the ESP applicant should expect to be

identified in its permit. We recommend that the North Anna EIS and future DEISs include a

tabulation of the parameters used in support of the staffs environmental reviews for ESP. 

(DW-0435 3)

Response: The parameters included in the PPE are enumerated in Appendix I of the EIS. In

addition to the parameters contained in Appendix I, the staff made assumptions and relied on

Dominion’s representations made in its ER to reach its conclusions. These assumptions and

technical bases are now listed in a new Appendix J of this EIS.

Comment: We think that the draft environmental impact statement, while it is voluminous and

treats many issues in detail, nonetheless has some very serious deficiencies in that it doesn’t

treat some issues adequately. (DT-0021 2)

Comment: The ESP is part of a new ?streamlined” licensing process meant to reassure

investors that past regulatory delays will not occur again. However, this will prevent citizens

from raising crucial safety problems that have been at the root of past delays. The process has

gone forward rapidly with little effort on behalf of the U.S. Nuclear Regulatory Commission

(NRC) or Dominion to involve members of the public, either locally or nationally, despite its

profound implications. (DT-0053 5)

Comment: The draft environmental impact statement fails to consider or to fully acknowledge

numerous environmental issues that indicate that the North Anna site is not suitable for

additional reactors. It has been said that these issues are not as critical now since the ESP

would not permit full construction, but if the ESP is granted, “site preparation” and preliminary

construction activities” can be carried out, including site clearing, stream clearing, and

excavation, as well as construction of permanent foundations, intake structures, and outfall

structures. (DW-0401 2)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-13 NUREG-1811, Volume II

Comment: Based on the above review, I believe that the document is substantially flawed and

request that these comments and others be fully addressed and that another DRAFT EIS be

released. Unless such an action is taken, concerned citizens and local governments (and

indeed the NRC since it is supposed to be relying on the DEIS for decision-making) cannot

make informed decisions about the proposed project. ( DW-0438 176)

Comment: The flaws in the document do not provide the scientific, legal, or policy background

to support a finding to recommend the ESP. (DW-0438 177)

Response: The NRC process for evaluating the environmental portion of ESP applications was

embodied in its Environmental Standard Review Plan for Environmental Reviews of Nuclear

Power Plants (ESRP) (NUREG-1555), which was issued in 2000 after it was subject to public

comment. The ESRP forms the basis for the environmental portion of RS-002 (ML040700094)

(NRC 2004). This ESP EIS conforms to the review guidance and is sufficient to fulfill NRC’s

NEPA responsibilities. The comments do not specifically identify which portion of the NRC

review does not conform with NRC’s published review guidance. The staff has determined that

another Draft EIS does not have to be issued. Accordingly, no changes were made to this EIS

as a result of these comments.

Comment: In sum, the DEIS fails to undertake an adequate analysis and assessment of the

environmental impacts of two additional units at the current North Anna Power Station. There is

insufficient discussion of the impacts that two additional reactors would have upon compliance

with the designated use of Lake Anna and the North Anna River for aquatic life, and with the

numeric water criteria for maximum temperature within both waters. The DEIS leaves

unresolved several critical, site-specific environmental issues at the very proceeding that is

designed to determine the environmental suitability of the site for additional units. It is

impossible to declare this a suitable site based on the data and analysis contained in the DEIS. 

(DW-1122 15)

Comment: The impact analysis deferral [regarding hydrologic operational practices and

procedures] on page 5-7, line 11 is objectionable. (DW-0438 135)

Response: Water related impacts are thoroughly discussed in Section 5.3, and aquatic

impacts in Section 5.4.2 of the EIS. Additional discussion related to the impacts on aquatic life

in the North Anna River has been added to the EIS.

Comment: The important factors [excluded from the process] are too numerous to list in a brief

communication – but you know what they are anyway! ( DW-1037 2)

Response: The public was afforded the opportunity to provide comments on the Draft EIS and

supplement. This comment lacks specificity and was not evaluated. There are areas that were

not evaluated at this stage in the licensing process, including the benefits assessment (need for
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-14 December 2006

power, cost of power) and alternative energy sources. In addition, the safety evaluation report

evaluated safety issues including emergency planning, security, and seismic issues. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: In addition, many of the necessary analyses about mitigating these potential

impacts are being postponed to the COL stage, the combined construction and operation

license stage. For example, Dominion did not have to provide any information on the practices

and procedures to minimize the impacts of adding additional hot water to the lake. Other

decisions are left until after the NRC has already granted the ESP, such as whether the State of

Virginia or the Commonwealth of Virginia, rather, would permit Dominion to even increase its

effluent discharges into the lake. (DT-0019 3)

Response: Measures and controls to limit adverse impacts during construction and operation

that were considered are discussed in Sections 4.10 and 5.11, respectively, of the EIS. At the

COL stage, the staff will tier off the ESP EIS and identify and assess new and significant

information including, as stated in Section 5.3.1, practices and procedures to minimize the

adverse impacts resulting from hydrological alterations. The Commonwealth of Virginia has the

regulatory authority under the Clean Water Act to regulate the non-radiological discharges to

receiving waters. In fulfilling its NEPA responsibilities, the NRC discloses the impacts of the

effluent discharges, but does not have the regulatory authority to set the limits. Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: Also we are concerned that the U.S. Nuclear Regulatory Commission admitted two

of the arguments – that Dominion had failed to analyze the environmental impact if they took no

action at all, and that Dominion had failed to fully analyze the impact of new reactors on the

striped bass population in the lake. (DW-0857 6)

Response: The NRC staff evaluated the no-action alternative (Section 8.1) and analyzed the

impacts of new reactors on the striped bass population in the lake (Section 5.4.2.5). 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The 10 CFR Part 52 framework provides finality for previously resolved issues that

is fully consistent with the requirements of NEPA. There is no requirement for NRC to re-review

previously resolved issues or to prepare an EIS for a subsequent COL proceeding regarding

impacts that were considered at ESP. Under NEPA, ESP and COL are “connected actions”

because the EIS prepared for ESP considers the potential environmental impacts of constructing and operating one or more new nuclear plants at the proposed site. The environmental review at the COL stage (when an ESP is referenced) would therefore be limited to a

showing that the specific design chosen falls within the parameters specified in the ESP and to

consideration of other significant environmental issues, if any, not considered in the previous
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-15 NUREG-1811, Volume II

proceedings. For any issues deferred from ESP to COL, the NRC could issue a supplemental

EIS documenting its evaluation. This position is fully discussed in NEI’s February 10, 2005

letter to NRC. (ML050530439) [page xxi, line 35 and other DEIS locations] (DW-0423 1)

Comment: The environmental impacts of construction and operation are evaluated in the

DEIS. The environmental review at the COL stage (when an ESP is referenced) would

therefore be limited to a showing that the specific design chosen falls within the parameters

specified in the ESP and to consideration of other significant environmental issues, if any, not

considered in the previous proceedings. [page 1-3, line 33] (DW-0423 2); [page 2-21, line 2]

(DW-0423 8.2)

Comment: The environmental impacts of operation are evaluated in the DEIS. The

environmental review at the COL stage (when an ESP is referenced) would therefore be limited

to a showing that the specific design chosen falls within the parameters specified in the ESP

and to consideration of other significant environmental issues, if any, not considered in the

previous proceedings. [page 5-7, line 19] (DW-0423 30); [page 5-10, line 28] (DW-0423 33)

Comment: The environmental impacts of construction and operation are evaluated in the

DEIS. The environmental review at the COL stage (when an ESP is referenced) would

therefore be limited to a showing that the specific design chosen falls within the parameters

specified in the ESP and to consideration of other significant environmental issues, if any, not

considered in the previous proceedings. As discussed in NEI’s February 10, 2005 letter

(ML050530439), updated meteorological data may not be needed. [page 5.69, line 37] 

(DW-0423 42)

Comment: There is one major generic concern, the finality of matters reviewed and resolved at

the ESP. This is the subject of ongoing discussion with the NRC staff and is described in NEI’s

February 10, 2005, letter to Dr. William Beckner (enclosed). An ESP and a future combined

license (COL) referencing the ESP are “connected” federal actions within the NEPA framework. 

This means that once reviewed for ESP, an environmental issue need not be reviewed again at

the COL stage. Mirroring the intent of connected federal actions within environmental regulations are the finality provisions of 10 CFR 52.39. These finality provisions state that in a COL

review, the NRC shall “treat as resolved” those matters in that were resolved in the ESP. 

(DW-0435 2)

Comment: If, once the new reactors are installed, a devastating effect in lake levels or

temperatures, or noise levels manifests, Dominion will merely say “oops”. There will be nothing

that can be done, even by the NRC or State. The only hope we have for equity and fairness in

this matter is that your commissions can ensure that Dominion’s impact analyses are wholly

accurate and realistic NOW, before approval is given. (SE-0020 2)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-16 December 2006

Response: The actions of issuing an ESP and a COL for which the application references the

ESP are not connected in the sense that a single EIS is required to evaluate the impacts of both

actions. Rather, the NRC is free to evaluate the matters that are ripe for consideration at the

ESP stage separate from those matters that become ripe at the COL stage. An ESP

proceeding includes the preparation of an EIS addressing the environmental impacts of reactor

construction and operation. The environmental issues resolved in that EIS are sufficient to take

the action on the ESP and, absent new and significant information, are deemed to be sufficient

to be considered resolved at the COL stage. The ESP proceeding, however, need not resolve

those matters that are not yet ripe for consideration. Insofar as the actual design selected may

contain new information or unexpected environmental changes may occur during the

intervening years, the NRC staff will determine whether the new information is significant.

The COL applicant must address any significant environmental issue not considered in any

previous proceeding, such as those issues deferred from the ESP stage to the COL stage

(e.g., the benefits assessment) and should address whether there is new and significant

information on an issue that was previously resolved. 

If a COL application referencing an ESP is submitted, the environmental topics resolved in an

ESP EIS will be reviewed if new and significant information exists. The NRC staff, in the context

of a COL application that references an ESP, defines the term “new” in the phrase “new and

significant” as any information that was both (1) not considered in preparing the ESP

environmental report 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 publically available during the preparation of the EIS (such as information in

reports, studies, and treatises). This new information may include specific design information

that was not contained in the application, especially where the design interacts with the

environment, or information that was in the ESP EIS, but has changed by the time of the COL

application.

In its ER for the North Anna ESP application, Dominion did not assess the benefits of the

construction and operation of new units at the North Anna ESP site, nor did it assess alternative

energy sources. Therefore, if the NRC grants the application and the ESP is referenced in a

COL application, the COL applicant must address the benefits of the requested COL and energy

alternatives in the COL ER. The NRC will then prepare a supplement to the ESP EIS to

evaluate these matters. 

References were made to NEI’s letter of February 10, 2005 (ML050530439); the NRC

responded to that letter on July 6, 2005 (ML051050031).

No changes were made to this EIS as a result of these comments.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-17 NUREG-1811, Volume II

Comment: [W]hat [are] the meanings of those categorizations small, moderate, et cetera that

we have seen through the presentation and also in published literature. (ST-0001 1)

Comment: In the revised environmental statement, impact is listed as "small" fairly often. It

seemed that "large" would be equally valid and would allow us all at least to look squarely at the

problems caused by what we do. Destruction of habitat is destruction of habitat. (SW-0014 1)

Response: As outlined in the Draft EIS and its supplement, to guide its assessment of

environmental impacts of a proposed action or alternative actions, the NRC has established a

standard of significance for impacts using the President’s Council on Environmental Quality

(CEQ) guidance (40 CFR 1508.27). Using this approach, the NRC has established three

significance or impact category levels – SMALL, MODERATE, or LARGE – which are defined

below:

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.

The technical analyses performed by the staff were focused on the resource and the

assessment of the impacts of the proposed action on the resource.

Comment: I think the NRC, if you are truly an honest broker, should assure that Dominion's

assumptions and calculations are, in fact, actual, correct, and realistic. ...We respectfully ask

that ALL CALCULATIONS/ASSUMPTIONS used in Dominion's Engineering proposals

(impacting lake water levels, temperatures, etc.) be thoroughly reviewed and independently

verified by a qualified and disinterested engineering firm BEFORE Dominion's proposal is

approved. (SE-0016 2)

Response: The NRC and its contractors independently evaluate the assumptions and

calculations made by the applicant for reasonableness. In certain cases, the staff conducts its

own analysis as was done, for example, with the water budget calculations in this EIS. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: It makes no sense to certify the suitability of a site before it is clear whether there

are viable and satisfactory solutions for issues such as storage of spent fuel and provision of
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-18 December 2006

water for cooling. That could lead to abuses of the staged process in which excessive

momentum is developed favoring final approval irrespective of whether there is strong evidence

that alternatives and solutions exist for issues left unresolved during the ESP process. 

(SE-0038 10)

Comment: [B]y creating a twenty year window for the action, the ESP process makes

conclusions about the Site and its environment, that are likely not to be true soon after the ESP

is approved...Please go back to the analysis process, do a thorough review, and issue a

complete Draft EIS. (SE-0049 6)

Comment: Another related issue is the approach in the DEIS of postponing several key

site-related issues to the COL process. We believe that violates the spirit, if not the letter of the

NRC’s staged process for approval of new reactors. It makes no sense to certify the suitability

of a site before it is clear whether there are viable and satisfactory solutions for issues such as

storage of spent fuel and provision of water for cooling. That could lead to abuses of the staged

process in which excessive momentum is developed favoring final approval irrespective of

whether there is strong evidence that alternatives and solutions exist for issues left unresolved

during the ESP process. The current ESP applications for North Anna and several other

reactors constitutes the first real test of how the NRC will implement the new staged process

and whether it intends to protect the public interest or subvert the process to avoid or obfuscate

important issues. (DW-0589 5)

Comment: Page 2-9 line 1, Sections 3.3, 4.1.2, 5.1.2, 5.8.4, etc., discuss transmission access,

a critical component of determining site suitability. The document asserts that no transmission

expansion would be required at any time any place within the region within twenty years after

receipt of the ESP and that the entire electrical output of two new nuclear generators can be

transmitted. I have three problems with the approach: (A) The conclusion is suspect – rules of

thumb (no details where given on the line configurations) indicate that the three lines would

have a combined capacity of about 1,750 MW so the lines would be above capacity with the

four nuclear units. (B) The methodology is flawed – the EIS says that the line capacity is

available and that the load flow study (to verify the assertion) would be done later!! That is not a

scientific approach suitable for a DEIS. If the load flow study is done later (or conditions on the

line change) and it is determined that additional lines are required, the DEIS conclusions about

the site would be voided. (C) The “bubble concept” requires that any new transmission lines be

analyzed in the DEIS. If Dominion stands by its assertion that no new transmission is required,

Dominion could stipulate that as a condition of the ESP. Otherwise, a detailed transmission

assessment and a study of the related impacts must be done now and incorporated into the

DEIS. This should include a 20-year load flow forecast. (DW-0438 18)

Comment: The NRC staff is assuming that “the existing transmission lines are adequate and

new transmission lines will not be needed” (page 5-2, line 1-11). This is yet another example in

the Draft EIS of putting off important analyses, in this case a load flow study, until the COL
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-19 NUREG-1811, Volume II

stage. Determining whether there is sufficient capacity on the existing transmission lines is

crucial for analyzing whether the land-use impacts to offsite areas will be significant – obviously

an important siting issue. (DW-0437 61)

Response: For an ESP, the NRC prepares an EIS that can resolve numerous issues based on

existing and projected environmental site characteristics, as well as bounding values of power

plant design parameters postulated in the application. These issues are subject to issue

preclusion in a proceeding on an application referencing the ESP (i.e., such an issue would not

be subject to litigation in the later licensing proceeding). NRC regulations allow an ESP

applicant to defer an issue (e.g., the benefits assessment) as Dominion has elected to do, but

also require that a COL applicant referencing such an ESP address the issue in its application. 

An application referencing an ESP must also demonstrate that the design of the facility falls

within the parameters specified in the ESP. In addition, the application should indicate whether

the site is in compliance with the terms of the ESP. If the ESP is granted, and an application to

construct a nuclear power reactor on the North Anna ESP site referencing that ESP is

submitted, the staff will prepare an EIS on that application. New information (e.g., the results of

a transmission line load study) would be reviewed by the staff to determine if it is significant. 

The Executive Summary and Chapter 2.0 of this volume include an explanation of the ESP

process and the interaction between the ESP EIS and the environmental review at the COL

stage if the requested ESP is granted and is referenced in a COL application.

The staff has evaluated water use for cooling in Chapter 5 and Appendix K of this EIS and

determined that the impact levels are SMALL during years with normal precipitation and

MODERATE during drought years.

In the Waste Confidence Rule 10 CFR 51.23, 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 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 such reactor and generated up to that time.

No changes were made to the EIS as a result of these comments.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-20 December 2006

4.1.1 Plant Parameter Envelope (PPE)

Comment: Here the site permit regulation [10 CFR 100.21] which Dominion must adhere to is

predicated on the type of nuclear power unit. But since “Dominion has not selected a particular

reactor design,” the power unit is as yet undetermined. In order to evaluate the radiological

dose consequences as stipulated in 10 CFR § 100.21(c)(2), the NRC must have the preliminary

safety analysis report (PSAR) which would be submitted with Dominion’s application for a

construction permit. (TR-0034 11)

Response: The NRC review of either an ESP application or a COL application has both safety

and environmental components. The 10 CFR 100.21 requirements apply to safety reviews, not

environmental reviews. The applicant provides safety analysis information that must be

contained in the ESP application as specified in 10 CFR 52.17, “Contents of applications.” 

From an environmental perspective, the staff evaluated the radiological dose consequences of

design basis accidents in Section 5.10.1, “Design-Basis Accidents,” of the EIS. Additional

information on the safety review of the radiological dose consequences of design basis

accidents can be found in Section 15.1, “Technical Information in the Application” of Chapter 15,

“Accident Analysis,” in Supplement 1 to the Safety Evaluation Report for Early Site Permit (ESP)

at the North Anna ESP site, issued in September 2006 (ML062160207). Accordingly, no

changes were made to this EIS as a result of this comment.

Comment: The fact that none of the reactors that Dominion is using to set its design

parameters have ever been built in the U.S. should be explicitly stated in the Final EIS. 

(DW-0437 63)

Response: The facts that the plant parameters may be drawn from a design certified by the

NRC or that no reactor with such parameter values has been built in the United States are not

disqualifying. The staff found that the values proposed for the consideration of analyses and

assessment of impacts were not unreasonable as required by Review Standard RS-002

(NRC 2004). Accordingly, no changes were made to this EIS as a result of this comment.

Comment: It would be helpful to provide comparisons for Plant Parameters to the existing two

units. (DW-0438 85) 

Response: There is no action related to the North Anna Power Station (NAPS) Units 1 and 2 in

this ESP application that would warrant the staff to compare Units 1 and 2 plant parameters to

the PPE to complete its environmental review. The proposed action does not involve the

consideration of construction or operational impacts of reactor units that are comparable to

NAPS Units 1 and 2. The environmental impact of the existing two units was evaluated as part 
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-21 NUREG-1811, Volume II

of a license renewal in November 2002. The impact of the two existing units is considered in

the staff’s evaluation of cumulative impacts in Chapter 7 of this EIS. Accordingly, no changes

were made to this EIS as a result of this comment.

Comment: Dominion utilizes and the NRC accepts a plant parameters envelope, or PPE, in

lieu of an actual reactor design to estimate safety impacts of the ESP... Dominion’s ESP

application posits a PPE which is filled with qualifiers and escape clauses. PPE date is not

site-specific, not from the ESP site, and bounds only 85% of existing sites. The application

states: “Site specific information is not listed on these tables. The data in this table is not to be

taken as final design specific information. In some cases, where designs are not mature, the

data supplied is based on engineering judgment, prior experience, or a calculation based on

non-site specific assumptions.” (emphasis added) [ESP Application Part 2-Site Safety Analysis

Report, Section 1.3.3, page 2-1-13, Sept. 2003] Dominion’s assertion that these data “can be

used until site-specific design data is available” is unsupported. The NRC cannot permit the

company’s educated guesses to substitute for the data requirements of federal law. (TR-0034 8

and DW-1163 8)

Response: The safety impacts are evaluated in the ESP safety evaluation report. The ESP

safety review was a site suitability review, not a design review. At the COL stage, the applicant

has the option of selecting a certified design, for which the design information has been

reviewed, or submitting a design that is not certified for the NRC to review. Under either option,

the design information required by the regulations has been or will be submitted and reviewed. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The consequence of these deficiencies [in the PPE approach] is that one cannot

verify the impacts of the new reactors. This is a failure of omission which prevents the NRC and

the general public from properly assessing the impact of new reactors at North Anna and

ascertaining the accuracy of Dominion’s analyses. (DT-0034 9) (DW-1163 9)

Comment: Since the ESP is an optional early stage process devised primarily for the

convenience of the applicant, and the environmental impacts of Dominion’s continually evolving

proposal are at this point still defined by a general “plant parameter envelope,” comprised of

nominal operating values rather than those pertaining to a site-specific detailed plant design, we

see no advantage, and significant disadvantages, to VDEQ offering its concurrence (or

conditional concurrence) at this time. (SE-0040 1)

Response: The PPE approach can be used as an acceptable surrogate for an actual reactor

design. The PPE values were used to evaluate the impacts, but will be compared to the design

selected at the CP/COL stage. If the design selected at the CP/COL stage is outside the

bounds of the PPE, then the significance of exceeding the bounds will be evaluated. The

advantages or disadvantages to VDEQ concurring on Dominion’s Coastal Zone Management
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-22 December 2006

Act certification are not relevant to the NRC’s EIS. Accordingly, no changes were made to this

EIS as a result of these comments.

Comment: The proxy plant approach that is used to define the Plant Parameters in Section 3

and elsewhere is hard to follow. Min, average, and max values for each key parameter should

be clearly identified. (DW-0438 81)

Response: The PPE values were used in the staff’s analyses to determine the environmental

impacts for the ESP action. Therefore, minimum, average and maximum values for each

parameter are not needed. The PPE values that were used in the staff’s analyses are included

in Appendix I. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Chapter 3, page 3-7, line 17 - Generally speaking, the design basis for the new

units will reject 1⁄2 as much heat to the environment as each of the existing units. Is there a

rationale for this, and for which designs does this apply? (DW-1272 5)

Response: The relevant text in Section 3.2.2.1 states, “During low water conditions, the

existing NAPS Units 1 and 2 are allowed to operate until the lake level elevation reaches a

minimum level of 73.8 m (242 ft) above MSL.” However the preceding paragraph states in part: 

“Dominion states that the heat rejection rate to the environment for each unit is bounded by

2800 MW (9.7 x 109

 BTU/hr). Unit 3 would withdraw water from Lake Anna and discharge the

heated effluent to the discharge canal, which is the same as for the existing NAPS Units 1

and 2, except for the difference in flow rates.”

The sentence stating that the discharge canal “... is the same as for the existing NAPS Units 1

and 2,” referred to withdrawing water from Lake Anna and discharging the heated effluent to the

discharge canal, and was not meant to imply that proposed Unit 3 would discharge the same

amount of heat as the combined heat output of Units 1 and 2. The text in the EIS was changed

to clarify this point.

Comment: Chapter 3, page 3-9, line 22 [Chapter 3, page 3-14 , Line 20 in SDEIS] - If adequate

design information is only available to accurately estimate liquid and gaseous effluents for 3

reactors, then this DEIS should only apply to those reactors. The usefulness of the information

included in this DEIS is limited to those plants used as a design basis for the PPE. Otherwise,

problems will arise when a PPE has been established, but a new design must [be]

“shoe-horned” into the parameters established by the PPE (which were based on other reactor

designs). (DW-1272 7 and SE-0030 21)

Comment: Chapter 6, page 6-20, line 6 - Note the admission that the impacts of gas-cooled

reactors would need to be assessed at the CP or COL stage, when more data is available on

the design. (DW-1272 11 and SE-0030 23)
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December 2006 4-23 NUREG-1811, Volume II

Comment: The document is too broad in its consideration of potential plant designs. The

document intends to allow for the citing of 7 potential designs for nuclear units. While adequate

design information exists for a few of the designs, by the admission of the NRC (see Chapter 3,

page 3-4, lines 31 and 32, lines 39 and 40, lines 40 and 41) there is inadequate design

information available for some of the proposed units from which to make accurate environmental assessments of the impacts. The document should limit its scope to those nuclear plant

designs for which reasonable data existed for assessing environmental impacts. If the NRC

continues to consider those reactor units as viable it should develop a supplemental EIS or an

additional EIS when environmental information becomes available. Based on a review of the

DEIS, the document should be limited to the following units: ACR-700, Advanced Boiling Water

Reactor, Advanced Pressurized Water Reactor (Surrogate API000), and the Economic

Simplified Boiling Water Reactor. (DW-1272 1 and SE-0030 15)

Comment: Chapter 6, page 6-22, line 21 - Note that the document states that there exists

significant uncertainty in the final design of any gas-cooled reactors. Thus, the DEIS [and

SDEIS] should be limited to exclude the design of these reactors until specifics on the design

are known. Same comment for page 6-38, line 25. (DW-1272 12 and SE-0030 24)

Response: The ER and Dominion’s responses to requests for additional information provided

some information unique to other-than-light-water reactors. However, because of the

uncertainty in the final design of the other-than-light-water reactors and the change in technology that could be applied to the uranium fuel cycle activities, if an other-than-light-water reactor

is chosen, additional reviews would be needed at the CP or COL stage in the following areas: 

fuel fabrication, enrichment, and solid low-level waste operation during decontamination and

decommissioning. If an applicant for a COL selected a type of reactor other than a light-water

reactor or one whose characteristics are not bounded by PPE values, then the applicant would

have to submit any related new and significant information in its COL application, and the NRC

would evaluate the impacts in the COL EIS. Because staff preparing an EIS at the CP/COL

stage would evaluate the impacts of the new information of designs other than the surrogate

ESBWR, AP1000, and the ABWR and determine whether the information is significant, there

would not be any “shoe-horning” of designs to fit within the staff’s evaluation contained in the

ESP EIS. The language in Section 5.10.3 was clarified in response to these comments.

Comment: Chapter 1, page 1-2, line 13 - The document states that a detailed design of the

reactor or reactors is not needed at this time. However, there should be enough design

information or data available on any reactor design to accurately bound the environmental

impact. For several of the desired plant designs, this information is either not available or not

provided as part of the DEIS in order to substantiate Plant Parameter Envelope information. 

(DW-1272 2 and SE-0030 16)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-24 December 2006

Comment: Chapter 3, page 3-3, paragraph - The approach to develop a plant parameter

envelope, while valid, is much more useful for developing a generic environmental impact

statement. The approach proves less useful when referring to a specific action at a site. This

approach is less credible when used to encompass reactor designs for which no accurate

design parameters exist (the gas cooled reactors; and the IRIS next generation pressurized

water reactors). (DW-1272 3 and SE-0030 17)

Response: Plant parameters cannot be unreasonable estimates and, therefore, may not bound

all circumstances. However, they are expected to bound a reasonable range of values from a

variety of reactor designs. The ESP does not allow the construction (other than certain site

preparation and preliminary construction activities) or operation of reactor(s). The ESP can be

referenced in a COL application requesting authority to construct and operate reactor(s). The

NRC does not subscribe to an approach that would lead to a generic EIS for a reactor design

for an unnamed location. 

For North Anna, the NRC will prepare an EIS at the COL stage. The EIS at the COL stage will

tier off the EIS prepared for the ESP. The staff will evaluate new design information to

determine whether it is significant. If the new design information is not significant, the

conclusion reached in the ESP EIS will not be revisited. If the new design information is

significant, the staff will evaluate the new and significant information to determine its impact. 

The staff expects there to be less potential for new and significant information about light-water

reactors than about gas-cooled or other advanced reactor designs. The interaction between the

environmental review performed for the ESP EIS and the environmental review that will be

performed for a COL application referencing an ESP is explained in more detail in Section 2.1 of

this volume.

Comment: What is the rationale for not using the same plant values in the DEIS and the safety

review (page 3-3, line 18)? It seems like bad science. (DW-0438 82)

Response: The safety review and the environmental review have distinct regulatory objectives. 

For some analyses that address similar issues, the analyses differ. For example, in the evaluation of dose assessment, the safety review uses “worst case” 95th percentile atmospheric

dispersion factors while the environmental review uses realistic case 50th percentile values. The

rationale for not using the same values in the safety and environmental review is that in environmental reviews, the staff presents a realistic evaluation of impacts, and in safety reviews, the

staff uses conservative assumptions to protect public health and safety. Realistic values are

used in environmental reviews to provide a consistent standard for weighing alternatives and

evaluating appropriate mitigation measures. Accordingly, no changes were made to this EIS as

a result of this comment.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-25 NUREG-1811, Volume II

Comment: I’m very concerned about this entire process. It’s a new process the government

has initiated. It’s a streamlined process. These two reactors that Dominion is applying to build

are the first to be applied for under this process, and I believe this is an abrogation of the

democratic system. (DT-0007 1)

Comment: [T]he need for a “Site Redress Plan” (Section 4.11), which addresses the activities

required to return the North Anna site to its present state if infrastructure construction activities

are truncated and the breadth of the facilities that can be constructed under the ESP (listed on

page 4-46 of the DEIS) is an indication of the bizarre and arbitrary division between the ESP

and the COL processes. Clearly, the specific site and the specific reactor are one in the same

project, and the division into the ESP and COL licensing process is completely arbitrary. 

(DW-0437 2) 

Response: The licensing process in 10 CFR Part 52 was developed through a rulemaking that

was completed in 1989. The rulemaking process invites public comment and participation. 

Accordingly, no change was made to this EIS as a result of these comments.

4.1.2 Public Participation

Comment: The powers to be had said that they have put the information out there for all to see

and participate in. Not so. My community ... lies approximately 15 miles from the current power

plant. None of the people living in this area have been approached or asked or given any

information about the current application for and ESP at north Anna. I do not want this

neighborhood left out because there are lots of minorities that live here. The Jackson district

pays taxes in this county. They should be allowed the facts on the impact of this proposed

nuclear reactor building. (DW-0626 1)

Response: The NRC publicizes every one of its public meetings through official means and is

receptive to public participation. The NRC took additional measures to ensure that all of the

local communities had the opportunity to become aware of the public meetings to discuss the

North Anna ESP application. For the environmental review, the first meeting was a scoping

meeting in December 2003, the second was in February 2005 on the Draft EIS, and the third

was in August 2006 on the SDEIS. In addition to the notice at the NRC website, in the Federal

Register and the issuance of press releases, these meetings were widely advertised in

newspapers throughout the region of interest (The Richmond Times-Dispatch, The Daily

Progress, The Free Lance Star, and The Central Virginian), through flyers posted in Louisa and

Orange Counties and through announcements on radio stations in the area. Known public

interest groups were also alerted to the meetings by the meeting facilitators. The Draft EIS and

SDEIS were available for public review at the Louisa Public Library and on the NRC website,

and copies of the Draft EIS and SDEIS were made available to anyone who requested them. 

The scoping meeting and the meeting on the Draft EIS and SDEIS occurred during specified

comment periods so that interested members of the public could attend and share their insights;
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-26 December 2006

even if a person could not attend either of these meetings, the official comment period remained

opened for a period thereafter to afford the public the opportunity to share information with the

NRC. Information regarding the NRC environmental review, as demonstrated by the above, has

been widely available to the public. Accordingly, no changes were made to this EIS as a result

of this comment.

Comment: If there are so many people that still want to speak, can I suggest that perhaps you

set up a second, third, and maybe a fourth public hearing in areas that are in Central Virginia so

that people may make comments and this session could continue? Because I think that this is

not only important for Central Virginia, but I think it’s important for Virginia...I think we should

have hearings in Charlottesville. I think you should have them in Richmond. I think you should

have them in Fredericksburg. (DT-0030 1)

Comment: And if the only say that citizens of this county have about the radioactive waste

being created here and stored in our community is three minutes to speak at one hearing or two

hearings where no decisions are made and some questions aren’t going to get answered, then I

think we need a new process. (DT-0037 4)

Comment: Please change this process so that everyone can be heard from. (DT-0037 9)

Comment: For a project of this magnitude it seems that one public hearing in one location is

insufficient to provide the public an opportunity to get educated and provide comments. I know

that I personally was unable to attend the revised hearing date due to work requirements. 

I again restate my request for another public hearing on the DEIS. (DW-0438 175)

Comment: The public hearing, delayed by snow and rescheduled, needs to be repeated. The

hearing on February 17th did not afford time for all who wished to present testimony and

conditions were very bad for all constituents. The format was not well controlled and executed. 

Please hold another public hearing in a better venue. (DW-0454 2)

Comment: I attended the public meeting the night of February 18, and stayed until 11:45 pm. 

I was very disappointed that even though I had registered to speak over a month ago, I did not

get the opportunity to do so, even though speakers who live much farther away were afforded

this opportunity, often with comments that were not relevant to the EIS. It wasn’t until after the

meeting that I found out that I had to “sign-in” again the night of the meeting to speak. 

(DW-0820 1)

Comment: There are two comments I have for future sessions of this nature. One would be to

address the issue of repetitive comments. I would recommend that in the future to make an

announcement beforehand that if, when a member of the public’s name has been selected to

comment, that if their views have already been expressed, then they should briefly indicate what

those were and to provide a full written comment after the meeting, or at a later date. This
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-27 NUREG-1811, Volume II

would provide more time for a greater number of issues and would have been particularly

beneficial at this meeting where probably 90% of the comments didn’t actually pertain to issues

raised in the Draft EIS, but instead boiled down to a debate for or against nuclear power in

principle. I am sorry that you did not have more constructive comments pertaining to the

subject at hand. (DW-1148 2)

Comment: I’d like to refer back to what you’ve mentioned, the safety evaluation review. The

opportunity for public comment on the safety evaluation review is February 23rd, I believe, and

then March 2nd and 3rd. Now, in order for the public to make comments on this critical aspect of

the application Dominion is putting forth, one would have to leave one’s job and go up to

Washington, D.C., and that’s exactly what I intend to do, and I’m, frankly, very resentful of

having to do that, and I think it’s very indicative of this whole process. Once a year we get a

time to talk among the community about this important issue, and I don’t think it’s enough. 

(DT-0007 2)

Comment: I do believe that this process is a farce. The NRC has streamlined it for the

purpose of limiting public participation. That’s why hearings about a new reactor in Mineral,

Virginia, are more likely to occur in Rockville, Maryland. That’s why important issues like

nuclear waste and terrorism are left out of the discussion. (DT-0036 1)

Comment: I am gratified of the number of people who have taken the time to go through the

ESP and make relevant comments, comments I think that the NRC needs to go back and

review and understand, and I believe come to a proper answer to [the ESP application]. 

(DT-0049 1)

Comment: I am thankful for the opportunity to participate in this democratic process. 

(DT-0045 1)

Comment: My second comment pertains to the filtering I perceived by the moderator in

selecting who would get to speak at the meeting. If that filtering was in search of other

affiliations so that a diversity of opinions could be expressed at the meeting, I understand and

accept that. However, I also did feel that certain members of the public were given a special

consideration to speak over others, even though they did not state anything that wasn’t

previously presented. This to me seemed unfair and disrespectful. What right do these people

have over others in the audience to speak? Please address this issue in future meetings. 

(DW-1148 3)

Comment: For the record, I would like to add that the NRC’s moderator at the February 17th

public hearing in Mineral did an excellent job. Throughout the meeting, Mr. Cameron was

courteous, respectful, and professional. (DW-1163 19)
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NUREG-1811, Volume II 4-28 December 2006

Comment: I was told time and time again at the EIS public meeting that this issue was very

complicated and that I would not understand all of the issues. I think that this is a very

dangerous attitude. (DT-0061 1)

Comment: If public meetings are being conducted, there should be no done deals, there

should be room at any point in this process to change, to acknowledge that we have made an

error based on the idea that actually we need to be stewards at our environment, not just the

environment. (DT-0051 1)

Comment: I may not be an expert, but I know not to trust the “experts” when they say “trust

us.” (DT-0061 5)

Response: NRC staff activities to fulfill its NEPA responsibilities are governed by the NRC’s

rules and regulations (see 10 CFR Part 51) and its body of regulatory guidance. Development

of the framework and conduct of regulatory activities are performed in open and transparent

forums.

Apart from the requirements to establish a scoping process to seek input and the issuance of

the Draft EIS for public comment, the NRC elected to conduct a public meeting during each of

these phases. These meetings did not short-circuit the formal scoping period or the comment

period. These meetings were scheduled at intermediate points within the scoping and comment

periods so that members of the public could obtain additional background information and

provide their insights. The NRC transcribed the meetings to provide convenient platforms to

accept comments from members of the public who were prepared to make comments during the

meetings. If the public had the interest to provide additional comments after the meetings, then

they were provided with the specific information necessary to communicate with the NRC on

this project.

More than 300 people took advantage of the NRC’s public meeting opportunity on the Draft EIS

held on February 17, 2005. The public meeting was scheduled from 7:00 to 10:00 p.m. with an

informal “open house” from 6:00 to 7:00 p.m. The “open house” period began shortly after

5:00 p.m. because the public arrived early, and the formal meeting did not end until nearly

midnight to afford the opportunity for as many people to share their views as possible. About

300 people attended the public meeting on the SDEIS held on August 15, 2006. The public

meeting and “open house” were widely attended.

Rather than conducting a public comment period for the 45 days required by NRC regulations,

the NRC staff included the equivalent of two 15-day extensions on the Draft EIS and granted a

15-day extension on the SDEIS. This was to afford the public as much time as practicable to

contribute in a meaningful manner.
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December 2006 4-29 NUREG-1811, Volume II

During the public meeting on the Draft EIS, the NRC facilitator accommodated as many

presenters as possible and anyone who attended the public meeting and wanted to offer

comments on the SDEIS. The NRC did not constrain the content of comments offered, whether

or not they were within the scope of the environmental review; the content was within the

prerogative of the presenter. The facilitator does assume that the proponent of the application

(Dominion) and governmental officials can present their comments first, but thereafter, the

facilitator has the discretion to schedule the presenters. The goal of the facilitator was to allow

as many people as possible to express their views without any bias as to the speakers’

viewpoints.

For ESP matters outside of the environmental review, the NRC has opportunities for public

observation and participation. Public meetings may be conducted in the site vicinity or in other

locations, including NRC headquarters in Rockville, Maryland. Interested members of the public

can obtain the schedule for NRC public meeting times and locations from the NRC website: 

www.nrc.gov. Accordingly, no changes were made to this EIS as a result of these comments.

Comment: [Comment on Dominion's ESP application rather than the SDEIS] [There are] too

many supplemental confusing documents, using inconsistent terminology to insure that all items

have been reviewed to protect the public’s interest. There are also many supplemental

Requests for Information and Responses from Dominion with in some cases unclear responses.

The NRC is planning to issue a supplemental draft environmental and supplemental draft safety

report. How is the public going to keep track of all these changes? ...It is recommended that

both the state and federal agencies have one only joint hearing and invite all associated federal

and state departments that may play a role in this major project, so the public is not confused on

whom to report what issues to and expect a reasonable response. (SE-0003 12)

Comment: [Comment re letter from Dominion in response to NRC questions dated

April 13, 2005 (i.e., Dominions Application Revision 6)] Will there be a joint Coastal

Management and NRC public hearing on this major revision to the ESP Application by Dominion

for the North Anna Units 3 and 4 including DEQ, Fish and Game, Health Department, and

surrounding counties? (SE-0004 1)

Comment: The current public comment period should be extended to permit the public to have

adequate time to review and comment on Revision 7 and Revision 8 which were just issued

after the supplemental draft environmental impact statement was issued in July just a few

weeks ago. (ST-0014 24 and SE-0022 37)

Comment: We appreciated the opportunity to participate in the August 15 hearing. However

VA DEQ held a hearing on the project on the following day. This presents a time burden on

affected individuals to participate in both processes. Would it be possible to hold a combined
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-30 December 2006

public hearing that addresses all jurisdictional issues in the future? This would facilitate public

participation (which is one of the goals of the NEPA process) rather than be divisive. 

(SE-0045 9)

Comment: [Y]ou issued the supplemental draft environmental impact statement on the 7th of

July. Isn't it unusual to have a public hearing so quickly after the issuance of a supplemental

draft environmental impact statement? Shouldn't there be more of a period of time for the

public? In addition, it is August and a lot of people are on vacation. (ST-0002 1)

Comment: The NRC has either deliberately devised or negligently allowed the ESP process to

evolve in a way that overtaxes and bamboozles the public and even state regulators with a

continuing and chaotic blizzard of ever-changing project documentation. ...We would hazard a

guess that the logistical, analytical, and sheer time demands of keeping up with the NRC’s

chaotic permit review process have deterred many citizens from participating in it at all, and

discouraged others as soon as they became aware of its daunting demands and perverse

complexity. The process effectively excludes anyone from meaningful participation who does

not have the patience, time, and particular skill set to wade through the documentary swamp the

NRC has generated. (SE-0040 13)

Comment: The NRC should evaluate all of the applicant’s documents and ensure that they are

complete before completing its analysis of the issues and issuing the documents to the public or

the commonwealth for review. Once the NRC and the applicant have finalized the requested

ESP application, then and only then should the documents be issued for public and

commonwealth review. (SE-0022 7)

Comment: The NRC continues to accept many changes to the ESP, without automatically

extending the public comment period each time a change is issued. ...While the Draft

Environmental Impact Statement (DEIS) is still under review, Dominion continues to make

revisions to issues that are analyzed. Hence our review of the DEIS is a moving target, without

the NRC automatically extending the public comment period and giving the public sufficient time

to review the changes (SE-0022 6)

Comment: And the NRC continues to accept many changes to the ESP without automatically

extending the public comment period time with these changes and issues. Recently, we've

reviewed just thousands of pages and within the last few weeks, a revision seven and eight

were issued and the public comment period has not been extended for that there. The current

ESP resembles a three ring circus without having the ring master to direct all of the acts, but the

timekeeper is making sure that the public audience moves out of the big top so the next

scheduled performance can begin. (ST-0014 3b)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-31 NUREG-1811, Volume II

Comment: Has the NRC’s shoddy ESP process violated citizen’s due process rights under the

Administrative Procedures Act, the National Environmental Policy Act, and NEPA’s

implementing regulations? (SE-0040 15)

Comment: The public should be involved in both the Safety Evaluation Report, as well as the

Environmental Impact Statement. The NRC does not provide for any public scrutiny of a draft

Safety Evaluation Report prior to its issuance. The public’s safety should be the primary focus

of any government agency. The public’s review of any safety projects is essential. (SE-0022 3)

Response: Because the application is electronically filed, the entire application is assigned a

new revision number even if only a few pages are changed. Dominion’s ESP application is an

electronic filing; as such, every revision or amendment reflects the most updated version of the

application. The NRC develops two documents to record the results of its reviews, an EIS and

a SER. The EIS is to fulfill the NRC’s responsibilities under NEPA. The SER is to fulfill the

NRC’s responsibilities under the Atomic Energy Act. These documents have different purposes

and different review standards. Similarly, NEPA, the CZMA, and other environmental statutes

have differing purposes and procedural requirements. At times, particularly in this case where

the applicant elected to make a substantial change to the proposed action, the NRC may have

to issue a supplement to its document; consistent with its regulations at 10 CFR 51.72, the NRC

invited the public to comment on its supplement to the Draft EIS before it was finalized. The

NRC supplemented its safety evaluation report as well. The public comment period on a draft

EIS is a minimum of 45 days from the date that the EPA publishes the Federal Register notice

that the EIS was filed; the draft EIS cannot be filed with EPA until it has been distributed to

known interested parties. An applicant may make subsequent revisions or amendments to the

application. Insubstantial changes may be made to an application without a supplemental EIS

being issued, therefore having little or no effect on the review schedule. If the staff determines

that the revision is a substantial change, then the NRC could issue a supplemental EIS, as it did

in the change to the cooling system. 

In addition to the Federal review and consultations, the Commonwealth of Virginia also has

statutes and regulations that relate to the ESP application and that have to be met. For

example, the Commonwealth must either object to or concur with a certification that a proposed

action is consistent with the Commonwealth’s plan under the Coastal Zone Management Act

(CZMA). The public is an important stakeholder in all of these processes; individuals have the

opportunity to determine whether they have an interest to participate in these different

regulatory processes. Staff of the NRC and the Commonwealth have been responsive to

stakeholder concerns in each of the different regulatory forums, but the goals and objectives of

each do not uniformly overlap and should not be conducted jointly; furthermore, public meetings

and public hearings have different legal effects. Specifically, the NRC conducts “hearings” to

compile a record for the agency to use in making a decision on the application, and which may

ultimately be reviewed by a court. In contrast, a “public meeting” is a means to obtain

information from members of the public to assist the NRC in addressing public concerns,
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-32 December 2006

improve the quality of the review documents informed by those concerns, and satisfy legal

requirements (such as in NEPA) for obtaining public input. To the degree that the NRC and

other organizations can cooperate to avoid duplication, the NRC has established Memoranda of

Understanding or used NEPA principles to work cooperatively. Accordingly, no changes were

made to this EIS as a result of these comments.

Comment: [P]art of the NRC's mission is to protect our interest. It's also to allow us to educate

ourselves by gaining information. I advocate for more hearings around the state. (ST-0002 8)

Comment: We are very disappointed at Dominion’s apparent approach in trying to influence

the NRC and VDEQ public hearings held on 15 and 16 August. ...over 50% of the public

speakers at both hearings were Dominion employees, retirees or contractors, all of which had

only positive comments about the proposed 3rd and 4th reactors. ...The meeting room in the

Louisa Middle School held about 300 persons, of which about 150 plus were Dominion

employees/retirees/contractors. ...With this type of an apparent attempt by Dominion to

influence both the NRC and VDEQ public hearings, how can the National Environmental Goals

which are expressed by the National Environmental Policy Act (NEPA) of 1969 public law

91-190, 83 Stat. 852 receive a fair and impartial public hearing . ...How can the NRC and VDEQ

prevent this from happening in future public hearings? (SE-0033 1)

Comment: For a project of this magnitude it seems that one public hearing in one location is

insufficient to provide the public a real opportunity to get educated and provide comments. 

Limiting the public hearings to evening hours excludes the participation of those who work

evenings. Limiting the public hearings to the Louisa location makes it difficult for those who live

in other localities within the affected area to attend. (SE-0045 48)

Comment: A more thorough EIS would have multiple public hearings at different times. 

(ST-0036 11)

Response: The NRC has established numerous means for the public to become aware of

actions pending before the agency so that the public can determine whether it has the interest

to participate. Apart from the required notices published in the Federal Register, the NRC

maintains a website that lists every public meeting and information on various licensing

programs, such as for new reactors, with the detailed licensing schedule and information

sources on the application, specifically, and brochures and information in general. The NRC

believes that an informed public can determine whether it wants to participate in the licensing

process and have an appreciation for the schedule that will be followed to determine how to

plan for participation.

For the environmental review, the NRC undertakes the additional effort to provide platforms

during the NEPA scoping process and on the draft EIS for the public to engage with the staff in

meetings close to the site. The public comment period on a draft EIS is a minimum of 45 days
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-33 NUREG-1811, Volume II

from the date that the EPA publishes the Federal Register notice that the EIS was filed; the draft

EIS cannot be filed with EPA until it has been distributed to known interested parties. The NRC

may elect to hold one or more public meetings during the public comment period. These

meetings are not required, but the NRC believes that they are important opportunities for

members of the public to participate, if they elect to do so, with the staff in a meaningful manner

either to obtain information to formulate their comments or to share information and views on

the proposal before the agency or the staff review. The earlier in the public comment period

that the NRC holds the public meeting, if it elects to hold one, the greater the likelihood that

interested parties will obtain the information that they need to develop comments and insights

that will inform the work of the NRC. Public meetings are not hearings and the licensing action

is not subject to a referendum. Hearings have particular meaning for the NRC and are held

before an adjudicatory body, the NRC’s Atomic Safety and Licensing Board (ASLB), on certain

types of licensing actions, such as an ESP. The ASLB also has the discretion to provide the

public the opportunity for limited appearances. 

Interested parties have taken these opportunities to share their views on the issues. If they

cannot attend the public meeting, that does not foreclose their opportunity to participate; in the

case of formal public comment periods, they can submit material to the NRC even after the

public meetings have been held and it will have the same standing as if presented at a public

meeting where a transcript was taken. If a member of the public elects to share her or his view

that he or she is in favor of the action or against the action, but does not provide detailed

information on an environmental issue considered in the EIS, that is her or his prerogative, but it

cannot inform the staff’s review and it will not affect the analysis or conclusion. If a public

interest group, an industry interest group, or an applicant encourages public participation in the

process and, as a result, members of the public engage in the process, then it serves the goals

of NEPA. If no one elects to engage in the process, then the NRC can finalize its EIS without

modification even if analyses prove to be incorrect; such a situation does not serve the goals of

NEPA. The general public needs to understand that at an NRC environmental public meeting,

the applicant’s proponents, indeed the applicant, is just another member of the public in the

eyes of the NRC. Accordingly, no changes were made to this EIS as a result of these

comments.

Comment: I do support the process that you're going through and in a profession I've focused,

my career is process management, so it's nice to see it in action and that I can be a part of it. 

(ST-0019 1)

Comment: I also support the ESP process as the means to warrant an open and thorough

evaluation of future nuclear projects, involving all the stakeholders and ensuring the timeliness

and predictability of the process. I really think that this process works and this is why we are all

here today. We all have the opportunity to voice our concerns with Dominion's plans and

thorough discuss them. Dominion was very proactive to revise the proposal to address the
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-34 December 2006

concerns that were raised in this meeting and are coming for additional meetings and this is

also the reason why we are here today again. (ST-0013 4)

Comment: The NRC staff has performed a rigorous review of the potential environmental

impacts associated with the operation of additional reactors at the North Anna site. 

(SW-0013 4)

Comment: It seems that the SDEIS, like the DEIS, was not performed by an unbiased

interdisciplinary team as is required by NEPA. ...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 have

commissioned independent sources to develop the required data. It is imprudent to conclude a

recommendation to approve an ESP where major issues “are not resolved”. (SE-0045 10)

Comment: I respectfully ask that your commissions require A Full Technical Analysis and

Certification of Dominion’s Engineering Studies, Assumptions, Estimates and Mathematical

Calculations By Competent Disinterested and Independent Engineering Firms Before the ESP is

Approved [quoted from SE-0016 1]. We do not believe that an impartial, qualified “honest

broker” has technically analyzed in depth or substantiated Dominion’s impact assertions. ...Over

time, as the EIS process has forced Dominion to confront the concerns of other Counties and

State Agencies, its rhetoric has grown more diplomatic, its manner polite, its demeanor sincere

and the potentially disastrous impacts have all but faded away in their presentations. 

(SE-0020 1)

Comment: The NRC staff has performed a rigorous review of the potential environmental

impacts associated with operation of additional reactors at the North Anna site. I commend the

agency staff for its meticulous review of Dominion's ESP application and support its conclusions

contained in the supplemental draft environmental impact statement. (SW-0002 4)

Comment: The NRC scientists should be embarrassed. They also approved this plan the first

time. All of this information was out about the water temperature on the warm side of the lake. 

It was there, and they said...they liked it. (ST-0024 5)

Comment: [W]hat we're talking about here is a federal action that has potentially serious

regional consequences that have not yet been properly analyzed and documented. I hope that

the NRC takes corrective action sooner rather than later, and gives the public additional

information. (ST-0036 13)

Comment: [I]t is confusing for the reader whether the SDEIS is addressing just the cooling

changes or the entire project. Without a clear understanding the reader cannot form an

educated opinion about the project impacts...[Because of this] a new DEIS could be issued that
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-35 NUREG-1811, Volume II

provides a comprehensive analysis including addressing many of the shortcomings of the

original DEIS. (SE-0045 8)

Comment: It's unclear to me whether the supplement is strictly about the cooling system

change, or the whole project. A more thorough draft document would show what the changes

are in each section. (ST-0036 8)

Comment: I believe that the SDEIS is substantially flawed and request that these comments

and others be fully addressed and that another DRAFT EIS be released. Unless such an action

is taken, concerned citizens and local governments...cannot make informed decisions about the

proposed project. The flaws in the SDEIS and DEIS do not provide the scientific, legal, or

policy background to support a finding to recommend the ESP. (SE-0045 49)

Comment: I also support the ESP process as the means to guarantee an open and thorough

evaluation of future nuclear projects, involving all the stakeholders, while ensuring the

timeliness and predictability of the process. (SE-0025 5)

Comment: We support the ESP process as a means to facilitate an open and thorough

evaluation of future nuclear projects, while ensuring the timeliness and predictability of the

process. (SW-0009 3)

Comment: [W]e support the ESP process as for the means to guarantee an open and

thorough evaluation of future nuclear projects, while ensuring the timeliness and predictability of

the process. Tonight's public meeting demonstrates the benefits of the new process. That is

that safety, environmental and licensing issues are resolved before large capital investments

are made. ...When Virginia DEQ nearby residents raised concerns about the impact on lake

temperature that a third unit would have, as a result of this public process, Dominion modified

its proposed design to include a cooling tower for a third unit to address the concerns, exactly

what the process was intended. (ST-0012 2)

Response: The ESP licensing process was established in 10 CFR Part 52 and was

promulgated in 1989 (see 54 FR 15386). In 2000, the NRC staff finalized the environmental

procedures to guide its environmental review, published as the Standard Review Plans for

Environmental Reviews for Nuclear Power Plants (ESRP), NUREG-1555 (NRC 2000). The

ESRP and Part 52 were issued for public comment to ensure that all interested parties had the

opportunity to provide insights on the NRC’s approach to comply with its NEPA review

responsibilities before the NRC conducts its reviews and develops its EISs. The NRC’s Draft

and Final EISs are developed using these environmental review procedures and an

interdisciplinary team of environmental specialists comprised of NRC staff and its contractors. 

The ESP application includes the applicant’s representation of environmental impacts and it
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-36 December 2006

serves as a starting point for the staff’s independent assessment; in the end, the NRC is

responsible for the reliability of all information it uses in its EIS, even if information or analyses

were provided by the applicant.

In the situation where an EIS is supplemented before it is finalized, the supplemental EIS is to

focus on the issues that changed from the original proposal and the effects of such changes on

the various sections of the Draft EIS. This is clearly articulated in the NRC’s Notice of

Availability published in the Federal Register regarding the availability of the supplement as well

as in the introductory matter of the supplement, which was intended to guide the public’s

attention in developing their comments. In fact, sections that were unaffected by the applicant’s

change in the proposal were so identified. The fact that an acceptable approach or design is

modified can be the result of any of numerous technical or policy decisions. The NRC’s

approach for inviting the public to participate in the environmental review is entirely consistent

with NEPA principles; however, the NRC provides for additional opportunities for public

participation on most actions that require an EIS to ensure that all interested stakeholders can

participate effectively.

An ESP is valid for up to 20 years and can be renewed. By itself, an ESP does not result in the

construction and operation of a nuclear power plant. If an ESP is referenced in a COL

application, then the COL applicant must demonstrate that the facility proposed at the COL

stage falls within the parameters contained in the ESP. If new and significant information is

revealed in the subsequent licensing action, then the issue in question will be revisited at the

time of the COL. An issue that was not resolved in the ESP proceeding because, for example, it

could be deferred in accordance with NRC rules or insufficient information was available at the

time the ESP application was considered, must be resolved in the COL proceeding. Examples

of issues that can be deferred include the benefits assessment/need for power assessment can

be deferred until the COL under 10 CFR 52.18 and the Commission has determined that the

alternative energy analysis.

4.2 NEPA Compliance

Comment: The Commission can and, we contend, should require Dominion to submit

information in accord with NEPA to allow an independent and fully informed evaluation as

required by NEPA, including the no-build option. (DT-0034 18)

Comment: The Purpose and Need of the Draft EIS does not include an assessment of the

energy needs for the addition of two nuclear power units at the North Anna facility, nor does it

assess other energy alternatives. The focus of the Purpose and Need was restricted to

simpl[ify] the suitability of citing two nuclear power units at the facility. It is EPA’s understanding

of the NRC’s two-step streamlining permiiting process would require an energy needs analysis

which would include energy alternatives assessment in a second EIS in accordance with
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-37 NUREG-1811, Volume II

10 CFR Part 50. EPA has concerns with this approach since it ignores the justification for the

power plant addition in the early stage of project development as well as biases the subsequent

energy alternative analysis toward nuclear power under the second EIS since the NRC would

have approved the suitability under the ESP. (DW-0422 1)

Comment: The Dominion Environmental Report (ER) is referenced extensively ... Many of the

Draft EIS conclusions are based on this document. Further the Dominion ER is not part of the

Draft EIS nor was it submitted to EPA as part of the Draft EIS submittal. EPA believes that a

review of the ER is an important element of the evaluation of the Draft EIS and should [be]

included as an attachment. (DW-0422 2)

Comment: The science behind many sections of the DEIS seems fuzzy. The conclusion of

SMALL impacts doesn’t logically flow from the discussion and often is unsubstantiated. The

policy analysis specifically with regard to regional socio-economic measures is very weak. 

I request that the DEIS be prepared in accordance with the intent of NEPA and re-issued. 

(DW-0432 1)

Comment: Page 1-3 states that the ER does not need to include discussion of energy

alternatives. A NEPA-compliant EIS, on the other hand, does need to. (DW-0438 6)

Comment: Page 1-3 states that the EIS does not include an assessment of the benefits of the

proposed action. It is thus not a NEPA-compliant EIS. (DW-0438 7)

Comment: There appear to be three major flaws with the process and the project and we are

hopeful that the NRC will go back and do the appropriate research and reporting, perhaps via a

revised Draft EIS that meets the intent of the National Environmental Policy Act. It appears that

information about this proposed action is incomplete at this point in time and that the public has

not been provided with important information that they would need if they were to be able to

make relevant comments. This would be the same information that the agency would use to

make an informed decision. ...I urge you to produce as complete a record as you can and

suggest that only then do we have a legitimate process to receive public input on this proposal. 

We thus request that the NRC issue a supplemental DEIS and defer the decision making

process until the record is complete. (DW-0594 1)

Comment: The EIS is not a true NEPA document – it does not include mitigation steps and

clear discussion of irreversible and irretrievable impacts. (DW-0594 13)

Comment: Dominion’s Environmental Report does not contain a sufficient discussion of the

purpose and need for the proposed action, the environmental impacts, or the relative costs and

benefits of alternatives. (DT-0034 16 and DW-1163 17)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-38 December 2006

Comment: The Commission can and, we contend, should require Dominion to submit

information in accord with NEPA to allow an independent and fully informed evaluation as

required by NEPA, including the no-build option.... Before granting a permit, the NRC has the

duty to comply with the National Environmental Policy Act (NEPA) to the fullest extent

possible... In Natural Resources Defense Council v. Morton, 458 F.2d 827 (D.C. Cir. 1972) the

court held that reasonable alternatives must be considered, even if the alternatives are not

within the scope of the agency. (DW-1163 18)

Comment: I concur with the assessments on the DEIS which have been presented to you by

the Blue Ridge Environmental Defense League, and strongly state that, overall, the NRC’s

analysis of the potential environmental impact has significantly underestimated the potential

negative impacts that granting an ESP would bring to the quality of the air, water, and land of

the region. ... I would ask the NRC to withdraw its current Draft Environmental Impact Statement

and redo its analyses so that proper attention is given to the negative impacts that the new

nuclear reactors would bring were the NRC to grant Dominion an Early Site Permit. 

(DW-1176 1)

Comment: In general, the North Anna ESP DEIS provides a thorough evaluation and well

founded conclusions on the Environmental Report provided as part of the Dominion ESP

application. The evaluations and conclusions are consistent with the requirements of NEPA

and 10 CFR Part 51. (DW-0435 1)

Comment: We repudiate the Commission’s (NRC) and heavily subsidized industry’s efforts to

license new nuclear power plants despite unresolved safety and waste issues which include

immunizing plant operators from liability in the event of a massive nuclear accident. 

(DW-0187 1)

Comment: [T]he DEIS does not inform the public that private insurance will not provide total

coverage for this kind of facility and that, in fact, taxpayer funds are used to self insure. Is the

public informed that much of the cost of security and waste disposal is also paid for not by

investors but through their tax dollars? Are we willing to provide the information to the public so

they can comment on it? The NRC can waiver provisions to provide this information but it

cannot waiver the legitimate rights of the public to know this information especially if you invite

them to comment on the proposal. (DW-0594 4)

Response: Section 102 of NEPA directs that an EIS is required 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. Subpart A of 10 CFR Part 52 contains the NRC

regulations related to ESPs. It is the NRC EIS rather than the applicant’s ER that is used as the

basis for the decision on the ESP application. Therefore, no further action is planned on

comments on the ER.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-39 NUREG-1811, Volume II

The Council on Environmental Quality (CEQ) regulations state that tiering is appropriate when it

helps the agency “to focus on the issues which are ripe for decision and exclude from

consideration issues already decided or not yet ripe.” See 40 CFR 1508.28(b). As set forth in

10 CFR 52.17, the ESP applicant must submit a complete ER focusing on the environmental

effects of construction and operation of a reactor or reactors; however, in accordance with

10 CFR 52.17, the applicant need not include an assessment of the benefits (e.g., need for

power), since such matters may not be ripe for consideration at the ESP stage. Similarly, in its

denial of a petition for rulemaking, the Commission stated that the consideration of alternative

energy sources may be deferred until the COL stage (68 FR 55905). These Commission

determinations are consistent with the CEQ regulations in 40 CFR 1508.28(b). The ER is

intended to assist the Commission in complying with Section 102 of NEPA. The ER may be

used extensively by the NRC staff as a starting point in its review. However, the NRC staff

independently evaluates information contained in the ER and develops its own bases and

analyses. Ultimately, the NRC staff is responsible for the reliability of any information used.

As set forth in 10 CFR 52.18, the Commission has determined that an EIS will be prepared

during the review of an application for an ESP. An applicant for a CP or COL for a nuclear

power plant or plants to be located at the site for which an ESP was issued can reference the

ESP. A CP or COL to construct and operate a nuclear power plant is a major Federal action

that requires an environmental review in accordance with 10 CFR Part 51. The NRC process

for evaluating the environmental portion of ESP applications was embodied in its Standard

Review Plans for Environmental Review of Nuclear Power Plants (ESRP) (NUREG-1555)

(NRC 2000), which was subject to public comment. The ESRP forms the basis of RS-002

(ML040700094) (NRC 2004), which was also subject to public comment. This ESP EIS

conforms with the review guidance and is sufficient to fulfill NRC’s NEPA responsibilities.

Among the areas included in the EIS, the NRC staff considered the no-action alternative or

denial of the ESP, mitigation measures to further reduce environmental impacts, alternative

sites, unavoidable adverse environmental impacts, irreversible and irretrievable commitments of

resources, the relationship between short-term uses and long-term productivity, cumulative

impacts, construction impacts, and the impacts of operation.

Accordingly, no changes were made to this EIS as a result of these comments.

Comment: Chapter 9, Page 9-1, Line 31 - NRC has cited NEPA Section 102(2)(c)(iii) as

requiring an analysis of alternatives to the proposed action. EPA believes this to include an

analysis of a wide array [of] alternatives not just alternatives of different sites. Furthermore,

EPA believes this interpretation is reinforced by Section 102(2)(E) that requires all agencies of

the federal government to “study, develop, and describe appropriate alternatives to

recommended course of action in any proposal which involves unresolved conflicts concerning

alternatives uses of available resources.” (DW-1272 14)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-40 December 2006

Response: The NRC determined and informed prospective ESP applicants by letter that

evaluation of alternative energy sources did not need to be covered in an application for an

ESP. This determination is included on the NRC’s web site at

http://www.nrc.gov/reactors/new-licensing/esp/generic-esp-issues.html. NRC’s position on this

issue is further explained in a proposed change to 10 CFR Part 52 that was published in the

Federal Register on July 3, 2003, (68 FR 40025) and on March 13, 2006 (71 FR 12782). If an

applicant is granted an ESP and has not addressed alternative energy sources in its application,

and if the applicant subsequently elects to apply for a construction permit or a combined

license, then the applicant would be required to include an analysis of energy alternatives in its

application. In conjunction with its evaluation of the application at that time, NRC would prepare

an EIS that would evaluate energy alternatives to construction and operation of new nuclear

generating units at the ESP site. The comment may also be referring to alternatives to systems,

structures, or components of a new nuclear unit that might be constructed and operated at the

North Anna ESP site. To the extent that such alternatives could change the new unit’s

environmental impacts, the staff has considered such alternatives, for example, alternative

cooling systems.

Comment: The draft and supplemental draft don't seem to me to be NEPA-compliant

documents. They should be re-done with more thorough analysis, and circulated for review and

comment. (ST-0036 10)

Comment: The Purpose and Need provision of [the] SDEIS does not include an assessment of

the energy needs that the addition of two nuclear power units at the North Anna facility would be

intended to satisfy. The focus of the Purpose and Need was restricted to simply the suitability

of siting two nuclear power units at the facility without any assessment of the need for the two

additional units. EPA believes an energy needs assessment should be included in the NRC's

NEPA review at a point in the process when such an assessment – including an assessment of

options other than construction of additional units – would be meaningful. This is especially a

concern because the NRC apparently has not yet resolved issues related to the interface of the

ESP with the combined construction and operating license, combined license (COL) process.

See http://www.nrc.gov/reactors/newlicensing/esp/generic-esp-issues.html. It is unclear

whether the energy needs analysis will be included under the NRC's Construction

Permit/operating license EIS. (SE-0030 1)

Comment: The SDEIS only evaluates alternative sitings for nuclear power plants and does not

evaluate alternative energy sources. ... It is unclear whether alternative energy sources will be

included under the NRC's Construction Permit/operating license EIS. (SE-0030 2)

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? 

(SE-0045 47)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-41 NUREG-1811, Volume II

Response: The ESP licensing process was established in 10 CFR Part 52 and was

promulgated in 1989 (see 54 FR 15386). In 2000, the NRC staff finalized the environmental

procedures to guide its environmental review, published as the Standard Review Plans for

Environmental Review for Nuclear Power Plants (ESRP), NUREG-1555 (NRC 2000). The

ESRP and Part 52 were issued for public comment to ensure that all interested parties had the

opportunity to provide insights on the NRC’s approach to comply with its NEPA review

responsibilities before the NRC was called upon to do so for an ESP. The NRC’s Draft and

Final EISs are developed using these environmental review procedures and an interdisciplinary

team of environmental specialists comprised of NRC staff and supported by its contractors. The

ESP application includes the applicant’s representation of environmental impacts and it serves

as a starting point for the staff’s independent assessment; in the end, the NRC is responsible for

the reliability of all information it uses in its EIS, even if information or analyses is provided by

the applicant. 

The resolution issued by Spotsylvania County did not provide any technical information that

would affect the staff’s environmental review and is treated as a comment letter in this

appendix.

In accordance with NRC regulations and guidance, the staff’s review at the ESP stage is

focused on the impacts of construction and operation of a reactor or reactors that have

characteristics that fall within the site parameters and the evaluation of alternative sites. At a

minimum the applicant must demonstrate, and the staff must determine, whether there is an

obviously superior alternative site. Some issues (e.g., the benefits assessment, including the

need for power), may not be ripe for consideration at the ESP stage, and the NRC’s regulations

specifically allow deferral of consideration of these issues to the construction permit or

combined license review See 10 CFR 52.17(a)(2). In addition, the staff’s review guidance for

an ESP recognizes that design-specific information may not be available at the ESP stage, and

directs the staff to use its experience and judgment in such cases. See Attachment 3 to Review

Standard (RS)-002, “Processing of Applications for Early Site Permits” (NRC 2004).

Issues that are deferred or not resolved in the ESP review must be addressed and resolved in

the review of an application for a CP or a COL referencing an ESP, if granted. This is the

structure of the NRC’s review in accordance with its regulations. For the North Anna ESP, the

applicant chose to defer its evaluation of (1) the benefits of construction and operation

(including the need for power) and (2) alternative energy sources, and these issues will be

evaluated in the context of a CP or COL application referencing the ESP, if granted. 

Accordingly, no changes were made to this EIS as a result of these comments.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-42 December 2006

4.3 Editorial Comments

Comment: Per ER Figure 3.1-3, this DEIS figure should identify the Unit 3&4 discharge

structure as existing. [page 3-2, Figure 3-1] (DW-0423 15)

Response: Figure 3-1 was modified to indicate that the discharge structure for future units

already exists. 

Comment: Per ER Figure 3.1-3, this DEIS figure should identify that the existing training

building would be expanded. [page 3-2, Figure 3-1] (DW-0423 16)

Response: Figure 3-1 was modified to indicate that the existing training building would be

expanded.

Comment: DSER page 2-61 states 251 km2

 [versus 250 km2] and 119 km2 [versus 120 km2],

respectively. [page 2-21, lines 21-22 and 29-31] (DW-0423 56)

Response: Unlike the safety evaluation report, unit conversions in the EIS are generally

provided with the same number of significant digits as in the original units. In this case, the

areas discussed were documented in the literature as being 97 and 46 mi2

, respectively. 

Accordingly, no changes were made to this EIS as a result of this comment.

Comment: Percichthyidae, Morone americana, and Morone saxatilis are the correct scientific

names. Morone americana and Morone saxatilis are correct in accompanying DEIS text. 

[page 2-36, lines 10-12] (DW-0423 58)

Response: These scientific names were corrected in Table 2-3 in the EIS as a result of this

comment.

Comment: Alasmidonta heterodon is the correct scientific name. [page 2-43, line 9] 

(DW-0423 59)

Response: The spelling of this scientific name was corrected in Table 2-4 in the EIS as a result

of this comment.

Comment: The correct value is 9.7 x 109

 Btu/hr. [page 5-6, line 21] (DW-0423 60)

Comment: Page 5-6, line 22 is missing data in the parenthesis “9.7 BTU/hr” is not correct). 

(DW-0438 133)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-43 NUREG-1811, Volume II

Response: These values are no longer in the document because of the changes to the cooling

system.

Comment: ABWR value is 2.4E-11 [versus 2.3E-11]; AP1000 value is 1.2E-10 [versus

1.1E-10]. [page 5-78, lines 10 and 12, Table 5-19] (DW-0423 61) 

Response: These numbers were corrected in Table 5-19, now Table 5-20, in the Final EIS.

Comment: AP1000 value is 2.4E-07 [versus 2.7E-07]. [page 5-80, line 12, Table 5-20] 

(DW-0423 62)

Response: This number was corrected in Table 5-20, now Table 5-21 of the Final EIS.

Comment: Reference should be to Section 7.5. [page 7-2, line 15] (DW-0423 63)

Comment: Also an apparent typo, on page 7-2: “Cumulative thermal effects are discussed in

Section 7.4.” I believe you intended Section 7.5, since the aquatic ecosystem is more likely to

experience thermal effects than the terrestrial ecosystem. (DW-0827 3)

Response: The reference was corrected to Section 7.5 in the EIS.

Comment: The paragraph on page 5-70, line 14 would benefit from simpler language. 

(DW-0438 161)

Response: This paragraph in Section 5.9 of the EIS was rewritten for greater clarity.

Comment: Flow rates are confusing in the report. Some liters/second, meters3

/second,

ft3

/second, and gallons/minute are used. I suggest that the same units be used throughout the

ESP report. (DW-0806 1)

Response: The staff agrees that the use of various volume units can be confusing. However,

the units used throughout the EIS are typical of engineering standard units, which differ by

discipline. Accordingly, no changes were made to this EIS as a result of this comment.

Comment: The correct monthly snowfall is 28.5 inches [versus 28.3 inches]. [page 2-11,

line 27] (DW-0423 52)

Response: The monthly snowfall was corrected to 28.5 inches in Section 2.3.1 of the EIS.

Comment: The correct percentage is 90.09 [versus 90.9]. [page 2-15, line 16] (DW-0423 53)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-44 December 2006

Response: The percentage of data recovery rates from the meteorological monitoring system

was corrected in Section 2.3.1.6 to 90.09 percent. 

Comment: The dispersion factor should be shown as X/Q. [page 2-15, line 23; and other DEIS

locations] (DW-0423 54)

Response: The symbol used for the “chi” in Section 2.3.1.6 (L) was replaced by the symbol Ȥ,

which is the capitalized version of “chi” in Arial font. This version of the symbol now appears

throughout the EIS.

Comment: Correct value is 2.45 x 105

 acre-ft [versus 2.45 105. [page 2-19, line 15] 

(DW-0423 55)

Response: The flood control storage volume was corrected to 2.45 x 105

 acre-ft in the EIS.

Comment: [page 5-17, line 17] should state, “In the area above the State Road 208...” 

(SE-0050 18)

Response: The sentence was changed to correctly indicate the location.

Comment: The D/Q exponent [in Table I-1, line 19] is incorrect. It should be 6.0 x 10-9.

(SE-0050 22)

Response: This number was corrected in Table I-1 of the FEIS.

Comment: [T]he SDEIS makes reference to the shortnosed sturgeon as being listed as

endangered by the National Marine Fisheries Service and by Virginia. It also appears on the

Virginia Department of Cultural Resources List of "Extinct and Extirpated Animals of Virginia."

(SDEIS, page 8-29, section 8.5.4). There is no "Virginia Department of Cultural Resources." 

Perhaps the reference is to the Department of Historic Resources, which does not have

responsibility for endangered species. (SW-0017 59)

Response: The correct reference should have been to the Virginia Natural Heritage Program

under the Virginia Department of Conservation and Recreation, which maintains a list of rare

animals. In that list, the shortnose sturgeon is listed as “LE” or “Listed Endangered,” by Virginia. 

Section 8.5.4 was modified to clarify this.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-45 NUREG-1811, Volume II

4.4 Comments Supporting or Opposing the ESP

The Congress has authorized the NRC to implement the Atomic Energy Act of 1951, as

amended, and the Energy Reorganization Act of 1974, as amended, in regulating the nuclear

power industry. NRC’s implementing regulations are published in 10 CFR Parts 1 to 199. The

NRC’s environmental protection regulations are located at 10 CFR Part 51, and the regulations

governing an early site permit are located in 10 CFR Part 52.

The Congress has developed national goals regarding Federal energy policy in the Energy

Policy Act of 2005. It is the purview of the President and the Congress to establish the energy

policy of the United States, not the NRC. The Energy Reorganization Act of 1974, which

created the NRC from the regulatory arm of the abolished Atomic Energy Commission, ensured

that the NRC would not have a promotional role regarding nuclear power; that is now the

domain of the U.S. Department of Energy.

The ESP process is not a public referendum or vote. Rather, it is a process designed to assure

that applicants meet applicable NRC safety requirements before a permit is granted. In addition

to ensuring that applicants conform to safety requirements under the Atomic Energy Act and

NRC regulations, the ESP process also ensures that the NRC complies with the requirements of

NEPA. The NRC’s environmental review process for this EIS ensures that the public can

participate effectively following established guidelines. The public was given the opportunity to

participate in the development of NRC regulations and the body of work that makes up

regulatory guidance. This EIS is subject to public scrutiny and the hearing before the Atomic

Safety Licensing Board. The NRC’s Safety Evaluation Report (September 2005, Accession No.

ML052710305) is subject to the scrutiny of the Advisory Committee on Reactor Safeguards and

the hearing before the Atomic Safety Licensing Board. Subject to certain safeguards and

security requirements, the reports and the information and bases leading up to the reports are

readily available to every member of the public.

The ESP process is one of many licensing processes implemented by the NRC and authorized

by the Congress. Certain environmental issues that must be considered before the NRC could

authorize construction and operation of a new nuclear power plant (e.g., the benefits

assessment) may not be ripe for consideration at the ESP stage, and need not be resolved with

the issuance of an ESP. Certain issues are not appropriate for consideration in any

environmental review (e.g., malevolent acts of terrorism). Certain issues have been generically

resolved (e.g., fuel cycle environmental impacts for light-water reactors). Certain issues

(e.g., whether a license should be issued for a spent fuel and high-level waste repository) are

not part of the ESP review.

The following comments, which either support or oppose the North Anna ESP, do not provide

new information, and no changes were made to the EIS as a result of these comments.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-46 December 2006

4.4.1 Support for the ESP

Comment: We think that the environmental review that has been done has been done well. 

It is done adequately. We appreciate the NRC’s detail review. (DT-0004 7)

Comment: I appreciate the opportunity to take part in this environmental impact assessment

discussion, and I’d like to point out that these environmental impact assessments are valuable

to us probably more than most of us realize...And these environmental impact assessments at

this point are under some danger of disappearing from our communication, and I think that as

much as anything we’re concerned about we need to be paying attention to the openness of

communication about our reality. So I do appreciate all of the information that the NRC has

provided us this evening. I appreciate the viewpoints on both sides of this issue. (DT-0010 1)

Comment: I speak in support of the conclusions reached by the draft NRC EIS for the North

Anna early site permit with comments. (DT-0014 1)

Comment: Furthermore, the local NAYGN is here to show our support for the ESP process as

a means to guarantee an open and thorough evaluation of future nuclear projects while insuring

the timeliness and predictability of the process. In particular, as nuclear professionals and as

concerned local citizens, we concur with the NRC’s conclusion that environmental impacts

would not prevent issuing an early site permit for the North Anna site. (DT-0020 2 and

SW-0009 1)

Comment: I cannot really understand how any serious environmentalist after thoroughly

reviewing the facts can realistically dismiss the measurable, positive contribution of existing

nuclear power plants and the potential in the future role of new nuclear power towards the

sustainable development of humankind. I insist I am talking about the unbiased review of facts,

not wandering (phonetic) half truths and out of context, misinterpreted data. (DT-0025 2)

Comment: I also support the ESP process as a means to warrant the open and thorough

evaluation of future nuclear projects while insuring the timeliness and predictability of the

process. (DT-0025 5)

Comment: There are other companies in the energy industry that are pursuing early site

permits and testing other NRC licensing processes to build new reactors in the future. And

these efforts are broadly supported by the public, by policy makers, Republicans, Democrats,

independents alike, as Mr. Sloane said, by leading environmentalists across the world. 

(DT-0027 4)
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December 2006 4-47 NUREG-1811, Volume II

Comment: I want to thank the NRC staff for having this, coming here tonight and hold this

public comment hearing. It demonstrates that the NRC is interested in obtaining the citizen

input into environmental, as well as the safety issues regarding the proposed regulatory action. 

(DT-0029 1)

Comment: We concur with the NRC’s conclusion that environmental impacts would not

prevent issuing an ESP for the North Anna site. (DT-0052 1)

Comment: We support the ESP process as the means to guarantee an open and thorough

evaluation of future nuclear projects, while ensuring the timeliness and predictability of the

process. (DT-0052 3)

Comment: A well conformed EIS will tell us (the people by the way, not Virginia Power, Public

Citizen, or the NRC) whether North Anna can safely support more nuclear plants. (DW-0360 2)

Comment: Today, the time necessary to obtain a permit has grown so long that it becomes

difficult to justify a plant financially based on the permitting process. By getting the early site

permit, a timely study of electric power needs can be done to determine when the new units

should be built. (DW-1007 4)

Comment: I felt the NRC staff present did an excellent job presenting the reason for being

there that evening and for summarizing its findings of the draft EIS. I felt the staff were well

composed, professional and did not indicate a bias one way or the other to the comments

offered. I felt that the public present were grateful for the opportunity to speak their minds on

this important topic. (DW-1148 1)

Comment: I think the NRC draft EIS does a good job of covering the issues pertinent to this

part of the process and commend the team for the draft report (NUREG-1811) and their

handling of the local comment meeting as well. (DW-1167 7)

Comment: As you heard, we do not have any plans at the moment to build a nuclear plant at

North Anna. What we’re doing here is keeping the option open. We are looking forward toward

where the energy that Virginia is going to need in the future is going to come from, and as we

look at the various options, one of those options is nuclear. (DT-0004 1)

Comment: We’ve been operating plants for 30 years. We have a great deal of experience with

that, and so between the safety of our existing operations and our environmental record, this is

something that we feel very confident with. This is something that we feel we’ve developed a

long experience and relationship with the local communities. So we’d like to continue them. 

(DT-0004 2)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-48 December 2006

Comment: At this point we are not announcing or we are not saying that we’re going to build. 

We are trying to maintain an option. (DT-0004 6)

Comment: As a customer of Dominion Power and to the men and women who work there,

thank you for beginning this long and arduous process and necessary process. (DT-0014 10)

Comment: The environmental report of Dominion’s ESP application and the NRC’s draft

environmental impact statement demonstrate in great detail what has become patently obvious

in an area of increasing concerns about global warming, air pollution, environmental protection

and industrial safety. (DT-0020 3)

Comment: I have found the management to be uncompromising when it comes to safety and

ethics ... Even if addressing my concerns meant schedule delays or additional costs, even if at

the end my concern was unfounded, I have always have the support of my management in

pursuing questions of safety, design, and ethics ... If there was something seriously wrong with

the plant, it would take only one person to shut it down. (DT-0020 7)

Comment: I commend Dominion for the interactive draft in planning for expected increases in

energy demand over the coming years, while considering sources that minimize the environmental footprint, as well as the economic burden on Dominion’s estimates ... And finally, I want

to voice my support to granting Dominion Resources an early site permit to construct new

nuclear reactors at its North Anna site. (DT-0025 4)

Comment: I’d like to applaud Dominion for pursuing an early site permit at North Anna, for its

efforts to preserve the options to make prudent future choices for our electricity, not only today,

the electricity challenges we have today, but also the challenges our future generations are

going to have. (DT-0027 1)

Comment: Simply put, it makes sense for Dominion to take this step to explore options for

serving millions of customers in Virginia, including my family who’s going to depend on reliable,

affordable, and clean electricity. (DT-0027 5)

Comment: I have concluded that any environmental impacts associated with the preparation

and preliminary construction activities -- and I’m emphasizing that -- allowed by 10 CFR 50.10 --

you know the rules -- are minor and will not result in any adverse environmental impact, and I

really recommend the draft be issued as a final. I meant to emphasize that that conclusion only

has to do with, as you said, the increased or the impacts associated with the pre-construction

ones. (DT-0029 3)

Comment: It’s good to see that there is some new interest by utilities to pursue possible

consideration of additional nuclear power plants. (DT-0029 10)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-49 NUREG-1811, Volume II

Comment: Based on my experience, I have complete confidence in the safety of nuclear

power facilities and particularly those operated by Dominion Power. (DT-0029 13)

Comment: There are numerous other reasons which I’ll only mention here since I have limited

time. Fossil fuel prices rising recently. Increased electricity demand. Air pollution.

Comment: For me, all of these events, all of these developments point to one thing. It’s time

for us to build a new generation of nuclear plants. Approving an early site permit for the North

Anna site is an important step in that direction, and I think that it should be done. Let’s do it. 

(DT-0032 5)

Comment: I have reviewed the draft environmental impact statement for the North Anna early

site permit. I have found it thorough, well written, with sound conclusions, and see no basis for

not approving the environmental impact statement and the early site permit. (DT-0045 2)

Comment: I agree with the draft environmental impact statement that concludes that there are

no environmental impacts from the possible future construction and operation of a nuclear

power plant in North Anna that should prevent issuing an early site permit. (DT-0046 4)

Comment: I applaud Dominion for taking the steps necessary to insure nuclear energy

remains an option. (DT-0046 5)

Comment: [I’m here tonight to voice my support] specifically for my support of the early site

permit at North Anna. (DT-0046 6)

Comment: Nuclear energy is efficient and cost-effective due to its high plant performance

coupled with modernized plants, low production cost, future price stability, and clean air

compliance value. New nuclear plants at North Anna will ensure nuclear energy’s continued

contribution to both our economy and the protection of our environment. (DT-0046 8)

Comment: We commend Dominion for being proactive and farsighted when looking for reliable

methods of addressing expected increases in energy demand over the coming years, while

minimizing the environmental footprint of the selected energy sources, as well as the economic

burden to Dominion customers. (DT-0052 4)

Comment: I endorse Dominion’s proposal for an early site permit for an additional plant at

North Anna. Nuclear energy is a safe and efficient supplier of our energy needs today and will

be more important in the future. (DT-0059 1)

Comment: I could think of nothing better than to have an additional nuclear plant at North

Anna. (DT-0060 1)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-50 December 2006

Comment: I am very supportive of Dominion Power and the North Anna Nuclear Power

Station. Many of my neighbors and business acquaintances feel the same. So I urge you to

swiftly approve the Environmental Impact Statement for the Early Site Permit (NUREG 1811). 

Follow your staff’s recommendation and approve the ESP and let Dominion get started with the

next reactors. (DT-0063 6)

Comment: [I] would like to voice my support of Dominion’s efforts to maintain nuclear power as

an energy option with the potential construction of new nuclear power plants in Virginia. 

(DW-0185 1)

Comment: I urge the NRC to consider issuing an Early Site Permit to the North Anna nuclear

project on the basis that it will not adversely impact the environment. (DW-0370 1)

Comment: I agree with the Staff’s conclusions that the North Anna site appears to be

environmentally acceptable for the construction of new reactors, and that Dominion’s request to

perform limited site preparation and investigation measures will not result in significant

environmental insult. (DW-0399 2)

Comment: I see no problem with an early site permit for North Anna site. (DW-0440 1)

Comment: Please approve the document [North Anna’s EIS]. (DW-0442 1)

Comment: Please approve the draft environmental statement as presented by North Anna for

an ESP at their site. (DW-0445 1)

Comment: Please register my support for any plans by Dominion to build any new nuclear

reactors at its North Anna nuclear power station in Virginia. (DW-0471 1)

Comment: You have correctly assessed the environmental impact. The recently conducted

public hearings, while an important part of the process, are just that: one source of public input. 

You correctly applied your approved process and scientific principles and judgment. The

conclusion in support of the use of the site is appropriate. Additional steps in the future

licensing of a unit or units will build on your work. Your job is complete and stands on its own

merit! It serves as an important foundation for continued safe use of the property. The public is

well served by your action and conclusions. (DW-0583 1)

Comment: An editorial last year in the Richmond Times-Dispatch put it this way: “Many

environmentalists want to reduce consumption of fossil fuels. Regarding electricity generation,

what better way to replace oil, coal, and natural gas plants than with nuclear?” And the

Washington Post, in an August 2004 editorial on energy policy, said it is time to “look again at
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-51 NUREG-1811, Volume II

nuclear energy, a taboo issue yet potentially a huge source of homegrown, non-carbon

producing energy. Dominion is doing just that...looking at its options for producing electricity for

future generations in a way that is safe, sustainable and affordable for all consumers. 

(DW-0668 3)

Comment: My vote is for Dominion Power’s plan to expand nuclear power generation. 

(DW-0757 2)

Comment: The Sierra Club is opposed to Dominion Power’s efforts to build two new nuclear

generators on the shore of Lake Anna. It is my considered opinion that the Sierra Club is

“barking up the wrong tree.” (DW-0760 1)

Comment: My vote is for Dominion Power’s plan to expand nuclear power generation. 

(DW-0760 3)

Comment: I am writing to SUPPORT granting an Early Site Permit to Dominion Resources to

build two new reactors at the North Anna nuclear plant in Mineral, Virginia. (DW-0791 1)

Comment: This is a wise decision for a company that has proven over time to be a safe and

effective nuclear operator. (DW-0791 2)

Comment: The electric power generation from nuclear energy must be revived with the

approval of early site permit (ESP) at North Anna followed by the issuance of combined license

for construction and operation (COL). The one-step licensing and economic viability of the

safest, the cleanest and the most modern nuclear technology must be demonstrated. It is

heartening to know that Dominion is at the forefront of this move. ... The ESP and COL

application are just two tiny but monumental steps in the pursuit of nuclear energy option here in

the United States and should not be thwarted by what amounts to a baseless anti-nuclear

propaganda. (DW-0812 2)

Comment: I fully support this initiative. (DW-0858 1)

Comment: I support your plan to build another nuclear power plant. (DW-0879 1)

Comment: It is also important to note that the lake at North Anna was originally constructed for

4 units and the people of Louisa as well as the state of Virginia knew about the 4 units since the

1970s. In fact, both Units 3 and 4 were started and construction went quite far before the

economic justification faltered, forcing the cessation of work on these units. (DW-1007 5)

Comment: I support the North Anna Early Site Permit as an important step in ensuring energy

diversity for Virginia, as well as paving the way for the next generation of safe, environmentally

friendly nuclear power for the United States. (DW-1149 1)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-52 December 2006

Comment: The construction of one or more additional nuclear generating facilities at the

current site of the North Anna Power Station makes sense from an economic and environmental

point of view. As a member of the public who is concerned about the effect of fossil fuels on our

environment, I fully endorse and encourage approval of Dominion’s plans for construction and

licensing. (DW-1158 1)

Comment: As a resident of central Virginia who will be impacted by any power plants built in

the general area, my preference for base loaded plants is the nuclear option. ... I heartily

recommend that the draft report be completed within the process and that the site receive final

approval for additional reactors if it becomes economically feasible to build them. (DW-1167 1)

Comment: The North Anna site provides what I think is a near ideal site for addition of nuclear

power plants. This site was designed for 4 nuclear units with only two currently in operation

there. The North Anna site already has a significant amount of the ‘things’ that are needed for

operation of such units, i.e., infrastructure in terms of transmission facilities and dedicated

personnel. As such, the impact of placing additional nuclear units there would be minimal

compared to a green field site. (DW-1167 4)

Comment: In my biased opinion (I’m a Dominion Resources employee), the operator of the

plant has demonstrated a continuing and significant concern for the environment and a

determination to safely and effectively operate its current nuclear units. Effective operation of

these units is a priority and I believe it will continue to be a priority. (DW-1167 5)

Comment: I look forward to getting my electricity from plants like the future ones on Lake

Anna. (DW-1235 3)

Comment: This is to express my unqualified support for issuance of an Early Site Permit for

North Anna. I live in the Dominion Virginia service area and enjoy the benefits of the

inexpensive nuclear generated electricity from the two existing North Anna reactors. I cannot

imagine any reason why an Early Site Permit would be denied. Virginia Electric and Power (the

predecessor to Dominion) originally planned to build four reactors at the North Anna site, which

was sized to accommodate four units. The quicker an Early Site Permit can be issued, the

quicker Dominion can apply for a Construction Operating License. It would be great to have a

new nuclear reactor in Virginia in the next few years. (DW-1248 1)

Comment: In Virginia, the power output of the Surry and North Anna plants represent about

7 million tons of carbon dioxide emissions avoided each year. (DW-0863 2)

Comment: As a supporter of the rebirth of nuclear power in the U.S.’s power supply mix, I

applaud Dominion’s pursuit of an ESP and the Staff’s timely and thorough review resulting in

the issuance of NUREG-1811 (draft). (DW-0399 1)
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December 2006 4-53 NUREG-1811, Volume II

Comment: [T]hese are not simple issues. Nothing in power production is simple. Nothing in

energy consumption or energy economy is simple. Any project no matter what its size, no

matter what its type, will involve some change to the environment. Our job is to balance that, to

decide whether the impacts are controllable, whether the impacts make sense in relation to the

benefits of the project. (ST-0009 4)

Comment: I wish to express my support on the part of Dominion Resources to build additional

new reactors at their North Anna site in Louisa County Virginia. ...This appears to me to be a

huge benefit economically both locally and regionally and should be allowed to proceed when

all permits have been issued. (SW-0001 1)

Comment: On behalf of my constituents, Dominion Power and its 8,968 Virginia employees, I

am writing in support of Dominion's early site permit (ESP) application for the North Anna Power

Station site, and the U.S. Nuclear Regulatory Commission staff's preliminary recommendation

that the ESP should be issued. ...Dominion has safely operated the North Anna Power Station

since 1978 and the Power Station is an efficient, low cost nuclear generation facility. 

(SW-0002 1)

Comment: I am proud of my industry in general and Dominion in particular. ...Like any other

technology, nuclear is not risk-free. However, Dominion's record of safely operating its plants is

very reassuring. I would wholeheartedly endorse Dominion attempt to secure the subject permit

and urge you to issue the same. (SE-0023 1)

Comment: Although, as in any group of hundreds of people, we have members with differing

opinions, we, as a whole, as strongly in favor of proceeding with the [North Anna] third and

fourth units. We have had no fundamental, unanswered concerns relating to the nuclear

portions of the units or the accident safety of the total plant. (SW-0004 1)

Comment: [W]e strongly support Dominion's efforts to bring more Nuclear Generation to

Virginia, and specifically, Louisa. ...The International Brotherhood of Electrical Workers believe

that Corporate America, the American Worker and our precious American Environment can all

co-exist and prosper. That is why we believe that expansion at North Anna is good for The

Commonwealth, and good for the Nation. It should be permitted to go forward if the need for

additional generation arises. (SW-0003 1)

Comment: I would like to indicate my support for a favorable ruling for the Early Site Permit at

the North Anna Site. ...with the rising cost of electricity and the need to produce more, the way

to go now is nuclear. (SE-0011 1)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-54 December 2006

Comment: We are not opposed to the North Anna Project and do support the addition of 3rd

and 4th nuclear reactors at the North Anna plant, but want to ensure that all environmental

issues are taken care of prior to the issuance of either an NRC Early Site Permit or a VDEQ

Federal Consistency Certification. (SE-0022 2, ST-0012 2)

Comment: I want to voice my support for granting to Dominion Resources an early site permit

to construct new nuclear reactors at its North Anna site. (ST-0013 5)

Comment: I'm the County Administrator. I'll first say that we have a good working relationship

with Dominion Virginia Power. As you may know, they're our largest employer and are by far

our largest taxpayer and being County Administrator, I'm also involved in safety issues and find

them very cautious...the Board of Supervisors voted to say that they support Virginia Dominion

Power in their early site permit process. (ST-0010 1)

Comment: [W]e fully support implementing and constructing the new power plants. We are

located on the first lagoon, so we're the ones that are going to be most directly affected by the

temperatures that these cooling towers should alleviate for us. (ST-0029 1)

Comment: I commend Dominion for being proactive in planning for expected increases in

energy demand over the coming years, while considering sources that minimize the

environmental footprint, as well as the economic burden to Dominion customers. ...I want to

voice my SUPPORT to granting to Dominion Resources an Early Site Permit to construct new

nuclear reactors at its North Anna site. (SE-0025 4)

Comment: The Virginia Chamber commends the agency staff for its meticulous review of

Dominion's early site permit application, and supports its conclusions. Thank you for your time

and attention. (ST-0031 2)

Comment: [T]he Louisa County Board of Supervisors is in support of the Early Site Permit

being sought by Dominion Virginia Power. (SW-0005 1)

Comment: [A]s a trained environmentalist, I know that nuclear energy has one of the smallest

life-cycle environmental impacts. And it is comparable with those impacts associated with other

renewal energies, but at a much lower cost, and one that operates 24-hours a day, seven days

a week, 365 days a year. And that's why I truly support this permit request. (ST-0033 2)

Comment: I would like to speak very favorably for the additional of the two extra units here in

North Anna. (ST-0034 5)

Comment: I'm speaking this evening to register our strong support for Dominion's early site

permit application for the North Anna Power Station site, and the NRC staff's preliminary

recommendation that the permit be issued. (ST-0031 1)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-55 NUREG-1811, Volume II

Comment: Nuclear power is a safe producer of electricity and Dominion is one of the best to

do it. ...North Anna's commitment to safety directly affects me just as it does you and every

other member of the community. And if Dominion does build Unit 3, I believe it will only

strengthen our pursuit of excellence and dedication to this community. (ST-0022 3)

Comment: My wife and my daughters mean more to me than life itself and I feel very

comfortable moving five and a half miles from the North Anna Power Station. (ST-0021 2)

Comment: The Chamber of Commerce supports the approval of the early site permit for the

North Anna Power Station. The addition of one new nuclear unit is good. The addition is better

for the economy. (ST-0018 1)

Comment: So I would like to challenge those who question the analysis, techniques and the

results of the Nuclear Regulatory Commission...to see if there are some differences in

assumptions that each groups have made or if there is some other reason why there is a

discrepancy in value. (ST-0017 2)

Comment: I want to express my personal desire to see this supplemental EIS get approved. 

I think it's going well and it's a good idea. (ST-0017 1)

Comment: Nuclear holds the promise of being relatively safe and benign environmentally. It is

a shared...proven technology with enormous upside potential. And it is time to use it - here.

...The operators of nuclear stations and the NRC has done an excellent job through

preventative maintenance and rigorous engineering standard development and enforcement. 

(SW-0015 7)

Comment: I'm in full support of what I've read in the supplement. (ST-0015 1)

Comment: I applaud Virginia Power in first of all escalating the power rating of the reactor of

the proposed Unit 3 and Unit 4. I think that's a good move because I'm also a rate payer. ...I am

happy to see more power being produced at a base load facility at one location that's controlled,

that's secure, that's safe. (ST-0015 3)

Comment: Dominion's nuclear North Anna has been a responsible, good neighbor over the

years. ...Although as in any group of hundreds of people, we have members with differing

opinions, we as a whole are strongly in favor of proceeding with the third and fourth North Anna

units. (ST-0004 2)

Comment: I am writing to express my support for Dominion's early site permit (ESP)

application for the North Anna Power Station site, and the U.S. Nuclear Regulatory Commission

staff's preliminary recommendation that the ESP should be issued. ...Dominion is an excellent

nuclear operator, and the North Anna Power Station is one of the nation's most efficient nuclear
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-56 December 2006

generation facilities. I support the NRC staff's preliminary conclusion contained in the

supplemental draft environmental impact statement and urge the NRC to issue the early site

permit. (SW-0013 1)

Comment: So as nuclear professionals and as concerned local citizens, we concur with the

NRC's conclusion that environmental impacts would not prevent issuing an early site permit for

the North Anna site. (ST-0012 3)

Comment: We have always been and always will be a clean, safe, reliable, cheap energy

provide. (ST-0023 2)

Comment: As the elected Delegate representing the 72,000 residents of Louisa, Goochland

and northwestern Henrico counties in the Virginia General Assembly, I am writing to express my

support for Dominion's early site permit (ESP) application for the North Anna Power Station site.

...Dominion is an excellent corporate neighbor and has demonstrated a longstanding

commitment to work with its Louisa County neighbors. Dominion has built up significant

community goodwill by its willingness to listen and respond to the concerns of those who live on

Lake Anna. (SW-0012 1)

Comment: I am here tonight to voice my support for one of the most misunderstood

technologies of today's time - the generation of electricity using nuclear energy. . . and

specifically for my support of the Early Site Permit at North Anna. ...New nuclear plants at North

Anna will ensure nuclear energy's continued contribution to both our economy and the

protection of our environment. (SW-0006 1)

Comment: Upon review of the [Supplement to the] Draft Environmental Impact Statement

(NUREG 1811), U.S. Women In Nuclear fully supports the approval of the Draft Environmental

Impact Statement and approval of the early site permit request. (SE-0026 1)

Comment: We commend Dominion for being proactive and farsighted when looking for reliable

methods of addressing expected increases in energy demand over the coming years, while

minimizing the environmental footprint of the selected energy sources, as well as the economic

burden to Dominion customers. (SW-0009 4)

Comment: I believe the increased power level of the North Anna 2- proposed generation units

is justified due to the fact that the cooling will now be done by cooling towers rather than the

existing lagoon. ...I think you will do well to approve this early site permit and let Dominion build

the extra generation when it is needed. (SE-0001 1)

Comment: I am speaking this evening to register the support of the Virginia Chamber of

Commerce for Dominion's early site permit (ESP) application for the North Anna Power Station

site, and the U.S. Nuclear Regulatory Commission staff's preliminary recommendation that the
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-57 NUREG-1811, Volume II

ESP should be issued. ...The Virginia Chamber commends the [NRC] agency staff for its

meticulous review of Dominion's ESP application and supports its conclusions contained in the

supplemental draft environmental impact statement. (SW-0007 1)

Comment: [W]hat we're really talking about here is not in my backyard. That's what it really

boils down to. Sure, everybody wants safe, clean and affordable electricity and they certainly

don't mind the tax revenue and associative benefits, but many of the people who opposed the

expansion forget that Lake Anna was a creek bed that was virtually devoid of life before nuclear

power. (TR-0020 3)

4.4.2 Opposition to the ESP

Comment: I urge the NRC to reconsider issuing an Early Site Permit to the North Anna nuclear

project on the basis that it will not adversely impact the environment. (DW-MM1 1)

Comment: I am writing to ask the NRC to examine the “cradle to cradle” effects of building a

new nuclear plant. From construction, to power generation, to disposing of and storing the

spent fuel, the proposed nuclear site would be detrimental to the environment and local

communities. (DW-MM1 2)

Comment: Please consider the effects of construction, power generation and the disposal and

storage of spent fuel in calculating environmental impact. (DW-0266 2)

Comment: I am writing to OPPOSE granting and Early Site Permit (ESP) to Dominion

Resources to build two new reactors at the North Anna nuclear plant in Mineral, Virginia. 

(DW-MM2 1a)

Comment: Too many questions remain unanswered and too many problems remain unsolved

for the NRC to grant an ESP at North Anna. (DW-MM2 1b)

Comment: I am opposed to new nuclear power. ... Constructing new reactors would be bad for

Virginia’s environment, bad for taxpayers, and bad for residential and commercial ratepayers. 

(DW-MM1 9)

Comment: Please register my opposition to any plans by Dominion to build any new nuclear

reactors at its North Anna nuclear power station in Virginia. The site is unsuitable, and many

important factors are not being considered in the decision of whether to approve Dominion’s

application for an Early Site Permit (ESP) at the site. Constructing new reactors would be bad

for Virginia’s environment, bad for taxpayers, and bad for residential and commercial

rate-payers. I urge the U.S. Nuclear Regulatory Commission to DENY Dominion’s application

for an Early Site Permit, and for Dominion to instead focus on finding alternative methods of

addressing expected increases in energy demands over the coming years. (DW-MM3 1)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-58 December 2006

Comment: Please register my opposition to any plans by Dominion to build any new nuclear

reactors at its North Anna nuclear power station in Virginia. The site is unsuitable, and many

important factors are not being considered in the decision of whether to approve Dominion’s

application for an Early Site Permit (ESP) at the site. Constructing new reactors would be bad

for Virginia’s environment, bad for taxpayers, and bad for residential and commercial

ratepayers. (DW-MM4 1)

Comment: Virginia currently has a surplus of electrical generating capacity, so excess power

will likely be sold outside the state rather than being used in-state to lower prices. Local

residents will be forced to live with the risks of the nuclear plant without getting the benefits. 

(DW-MM4 9)

Comment: In light of these concerns [stated previously], we urge the U.S. Nuclear Regulatory

Commission to DENY Dominion’s application for an Early Site Permit. (DW-MM4 17)

Comment: I want to thank the NRC and Dominion for streamlining this process so that we can

look forward to future outbursts of radioactivity in our environment and future nuclear waste

dumps. (DT-0023 2)

Comment: We’re protecting the corporate interest and ignoring the safety of residents,

workers, fish, and the environment in future generations, and the reason why fish and other

animals are good for us to look at is because a habitat that’s not safe for fish is not safe for

humans. (DT-0035 2)

Comment: I write to oppose the issuance of an Early Site Permit to the North Anna nuclear

project. The proposed nuclear site would be detrimental both to the environment and to local

communities. (DW-0266 1)

Comment: I oppose the North Anna nuclear project. (DW-0305 2)

Comment: As a resident of Central Virginia, living in close proximity to the North Anna power

plant, I am writing to OPPOSE granting an Early Site Permit (ESP) to Dominion Resources to

build two new reactors at the North Anna nuclear plant in Mineral, Virginia. ... Too many

questions remain unanswered and too many problems remain unsolved for the NRC to grant an

ESP. (DW-0401 1)

Comment: Granting permit for new facilities, especially in a fast track manner, is deemed most

irresponsible for a government agency that should be working for the public’s interest. 

(DW-0406 4)

Comment: I oppose any plans by Dominion to build any new nuclear reactors at its North Anna

nuclear power station in Virginia. (DW-0593 1)
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December 2006 4-59 NUREG-1811, Volume II

Comment: I am strongly opposed to the approval of Dominion Power’s plan to build new

reactors at Lake Anna...Please deny Dominion Power’s permit application and preserve the

environment. (DW-0623 1)

Comment: As a resident of Richmond, Virginia and a citizen of the United States, I have many

concerns about Dominion’s ESP and the DEIS prepared by the NRC. I am significantly

concerned about the process the NRC has accepted to review new permits for nuclear reactors,

and see clearly that the issues NOT included for consideration (such as where toxic nuclear

waste will be stored) skew the process away from an honest discussion about the future of

nuclear power in the U.S. (DW-0630 1)

Comment: [T]he Early Site Permit is supposed to determine the feasibility of the two additional

reactors. But issues like specific radioactive waste management systems and long-term waste

storage plans have not been addressed. We would think this a necessary part of any nuclear

power plants feasibility study. (DW-1157 14)

Comment: Your charge charges you to protect, the citizens. In these times when people are

vulnerable and hunkered down and need you the most, you betray their trust. You have

returned to plunder the very people you are charged to protect, and I think somebody stands to

make a lot money. (DT-0006 5)

Comment: I’m sorry to say I believe that most people in the United States no longer trust our

government in their whole hearts. They’re fearful of one thing or another. They’re fearful of

bureaucrats. I pray that you are not bureaucrats abiding by the wishes on high in doing what

you think they want. (DT-0048 1)

Comment: We found some pretty serious problems. This is very serious in the EIS, and I’m

going to formally request that the NRC should redo the draft environmental impact statement

because of certain inadequacies. (DT-0001 5)

Comment: I think this draft environmental impact statement should be scrapped and the NRC

should start over and produce its own evaluation as required by law and under the rules that we

should be operating. (DT-0001 8)

Comment: I’m opposed to these reactors because this is an insensible national policy to build

our energy future without paying enough attention to conservation in our homes, in our

businesses, and in our transportation sector. (DT-0002 4)

Comment: The Nuclear Regulatory Commission is going to continue the process that it has

been going through for the last few years and continue to shove its regulatory responsibility off

onto the nuclear industry. (DT-0005 2)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-60 December 2006

Comment: I’d also like to talk a little bit about why exactly Dominion is spending this much

money if they have no intention of going forward with actually building plants, and I agree that

it’s a travesty from the perspective of the taxpayers because, as you know, taxpayers are

picking up half of the tab for Dominion to go through this process, the application process, not

only for the early site process, but you may or may not be aware that Dominion is also

simultaneously pursuing this combined operating license. They haven’t submitted the

application yet, but they’re already spending taxpayer money. They asked the Department of

Energy for $250 million to help them prepare this application and submit it and get it reviewed. 

So I agree that as a taxpayer, Dominion should not be spending this money, especially if they

have no intention of building these reactors. (DT-0016 2)

Comment: Too many lies for too many years have been told to us about nuclear power. I

cannot start believing you now. So my simple message is: don’t issue this permit. (DT-0017 4)

Comment: I ask everyone working for the NRC and for Dominion Virginia Power to join us

today, to do everything we can to stop our rush toward unparalleled catastrophe. (DT-0018 9)

Comment: The Sierra Club has opposed nuclear power but conditionally for many years dating

back to the ‘70s, but the Virginia Chapter of the Sierra Club, all 18,000 members we represent

here tonight, I’m the energy issues chair of the Virginia Chapter, and we took a resolution

several months ago opposing approval of additional reactors at Lake Anna or certification of that

site is suitable for new units. (DT-0021 1)

Comment: All the NRC has been able to determine [in its EIS] is that what they’re going to

place on this site will not be as dangerous as the two reactors that already exist there. 

Dominion does not even know the reactor design it wants to build. (DT-0033 1)

Comment: But I am outraged that Dominion is considering adding new reactors to Lake Anna. 

I love Louisa, and I know many people do because it’s beautiful. It’s healthy. It’s a great place

to raise kids. We’re in unchlorinated water. (DT-0037 1)

Comment: And I’m asking the NRC to refuse to grant this permit to Dominion. (DT-0037 5)

Comment: Please don’t build more reactors in this community. (DT-0037 8)

Comment: I’m speaking in opposition to the permit for two nuclear reactors. (DT-0038 1)

Comment: We oppose opening any further nuclear reactor power plants, including the two

proposed for North Anna, in my neck of the woods, and we oppose transporting nuclear waste

across the country through thousands of neighborhoods. We oppose Chernobyl on wheels. 

(DT-0041 4)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-61 NUREG-1811, Volume II

Comment: In the late ‘70s, early ‘80s, I was with Piedmont Alliance for Safe Energy. This was

our tee shirt: “safe energy alternatives.” That’s what we advocated, the wave of the future. 

Now I’m with People’s Alliance for Clean Energy. You still haven’t done it. Got you on it,

Dominion. Be a good corporate neighbor. Do it. (DT-0042 3)

Comment: We urge the Commission to take a stand against the construction of additional

nuclear power plants at the North Anna site. (DT-0047 1)

Comment: I would like to state my strong opposition to the proposed new reactors. 

(DT-0058 1)

Comment: Do not build more reactors. (DT-0058 5)

Comment: Please reconsider issuing an Early Site Permit to the North Anna nuclear project. 

(DW-0029 2)

Comment: Please reconsider issuing an Early Site Permit to the North Anna nuclear project. 

It would be wrong to issue this permit on the highly speculative grounds that it would not

adversely impact the environment. (DW-0050 2)

Comment: Please reconsider issuing an Early Site Permit to the North Anna nuclear project. 

The construction of the plant – including truck traffic, smog and building waste, will be

detrimental to the environment. (DW-0057 1)

Comment: In the same generation as two nuclear disasters (Three Mile Island and Chernobyl)

I cannot believe approval to build another nuclear plant is even being considered. This would

be the first license since Three Mile Island. We live in Fluvanna County, a neighboring county

of Louisa, where the proposed site is being considered. When we moved to Virginia, one of the

first things we did was to look up the location of nuclear plants and measure distance to be from

it when choosing a home site. (DW-0181 1)

Comment: I OPPOSE the expansion of nuclear power at the North Anna site for several

reasons [which are discussed in the relevant sections of this volume of the EIS]. (DW-0186 1)

Comment: I am writing to express my opposition to the granting of a new license for the

nuclear power plant in Louisa County, Virginia. (DW-0193 1)

Comment: Don’t expand North Anna. (DW-0195 2)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-62 December 2006

Comment: I am dismayed to read that the NRC concluded the draft of its Environmental

Impact Statement by saying “the environmental impacts would not prevent issuing and Early

Site Permit for North Anna.” I believe this to be unconscionable and unrealistic. (DW-0196 1

and DW-0744 1)

Comment: I’m urging the NRC to retract the Early Site Permit for the North Anna nuclear

project. There is no way such a facility will NOT adversely impact the environment. It will affect

the environment during construction, during power generation, and during the attempts to

dispose of and store the spent fuel. (DW-0198 8)

Comment: Constructing new reactors would be a danger to Virginia and its neighbors; it would

be bad for Virginia’s environment, bad for taxpayers, and bad for residential and commercial

ratepayers. (DW-0198 11)

Comment: I am writing you in regards to the permitting of new reactors at the North Anna site

in Virginia. I am vehemently opposed. (DW-0309 1)

Comment: Please [do] not grant Dominion Resources the site permit. (DW-0398 5)

Comment: Please don’t let Dominion Power or anyone else build a nuclear Power Plant. 

Although it has been many years since the disaster at Three Mile Island, it should still serve as

a lesson for all of us not to build such structures. (DW-0403 1)

Comment: They [Dominion Power] continue to spew out hazardous substances, like mercury. 

There are now 5 million Virginia residents living in areas below the EPA’s Clean Air Standards. 

Dominion Power is one of the key players in this FACT. (DW-0403 3)

Comment: Please, no new nuclear power plants for Virginia. I love this state. Help me protect

it for a very, very long time. (DW-0405 1)

Comment: I herewith voice my opposition to the proposal for expanding the North Anna Power

facility in Louisa County with two new nuclear reactors. (DW-0406 1)

Comment: I am writing to voice my opposition to the proposed two new nuclear reactors at the

North Anna power plant... As a Virginia resident living less than fifty miles from the North Anna

power plant, I ask you to please stop the new reactors. (DW-0408 1)

Comment: I believe that the recent Draft Environmental Impact Statement does not take into

complete consideration all of the unfortunate effects the new reactors may have on local and

national security and environmental health. (DW-0408 2)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-63 NUREG-1811, Volume II

Comment: I strongly oppose granting Dominion Virginia Power an Early Site Permit for

constructing any new nuclear plants at North Anna. (DW-0409 1)

Comment: We are writing to voice our dismay at the prospect of the granting of an ESP for two

new nuclear reactors at the North Anna, Virginia site. (DW-0424 1)

Comment: I am writing to inform you that I am against Dominion Power obtaining a permit to

expand nuclear energy operations in my State of Virginia. (DW-0424 1)

Comment: The purpose of an Early Site Permit (ESP) process is supposedly to “assess

whether a proposed site is suitable should the applicant decide to pursue a CP [construction

permit] or COL [combined license]” (DEIS, page xxi). Yet, this Draft Environmental Impact

Statement (DEIS) fails to consider or to fully acknowledge numerous environmental issues that

indicate that the North Anna site is not suitable for additional reactors. It does not appear that

the ESP really indicates anything about site suitability when analyses to determine environmental impacts or decisions on how to mitigate those impacts are put off to the COL stage or

are to be made by the state after the NRC has already granted the ESP. (DW-0437 1)

Comment: Please, Virginia doesn’t deserve more environmental degradation. She’s so

beautiful! Her people don’t deserve it either. (DW-0453 3)

Comment: [M]y simple message is just this: DON’T ISSUE THIS PERMIT. (DW-0614 11)

Comment: I’m especially concerned as a Dominion customer! Please don’t make me consider

taking my business elsewhere. (DW-0627 2)

Comment: The Dominion Web site, with regard to the existing North Anna facility, claims that:

“Continuing studies show that North Anna has very minimal effects on the environment.” 

Dominion’s idea of “very Minimal” is probably much higher-impact than most Virginians are

comfortable with. What is “very minimal” tripled? Two more plants would mean three times the

environmental impact. ... We should insist that Dominion bring their “very minimal” detriment to

our environment down to zero-impact for the power plant that they ALREADY have before even

considering granting permission to build more. ... To allow Dominion to proceed with their new

plans would be to REWARD them for harming our environment, however “minimally.” 

(DW-0628 1)

Comment: I am writing to register my opposition to Dominion Virginia Power’s application to

build a new reactor at their North Anna facility. ... It is my sincere hope the commission will

conclude a new reactor is not appropriate and will withhold its approval. (DW-0640 1)

Comment: VIRGINIA DOES NOT NEED NUCLEAR POWER (DW-0641 8)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-64 December 2006

Comment: I ask that you not grant an Early Site Permit at the North Anna Nuclear Power

Plant. ... Additional nuclear reactors at North Anna are not in the public’s interest. (DW-0653 1)

Comment: How can the NRC prepare an Environmental Impact Statement that finds that the

building of new reactors at North Anna would have no major adverse environmental effects? 

That is an unreasonable finding. (DW-0653 6)

Comment: Please DO NOT GRANT THE ESP to Dominion! (DW-0654 2)

Comment: I would like to register my objections to the proposed North Anna Nuclear Power

plant. There are so many reasons to oppose this plant. ... I strongly think that it is a bad idea to

build a nuclear power plant in North Anna. (DW-0729 1)

Comment: The proposed expansion of the North Anna Nuclear Plant in Louisa County, Virginia

is a terrible idea. (DW-0741 1)

Comment: Do not expand your nuclear plant in Louisa County, Virginia. (DW-0749 1 and

DW-0750 1)

Comment: I am writing to express my deep concern about the possibility of two new nuclear

reactors being at the existing North Anna nuclear power plant in central Virginia. I think this is

not the answer to our energy concerns, and ask that you do not grant a site permit for the

purpose of increasing the nuclear reactors at North Anna. (DW-0757 1)

Comment: My hope is you will hear what thinking, sensible people are saying and abandon

this project. (DW-0793 3)

Comment: Please DO NOT put any more nuclear reactors in Virginia. (DW-0798 1)

Comment: I am writing this to show my opposition for granting an Early Site Permit to

Dominion Resources for the construction of two new reactors. (DW-0802 1)

Comment: There is far too much risk to the environment in this proposal, Lake Anna is already

at risk, and the construction of this magnitude would only make the situation worse. 

(DW-0802 2)

Comment: I am writing in ADAMANT OPPOSITION to the granting of the Early Site Permit to

Dominion for the building of two new reactors at North Anna’s nuclear plant in Mineral, Virginia.

... I have to pledge my opposition to the granting of the ESP on behalf of community stability. 

(DW-0817 1)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-65 NUREG-1811, Volume II

Comment: I am against the construction of nuclear power plants at Lake Anna. I feel that

these plants are a risk to people and the environment. (DW-0821 1)

Comment: As a mother of two teenage children and a resident of southern Albemarle County,

I oppose the expansion of the nuclear facility at Lake Anna. The Lake Anna facility affects not

just Louisa County, but all of us. (DW-0822 1)

Comment: Please record this e-mail as a citizen’s new vote against the site permit, and the

unacceptably risky construction that it would facilitate. (DW-0825 2)

Comment: I am writing in OPPOSITION to new nuclear reactors at the North Anna nuclear

power plant. ... Please deny these permits. (DW-0827 1)

Comment: I am opposed to granting a preliminary permit for more reactors at North Anna

because the plan submitted for cooling the reactors is inadequate. (DW-0829 1)

Comment: If this meeting means anything whatever, you will not issue an early site permit to

dominion for further nuclear reactors to be located at North Anna. ... no more nuclear reactors at

North Anna – we are watching you closely! (DW-0830 1)

Comment: I am writing to express my belief that we do not need any more nuclear reactors at

Lake Anna. ...Please do not bring any more nuclear reactors to our area. (DW-0831 1)

Comment: I am also very concerned about the potential damage to the environment and to

wildlife and fish in the area of the lake. (DW-0832 3)

Comment: [I] am writing to voice my opposition to the building of additional reactors at the

North Anna site. I believe this would be environmentally, as well as economically, unsound.

(DW-0833 1)

Comment: I am writing to oppose the building of a new nuclear power plant at the North Anna

site. I don’t believe that all the issues concerning nuclear energy have been addressed with the

current power plant - waste disposal/storage, terrorism and security, health effects, and

evacuation and safety planning - just to mention a few. (DW-0834 1)

Comment: Please, please do not approve this. (DW-0846 4)

Comment: Please OPPOSE granting an Early Site Permit (ESP) to Dominion. Too many

questions remain unanswered and too many problems remain unsolved for the NRC to grant an

ESP. (DW-0851 1)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-66 December 2006

Comment: The Falls of the James Group Sierra Club (central, southern Virginia) is opposed to

the building of additional nuclear reactors in central Virginia and oppose an Early Site Permit

(ESP) for Lake Anna. (DW-0857 1)

Comment: I do not wish to see G.W. Bush and the DOE blow another 200 million of my tax

money to cover the cost of new permits for this proposed facility on behalf of Dominion Power. 

(DW-0900 3)

Comment: I am strongly against plans to build any new nuclear reactors at Dominion’s North

Anna nuclear power station in Virginia. (DW-0981 2)

Comment: I also have specific concerns about North Anna. (DW-0983 3)

Comment: [M]y husband, Louis, and I urge the U.S. Nuclear Regulatory Commission to DENY

Dominion’s application for an Early Site Permit. (DW-0998 6)

Comment: Please register my opposition to any plans by Dominion to build any new nuclear

reactors at its North Anna nuclear power station in Virginia. (DW-1042 1)

Comment: I urge the U.S. Nuclear Regulatory Commission to DENY Dominion’s application for

an Early Site Permit, and for Dominion to instead focus on finding alternative methods of

addressing expected increases in energy demands over the coming years. (DW-1042 4)

Comment: As a Louisa Virginia resident, please register my opposition to any plans by

Dominion to build any new nuclear reactors at its North Anna nuclear power station in Virginia.

[only slightly changed] (DW-1048 2)

Comment: As a Lake Anna fisherman, Virginia resident, and Dominion Power customer, I am

strongly opposed to any plans by Dominion Power to build any new nuclear reactors at its North

Anna nuclear power station in Virginia. (DW-1084 2)

Comment: This proposal is unacceptable for many reasons of safety and of health concerns of

the U.S. population. ... I am very much opposed to this nuclear reactor. (DW-1090 1)

Comment: This is not a well-conceived project for so many reasons. I do hope that those

entrusted with the decision will choose to deny permission to build additional reactors at the

Lake Anna site. (DW-1121 1)

Comment: I am writing to express my strong opposition to allowing another reactor at North

Anna. ...Please oppose this reactor permit. (DW-1151 1)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-67 NUREG-1811, Volume II

Comment: The Piedmont Environmental Council (PEC) continues to believe this permit is not

in the interest of the public and is unnecessary given the lack of need for additional electric

power generation in the Commonwealth. (DW-1157 1)

Comment: We would recommend that the two additional reactors at this site are inappropriate

for a multitude of reasons. We would ask that due to the numerous concerns mentioned in our

previous comments and those outlined in this submission, that the Early Site Permit for this

facility be denied. (DW-1157 16)

Comment: Do not issue a permit to Dominion Power for new nuclear reactors. (DW-1181 5)

Comment: Please consider my opposition to any plans by Dominion to build any new nuclear

reactors at its North Anna nuclear power station in Virginia. The site is unsuitable and many

important factors aren’t being considered in the decision whether or not to approve Dominion’s

application for an Early Site permit (ESP). Constructing new reactors would be bad for

Virginia’s environment, taxpayers, and residential and commercial ratepayers. I urge the

U.S. Nuclear Regulatory Commission to deny the ESP ... Please take my opposition to

Dominions plans into account. (DW-1233 1)

Comment: I am opposed to the granting of any early site permits to Dominion Nuclear North

Anna for future construction of additional nuclear power plants at North Anna Power Station. 

(DW-0832 1)

Comment: [T]he EIS is seriously deficient in a number of areas especially with regard to

socioeconomics and the human environment. There is a rather long list of important information

that is absent ranging from questions about impacts to striped bass to basic info about the

power plant’s cost, security, traffic, and plans for waste disposal. (DW-0594 3)

Comment: [A]n issue deferred in the consideration of the environmental impacts for this Early

Site Permit, the long-term management of wastes, re-emerges in my mind as a fundamental

environmental issue that must be considered if we are going to be realistic. Without considering

and largely solving this problem, a realistic consideration of likely environmental impacts must

recommend the denial of a request for site permitting for additional reactors. (DW-0685 15)

Comment: My only hope is that there’s a chance for the public to make a difference and get

this stopped. There is too much research on safety and waste to allow this to happen ... which

is not even being allowed to be presented. (DW-0181 6)

Comment: [We don’t need] the open invitation to whatever fanatics might find the site a source

of material for their efforts to terrorize the U.S. (DW-0967 3)
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-68 December 2006

Comment: Until we have found a way to safely dispose of waste heat without negatively

impacting the natural world around us, building additional reactors is simply not an acceptable

action. We must protect our world...it is the only one we have. (DW-0457 2)

Comment: I want to express my opposition to any new nuclear reactors at the North Anna

Virginia site. In addition to the problems of radioactive waste and reactor security, building new

reactors at North Anna will further damage Virginia's already stresses local and regional water

sources. (SE-0032 1)

Comment: I want to express my opposition to any new nuclear reactors at the North Anna

Virginia site. In addition to the problems of radioactive waste and reactor security, building new

reactors at North Anna will further damage Virginia's already stresses local and regional water

sources. (SE-0042 1)

Comment: The initial prospects of boiling the fish on the warm side of the lake; of flooding the

docks, piers, and boathouses on the cold side; of leaving everyone’s boat stranded without

water during prolonged draughts; and of deafening all of us with the loud 24/7 roar of cooling

tower fans have somehow faded into a chorus of amicable assurances and harmless impacts in

the face of your ESP hearings. (SE-0020 3)

Comment: I am writing to protest building a nuclear plant in this part of Virginia. (SW-0011 1)

Comment: I am opposed to the North Anna Nuclear Plant Early Site Permit being granted to

Virginia Dominion Power...The issue is not about how squeaky clean the plant looks to workers

and visitors, it is about the capacity of Virginia Dominion Power to protect all of our citizens

against radiation contamination and pollution. Without clean air and safe water supplies, we

humans will not survive. (SW-0021 3)

Comment: Spotsylvania County...adopted a resolution on February 8, 2005 which recited a

number of concerns about the Early Site Permit process, chiefly the demands of the proposed

project for Lake Anna water in light of the rapidly growing population in the Lake region and the

impacts on Lake residents and visitors of lowering the water level of the Lake. The County

objected to the ESP process. (SW-0017 80)

4.5 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.”
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

December 2006 4-69 NUREG-1811, Volume II

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Early Site Permits,

Standard Design Certifications, and Combined Licenses for Nuclear Power Plants.”

10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, “Requirements for

Renewal of Operating Licenses for Nuclear Power Plants.”

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 the Environment,

Part 1508. “Terminology and Index.”

54 FR 15386. “Early Site Permits; Standard Design Certifications; and Combined Licenses for

Nuclear Power Reactors.” Federal Register. April 19, 1989.

68 FR 40025. “Early Site Permits, Standard Design Certifications, and Combined Licenses for

Nuclear Power Plants; Proposed Rule.” Federal Register. Vol. 68, No. 128. July 23, 2003.

68 FR 55905. Nuclear Energy Institute; Denial of Petition for Rulemaking.” Federal Register.

Vol. 68, No. 188, September 29, 2003.

68 FR 57383. “Nuclear Energy Institute; Denial of Petition for Rulemaking.” Federal Register.

Vol. 68, No. 192. October 3, 2003.

71 FR 12782. “Licenses, Certifications, and Approvals for Nuclear Power Plants.” 

Federal Register, Vol. 71, No. 48. March 13, 2006. 

Atomic Energy Act. 42 USC 2011, et seq.

Clean Water Act (also referred to as the Federal Water Pollution Control Act). 33 USC 1251,

et seq. 

Coastal Zone Management Act (CZMA). 16 USC 1451, et seq.

Dominion Nuclear North Anna LLC (Dominion). 2006. North Anna Early Site Permit Application

– Part 3 – Environmental Report. Revision 9, Glen Allen, Virginia.

Energy Policy Act of 2005. Public Law 109.58.

Energy Reorganization Act of 1974. 42 USC 5851, et seq.

National Environmental Policy Act of 1969 (NEPA). 42 USC 4321, et seq.
ESP Process, NEPA Compliance, and Comments Supporting or Opposing the ESP

NUREG-1811, Volume II 4-70 December 2006

Nuclear Energy Institute (NEI). 2005. Letter to NRC regarding environmental reviews for a

combined license application, February 10, 2005.

Private Fuel Storage, LLC, CLI-02-25, 56 NRC 340. 2002.

San Luis Obispo Mothers for Peace v. NRC, 449 F 3d 1016 (9th Cir 2006).

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

Reviews for Nuclear Power Plants. NUREG-1555. Vol. 1. Office of Nuclear Reactor

Regulation, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2004. Processing Applications for Early Site

Permits. RS-002, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2005a. Safety Evaluation Report for an Early

Site Permit (ESP) at the North Anna ESP Site. NUREG-1835. Accession No. ML05160246. 

Available at http://www.nrc.gov/reactors/new-licensing/esp/north-anna.html.

U.S. Nuclear Regulatory Commission (NRC). 2005b. Letter to NEI regarding environmental

reviews for a combined license application, July 6, 2005.

U.S. Nuclear Regulatory Commission (NRC). 2006b. Supplement to the Final Safety

Evaluation Report for an Early Site Permit (ESP) at the North Anna ESP Site. September 2006. 

Accession No. ML062210441.
December 2006 5-1 NUREG-1811, Volume II

5.0 Comments Outside the Scope of the EIS

As set forth in 10 CFR 52.17(a)(2), an environmental report (ER) submitted as part of an early

site permit (ESP) application need not include an assessment of the benefits (e.g., need for

power) of the proposed action. Pursuant to 10 CFR 52.18, an environmental impact statement

(EIS) prepared in connection with an ESP application also need not include such an

assessment. Similarly, an ESP ER and EIS need not assess alternative energy sources and

cost of power. If these issues are not included in the ESP review, then they must be evaluated

during the environmental review performed in connection with a construction permit (CP), an

operating license (OL), or a combined license (COL) application. In addition, as set forth in

Volume II, Section 2.2 of this EIS, the position of the U.S. Nuclear Regulatory Commission

(NRC) is that malevolent acts, including terrorism, are beyond the scope of a National

Environmental Policy Act (NEPA) review. Comments received in response to the release of the

North Anna ESP Draft environmental impact statement (EIS, also referred to by commenters as

DEIS) and the Supplement to the Draft EIS (SDEIS) included many related to these issues,

which are outside the scope of the ESP review.

The NRC is not authorized to promote nuclear power, nor does the NRC, through its

environmental reviews or otherwise, have any role in setting policy with respect to encouraging

or discouraging development of any particular source of energy. Therefore, comments

supporting or opposing nuclear power are outside the scope of the NRC’s environmental

review. Several comments found fault with provisions in the NRC regulations. The NRC’s

preparation of an EIS on a requested licensing action, however, does not involve changes in

NRC regulations, nor does the request for comments on an EIS afford an opportunity for such

changes. Rather, the appropriate method to request a change to an NRC rule is through a

petition for rule making under 10 CFR 2.802. Accordingly, comments on the adequacy of NRC

rules and regulations are outside the scope of this EIS. A more detailed description of the areas

that are outside the scope of the environmental review has been added to the Executive

Summary in Volume I and the Introduction to Volume II of this EIS.

Comments on safety issues are generally outside the scope of the environmental review

because the NEPA process focuses on environmental impacts of the proposed action rather

than on issues related to safety. Safety issues become important to the environmental review

when they could potentially result in environmental impacts, which is why the environmental

effects of postulated accidents are considered in the EIS. The NRC has codified the regulations

for developing an EIS separate from the regulations for reviewing safety issues during the ESP

review. The regulations governing the environmental review are in Title 10 of the Code of

Federal Regulations (CFR) Part 51, referenced in 10 CFR 52.17(a)(2) and 52.18, and the

regulations covering the safety review are in 10 CFR Part 52. For this reason, the

environmental review is distinct and separate from the safety review. Because the two reviews

are separate, emergency planning and other safety issues are considered outside the scope of

the environmental review, just as the environmental issues are not considered as part of the
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-2 December 2006

safety review. Emergency preparedness and other safety issues are addressed in the NRC

Safety Evaluation Report (SER) (ADAMS Accession No. ML052710305) for the North Anna

ESP site, which was issued in September 2005 and supplemented in September 2006

(Accession No. ML063170371). The SER is available on the NRC’s website at www.nrc.gov. 

Safety comments received during the environmental review were forwarded to the appropriate

NRC staff for consideration.

This chapter is organized into the following sections:

& Section 5.1: Alternative Energy Sources

& Section 5.2: Cost and Need for Power

& Section 5.3: Emergency Preparedness

& Section 5.4: Safety

& Section 5.5: Security and Terrorism

& Section 5.6: NRC Oversight

These sections are followed by Section 5.7, which contains Comments in Support of Nuclear

Power (Section 5.7.1) and Comments Opposed to Nuclear Power (Section 5.7.2). Section 5.8

contains Miscellaneous Out-of-Scope Comments. Section 5.9 lists references.

Comments in this chapter are considered out of scope of the environmental review; therefore

comments are not addressed individually; rather, a general response is presented at the

beginning of each section, followed by applicable comments. Comments received on the

Draft EIS are listed at the beginning of each section, followed by comments concerning the

SDEIS. When a comment submitted on the Draft EIS was repeated exactly, or almost exactly

on the SDEIS, the comment is listed once and shown with both the Draft and SDEIS comment

numbers.

5.1 Alternative Energy Sources

This section lists comments that discuss a need to move toward alternative energy sources

such as solar and wind power, or to implement conservation of energy efforts. It also lists

comments supporting the use of nuclear energy rather than alternative sources because the

alternatives are not able to supply baseload capacity or because of other environmental

concerns. The subjects of these comments have been determined to be out of the scope of this

EIS. If Dominion applies for a CP or a COL in the future, the issue of alternative energy sources

will be evaluated at that time, as required to satisfy NEPA.

General Response: The NRC determined and informed prospective ESP applicants by letter

that evaluation of alternative energy sources did not need to be covered in an application for an

ESP. This determination is included on the NRC’s web site at
Comments Outside the Scope of the EIS

December 2006 5-3 NUREG-1811, Volume II

http://www.nrc.gov/reactors/new-licensing/esp/generic-esp-issues.html. NRC’s position on this

issue is further explained in a proposed change to 10 CFR Part 52 that was published in the

Federal Register on July 3, 2003 (68 FR 40025, 40028-40029). Dominion chose not to include

an analysis of energy alternatives in its ESP application and energy alternatives are not

considered in this EIS. If Dominion North Anna LLC (Dominion) is granted an ESP and

subsequently elects to apply for (1) a COL to construct and operate new nuclear units at the site

under the procedures at 10 CFR Part 52 Subpart C or (2) a CP under the procedures at

10 CFR Part 50, then Dominion would be required to include an analysis of energy alternatives

in the subsequent application. In conjunction with its evaluation of the CP or COL application,

the NRC would prepare an EIS that complies with NEPA and applicable NRC regulations

regarding the proposed action (i.e., the CP or COL). The staff would consider and include in the

EIS a discussion of energy alternatives to construction of new nuclear generating units at the

ESP site.

With respect to energy conservation, the NRC considers such matters in connection with the

need for power. Because 10 CFR 52.17(a)(2) explicitly states that an applicant need not

assess the need for power in its ER, Dominion did not do so in its ER, conservation is not

evaluated in the EIS, and the comments on conservation are out of scope.

Individual comments are organized below by general alternative energy type(s) or topic with

comments on the Draft EIS listed first and comments on the SDEIS following for each section:

Renewable Energy Sources

Comment: And I think the government could probably change the energy policies if they

wanted to, and there is a lot of things I think they could change, especially the kind of energy

that we use. And I think the best kinds are probably solar, hydro, and wind. (DT-0008 3)

Comment: The DEIS fails to consider alternative sources to nuclear energy for the generation

of electric power by Dominion at North Anna--Renewable sources of energy such as wind, solar,

and small hydro are available in Virginia and could provide electric power generation with far

smaller environmental and human health impacts. (DT-0034 5, DW-1163 4)

Comment: In its application for an ESP, Dominion failed to properly assess alternatives to its

proposed action including the utilization of renewable energy to generate electricity. There are

three favorable alternatives which could make additional nuclear reactors at North Anna

unnecessary: wind energy, solar energy, and small-scale hydropower. (DT-0034 17)

Comment: A clean, safe, renewable energy resource might be solar or wind power.

(DT-0041 2)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-4 December 2006

Comment: Research the sustainable alternatives of wind, solar, biomass, and many others. 

(DW-0173 4)

Comment: For the billions you waste on nuclear pollution, you could build windmills and solar

cells that would power the nation. (DW-0180 4)

Comment: Please consider putting your efforts toward clean energy. (DW-0192 4)

Comment: I urge you to work for the development of safe, renewable, environmentally-friendly

methods of electricity production such as wind power, solar power, and geo-thermal energy.

(DW-0193 4)

Comment: The only safe nuclear power plant is the sun - go solar! (DW-0195 6)

Comment: Dominion and all utilities should put all their resources to work developing

alternative and renewable forms of energy like wind or biomass. (DW-0198 10)

Comment: I live in a solar powered house including electricity so I know that technology works

with minimal environmental impact. (DW-0309 2)

Comment: NO to nuclear power - YES to renewable energy! (DW-0395 2)

Comment: Solar and wind provide clean and safe energy. (DW-0398 2)

Comment: There are real, harmless alternatives, such as solar energy. (DW-0403 2)

Comment: I am sorry that Dominion seems to only want to provide energy from coal and

nuclear power. I would like to see them promote other renewal energy sources such as solar,

wind, etc. (DW-0407 4)

Comment: Additional nuclear reactors are not needed; renewable energy sources can

accomplish as much and more than nuclear generated energy has or ever will. And with none

of the lethal consequences of the flawed nuclear technology. (DW-0411 4)

Comment: There are less dangerous ways of obtaining power from wind and sun energy,

which is ever abundant. (DW-0412 2)
Comments Outside the Scope of the EIS

December 2006 5-5 NUREG-1811, Volume II

Comment: More study needs to go into alternative energy sources such as wind power. There

is a lot of wind on the mountains that can be harnessed...Natural gas is plentiful in the coal

mines of West Virginia. Methane gas from landfills and decomposing cow manure can be

harnessed for energy to run the electric generators. We need to study all the options before

putting our area into a check mate situation. (DW-0413 6)

Comment: Today's technology can supply other alternatives, in fact many. (DW-0421 2)

Comment: The most patriotic thing our country can do to meet our energy needs is to commit

our nation's best minds to developing highly effective renewable energy technologies. This

would free us from dependence on other countries for fuel supplies, and would keep our own

citizens healthy by reducing air pollution and possible increased radiation exposure. Americans

are worth that effort. (DW-0426 19)

Comment: Instead of expanding our nuclear presence, we should explore, properly fund and

mandate renewable energy sources. (DW-0616 3)

Comment: Wind turbines and solar cells are more efficient, nonpolluting sources of energy

being used successfully. (DW-0641 7)

Comment: We should focus on renewable sources of energy, without hesitation, such as wind

and solar, and leave nuclear energy as a dirty part of our past. (DW-0654 4)

Comment: In Spain they use windmills to provide much of the electrical power. This is

cheaper, safer, and already being used in parts of California. We do not need to risk the use of

nuclear power when there are cheaper and better alternatives for generating electricity. 

(DW-0495 2)

Comment: Instead of nuclear, why not partner with renewable energy companies or start your

own renewables division. I choose to get my power, not from Dominion, but from Pepco

because they offer 100% renewable wind energy. It's renewable and there's no waste--you

can't beat that! (DW-0700 2)

Comment: We can easily meet our energy needs with energy efficiency and renewable energy

programs. (DW-0743 3)

Comment: We have renewable and clean forms of energy, such as wind and solar power.

...Be a leader in corporate development in renewable energy. (DW-0749 2 and DW-0750 2)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-6 December 2006

Comment: I would prefer that Dominion meet its power capacity needs using clean energy like

wind or biomass. In reevaluating the ESP and the EIS, the NRC should urge Dominion to

consider other alternatives to an expensive nuclear plant. (DW-0772 5)

Comment: If Dominion wishes to produce more energy, it should do so by building wind farms

in places like Highland County. If we want to leave our children a world worth inhabiting, then

we must invest in renewable energy now. (DW-0777 3)

Comment: There are other forms of energy that deserve our attention. (DW-0780 3)

Comment: Our country needs to be looking at sa[f]e, sensible and sustainable energy sources. 

Nuclear at this time is certainly none of these. (DW-0793 2)

Comment: Wind and solar energy need to be developed... Clean, safe energy is available. 

We need to use it. (DW-0797 2)

Comment: It is time to use other non-fossil fuel energy alternatives, such as wind, solar power,

and others. If money were allocated to this research before, we would already be able to

benefit from better methods of producing energy. (DW-0811 4)

Comment: I hope the NRC will require Dominion Nuclear North Anna to withdraw their

application and consider other alternative electricity generating technologies before

endangering the large, and growing, population of this area. (DW-0832 5)

Comment: Wouldn't the investigation into more sustainable energy be a more prudent

approach? (DW-0834 2)

Comment: We need to start investing in clean renewable energy - not nuclear!! We need to

leave a cleaner earth for our children's, children's children. (DW-0897 2)

Comment: Dominion Virginia Power should be using its resources to develop alternative

energy sources. (DW-0902 2)

Comment: There are cheaper and less controversial energy sources that are not being fully

investigated. (DW-0955 2)

Comment: Dominion [should] instead focus on finding alternative methods of addressing

expected increases in energy demands over the coming years. (DW-0998 7)
Comments Outside the Scope of the EIS

December 2006 5-7 NUREG-1811, Volume II

Comment: I am convinced that we have to start searching for alternative fuels to meet our

energy needs. We cannot endanger our lives by a fuel source that is a proven danger. I urge

you to focus instead on developing alternative fuels. Even if we had to make sacrifices for

them, it would be worth it in peace of mind and in safety. (DW-1042 3)

Comment: Focus your energy of funding and developing renewable sources of energy that

don't leave a radioactive or wasteful legacy. (DW-1069 4)

Comment: Why don't you invest in building solar energy facilities and give lots of people work

and generate a safe renewable source of energy in much less time that it takes to build nuclear

plants. (DW-1090 2)

Comment: The technology exists for the United States to switch from dirty energy to solar,

wind and water generated power. Why would we want to continue to use nuclear power when a

cleaner, safer alternative is available? ...I pray for this nation and it's leaders to set a new

standard in global energy production. Let's use the FREE energy the sun, wind and water

provide, update our power grid to incorporate solar power, and begin taking our environmental

safety and health seriously. Stop the madness! Go Solar!! (DW-1166 2)

Comment: I urge the US NRC to focus on finding alternative methods for addressing the

increasing energy demands. (DW-1233 2)

Comment: I would prefer that Dominion meet its power capacity needs using clean energy like

wind or biomass. In reevaluating the ESP and the EIS, the NRC should urge Dominion to

consider other alternatives to an expensive nuclear plant. (DW-MM1 10)

Comment: Safer, cheaper alternatives to new nuclear generating capacity are not being

explored as part of the Early Site Permit process. The ESP application doesn't consider what

the effect might be on the cost of power in Virginia, or the need for new generating capacity.

(DW-MM3 3)

Comment: Safer, cheaper alternatives to new nuclear generating capacity are not being

explored as part of the Early Site Permit process. (DW-MM4 7)

Comment: Renewable energy sources such as wind power create more jobs per investment

dollar than does nuclear power. Those jobs also require less specialized education, increasing

the chances that local workers will be able to secure the jobs rather than requiring outside

experts. (DW-MM4 11) 
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-8 December 2006

Comment: In light of these concerns [stated previously], we urge ... Dominion to instead focus

on finding alternative methods of addressing expected increases in energy demands over the

coming years. (DW-MM4 18)

Comment: It is past time to switch to safe, sustainable alternative energy sources -- oil and

nuclear energy are filthy, non-sustainable sources that wreak havoc with the health of all beings

on this planet and the planet itself. (DW-0891 2)

Comment: For once let us consider the harmfulness to our environment. The way things are

going there will be nothing left for future generations to enjoy. Let's work on find[ing] another

way to work on increasing energy demands. (DW-0493 3)

Comment: The proposed action is a major Federal action significantly affecting the quality of

the human environment; therefore, the NRC must consider alternative sources to nuclear

energy for the generation of electric power by Dominion at North Anna before granting an ESP.

Renewable sources of energy such as wind, solar, and small hydro are available in Virginia and,

if implemented, would allow increased electric power generation with smaller environmental and

human health impacts. (DW-1163 16)

Comment: Nuclear power is promoted to the public as safe, clean and cheap and yet

information that would enable them to understand the specifics of that claim is not provided in

this proposal and that information is key if the public is to understand the merits of this proposal

especially as compared to other power-generation choices such as coal, solar and wind. 

(DW-0594 7)

Comment: Please work towards sustainable and fiscally responsible energy technology. 

(DW-0408 10)

Comment: Please SPARE OUR LIVES and spend OUR (taxpayer) money on safe energy

alternatives. (DW-0196 7 and DW-0744 7)

Comment: Our country has developed technologies that are safer and more enduring in the

long term. Let's use them. (DW-0197 2)

Comment: I am the executive director of the, “environmental crisis center,” and our agenda is

having clean energy, now! (DW-0177 1)

Comment: I would urge you to be good corporate citizens. Stop feeding at the taxpayer

trough. Take that money and look at renewable energies. (DT-0042 1)
Comments Outside the Scope of the EIS

December 2006 5-9 NUREG-1811, Volume II

Comment: What will happen if Virginia Power is able to build a nuclear power plant? Our

children will be left to find out or then again maybe they won't. There are other ways to create

energy without harming our environment. (DT-0057 3)

Comment: In response to the Dominion VP's remarks: Why is there no mention of alternative

energy sources? Why just mention natural gas? Imagine if the amount of money put into this

NRC review was put into subsidizing solar applications or research on other alternative energy

possibilities in the area. (DT-0062 1)

Comment: The amount of money spent on nuclear research is $74 billion versus $14 billion on

all renewable energy research. I would like to install solar panels in my home, but the cost is

prohibitive. Until more citizens invest in these technologies, the cost will probably not come

down, so I am considering going into debt for it. (DT-0062 2)

Comment: If we shut down nuclear today, we would not have return to living in dark caves

rubbing sticks together to start fires. When we turn to wind and solar for our electricity, the

power companies will still make profits. People will still be employed. Taxes will still be paid. 

(DT-0018 7)

Comment: [A]ll energy technologies have their pros and cons. Life cycle emissions for wind

and solar are actually higher than nuclear. Furthermore, they ignore that solar produces about

the same amount of toxic waste per kilowatt hour produced as nuclear does. But this is waste

that never decays or becomes less dangerous. ...I still think we should develop renewables and

do everything we can to use them, but they are a part of a balanced energy mix, not the entire

solution, just like nuclear. (ST-0012 8)

Comment: [T]he draft shows no real consideration of renewable energy and demand-side

management. (ST-0036 9)

Comment: How much [energy] can we get from wind? What's the impact of wind going to be

on the bald eagle population when they fly into a turbine which they've had a problem with at the

turbine farm in West Virginia of birds flying into the turbines? (ST-0023 4)

Renewable Energy Sources and Conservation

Comment: Our government and our power production companies should instead establish

aggressive policies for energy conservation and clean renewable energy production. 

(DT-0047 8)

Comment: These resources would be better directed to alternative energy and energy

conservation efforts. (DT-0054 6)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-10 December 2006

Comment: Would it not be a better solution to be more conservative and efficient in the use of

the resources that we have and try safe wind and solar alternatives? (DW-0398 4)

Comment: Dominion Power should be encouraging conservation and passive solar

construction methods. They should also be exploring wind power. (DW-0576 2)

Comment: I’m asking Dominion to please pour your resources into sources of energy that are

really clean and safe and efficient. And I’m asking myself and citizens of Louisa to be loud and

consistent in our demands for safe power and in cutting back our own energy use and in our

own experiments with alternative power. (DT-0037 6)

Comment: As a taxpayer of our country and a shareholder in Dominion, I’m dismayed to hear

Dominion say that they're going to go ahead and spend hundreds of millions of dollars not to

build the plant. That’s unbelievable. This money could be well spent on many positive ways to

either conserve energy, energy efficiency, or to build a plant which is actually going to produce

energy. But here he says we're not building a plant. We’re just going to take your money and

spend my shareholder money not to do it. Dominion has many economic, environmentally, and

acceptable ways to produce or save energy. Let them do that, and let them leave us in peace.

(DT-0015 2)

Comment: I want for energy providers to educate the public on ways to reduce our use of

resources and to provide safer, cleaner options like solar, biomass and wind energy. 

(DW-0165 7)

Comment: Although our population is growing, future anticipated electrical power demands

can be met with more judicious per capita consumption and development of smaller distributed

electrical generation plants using alternative energy sources. (DW-0406 2)

Comment: I urge you to be wise for future generations and promote conservation, solar, and

wind alternatives. (DW-0429 4)

Comment: I urge that every effort be made to save energy through comprehensive

conservation plans for that region, and then the use of sustainable, clean power sources [can]

be pursued. (DW-1140 3)

Comment: Market-based programs for Energy Star products and green building should be

developed as part of our energy portfolio. These programs would render unsafe and expensive

proposals such as this one unnecessary. (DW-0593 4)

Comment: We can easily meet our energy needs with energy efficiency and renewable energy

programs. (DW-0743 3)
Comments Outside the Scope of the EIS

December 2006 5-11 NUREG-1811, Volume II

Comment: There is a better and less expensive way to solve our energy needs. Major

sacrifice and simple conservation discipline in every city, town and county in Virginia, as well as

the use of renewable energy would eliminate the need to build more nuclear power plants and

make all Virginians safer. (SW-0021 6)

Comment: Wind power and other renewables along with energy efficiency and conservation

and co-generation are much more cost effective and can be deployed much faster. (ST-0008 6)

Comment: If as much taxpayer money were put into research on renewable energy sources

and on increased energy efficiency and conservation as has been put into subsidizing the

nuclear industry, we would not be facing the increased energy needs that call for more nuclear

reactors. (SE-0010 2)

Conservation

Comment: I think it's in our hands as well, as citizens, as sharers of the earth to come up how

we live our life. We need to practice conservation. (DT-0026 2)

Comment: California was able to eliminate the construction of many nuclear power plants

years ago through conservation programs. (DW-0042 2)

Comment: What about conservation efforts, where are they? We have not [given] nearly the

attention here that is needed. (DW-0379 2)

Comment: The U.S. needs to implement conservation measures that will make the country a

leader in conservation technology...we need to support the conservation measures with

incentives and support for research. Investments in these areas will reap immediate and

long-term benefits for us all. (DW-0537 2)

Comment: We are...ready for technologies of efficiency. How about those standards for new

air conditioning and heat pump efficiency that President Bush removed early in his first term. 

They should be reinstated...Our current policies actually seem to encourage more demand for

energy, when it should be encouraging more efficient ways to use what generating capacity we

already have. (DW-0577 3)

Comment: First and foremost, this country should not invest a penny more in power generation

until it has a conservation plan that is equally invested in. (DT-0058 2)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-12 December 2006

Comment: To those who would argue that there are not enough non-polluting electricity

generating options to support the population demanding electricity, I respond that the population

should be reduced to the level that can be supported by sustainable non-polluting sources. 

(DW-0648 3)

Comment: I believe that Dominion would be better served by working to help its power users

reduce demand than to construct additional generating capacity at this time. I also think that an

investigation of the potential for tidal hydro generating systems in the Chesapeake Bay and

Virginia coastal areas would be a much better use of financial resources, although

environmental concerns would also have to be carefully addressed. (DW-0832 4)

Comment: We also need to embrace conservation, continue to develop our renewable energy

supplies and employ safe, clean nuclear energy as a continued part of balanced energy mix. 

(ST-0020 9)

Comment: I am asking all of us to cut back on our energy use, and be careful what we do. 

(SW-0014 2)

Desire for Safer Options

Comment: This antiquated power source has seen its day and the world needs to rid itself of it

and seek safer alternatives. (DW-0655 3)

Comment: We must find a different solution to meet Virginia's energy needs, one that does not

risk the health of future Americans. (DW-0426 16)

Comment: We need to be putting our funding and planning into alternative energy and

conservation--not reviving the dangerous and uneconomical industry. (DW-0409 5)

Comment: Please. It just is not worth the risk. Our country has developed technologies that

are safer and more enduring in the long term. Let's use them. (DW-0405 2)

Comment: We need to find other energy sources. Nuclear power is NOT it...I want my money

redirected for safer energy sources. (DW-0404 3)

Comment: Safer, cheaper alternatives to new nuclear generating capacity are not being

explored enough. (DW-1088 2)

Comment: It is time for humankind to figure out how to be creative, to manufacture energy that

causes no harm to the environment. Coal, gas, wind, solar are all safer to the environment than

nuclear. (DW-1089 3)
Comments Outside the Scope of the EIS

December 2006 5-13 NUREG-1811, Volume II

Comment: Safe, clean, renewable energy resources are available. Now Is the time to start

developing them and stop relying on an energy source that is unsafe in the long run. 

(SE-0032 2)

Energy Independence

Comment: What about alternative sources of energy? Well, for a fact, we have heard that

Dominion has already invested in what's called liquified natural gas. I wouldn't doubt that if

Dominion found the right spot to build a wind farm with windmills that could produce enough

energy and make a profit they would do it. Anyway, if all of the energy initiatives were to

succeed, you've got to ask yourself the question will America be better off. Will we get closer to

the goal of financial or -- excuse me -- of energy independence? (DT-0011 3)

Comment: We've heard a little bit about energy independence and the idea that nuclear power

is going to get us off foreign oil, and I personally believe we shouldn't just get off foreign oil, but

maybe oil in general, and if more of us were riding bicycles we could help do that. (DT-0016 4)

Comment: Nuclear energy helped back oil out of the electricity sector in the 1970s and the

1980s by essentially replacing oil in electric generation. We think it can do the same thing in the

transportation sector by making hydrogen to operate fuel cell vehicles, another way to make us

less dependent on foreign sources of oil. But nuclear power is not going to make a meaningful

dent in our oil consumption. According to, again, the United States Department of Energy

figures here, in 2003 the percentage of oil that was used in the United States on generating

electricity, 2.1 percent, and that’s total. Not all of that was imported even. That compares to

70 percent of all petroleum use in this country on transportation. So if you’re interested in

achieving energy independence, nuclear power is not going to get us there. (DT-0027 6)

Comment: The nation is now facing aging reactors needing retirement. ...Any new reactors

built in the next ten years would merely replace aging reactors, doing nothing to reduce our oil

dependence. (DW-0641 4)

Comment: Just about all of the electricity that has been added to the United States grid in the

last several years is being generated by natural gas...There has been tremendous price

volatility in the price of natural gas... in many parts of the country is that industries that depend

on natural gas are actually leaving the country. (DT-0004 4)

Comment: We believe that the U.S. should become self-reliant for energy sources and not be

dependent on foreign oil, but we do want to promote the wise and safe use of nuclear energy

and not have the impact of the new nuclear reactors destroy Lake Anna in the process. 

(ST-0014 1) and (SE-0022 1)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-14 December 2006

Energy Technology 

Comment: Industry advocates are promising the safety, cost and oil-replacing potential of

generation-after-next “pebble-bed” reactors, but these designs still need years of research and

development. (DW-0641 3)

Comment: There are better answers. Technology and design advances have opened up a

new way to organize our energy grid that encourages high-quality energy and healthy markets. 

Small natural gas turbines combined with better grid design can capture much of the wasted

energy by distributing clean generating capacity closer to consumers. Instead of putting one

massive power plant tens of miles from customers and taking five years to build, micro turbine

powerplants of any size can drop in incremental capacity onto the grid where it is needed, when

it is needed. Since they are affordable, they eliminate the need for market-corrupting and

deficit-worsening subsidies. (DW-0641 6)

Comment: And let's move on to fusion technology as quickly as possible. (DT-0063 8)

EIS-Specific Alternative Energy Comments

Comment: The list of alternatives in Section 8 should include the following:

a. Life extension of the existing two North Anna reactors 

b. Retirement of the existing two North Anna reactors. 

c. Constructing the new reactors and radioactive material storage underground to 

increase security against an air attack

d. Non-nuclear generation sources. (DW-0438 170)

Comment: The list of alternatives did not include life extension of the existing two plants or

retirement of those plants. (DW-0594 9)

Comment: [T]he alternative section of the EIS (in contrast to that of an ER) needs to assess

other alternatives beyond siting such as renewables, demand side management, repowering of

Units #1 and #2, etc. (SE-0045 38)

Comment: [W]e don't feel that NRC has adequately considered the alternatives to this whole

process which they are legally required to do...According to National Renewable Energy

Laboratory data that was actually published in a study by the Virginia Center for Coal and

Energy Research in 2005 actually concluded from that data that renewable energy, I mean

solar, wind onshore and offshore, geothermal heat pumps and possibly some advanced

hydropower could actually meet Virginia's electricity needs in the coming two to three decades

completely. ...The benefit is there's no radioactive waste, there's no risk from a plant having a
Comments Outside the Scope of the EIS

December 2006 5-15 NUREG-1811, Volume II

problem or being intentionally sabotaged. ...they should really seriously look at alternatives to

actually building more reactors in the first place. (ST-0005 7)

Comment: Dominion Power could resolve these issues [from water use through evaporative

cooling]...by investing in renewables and in energy conservation and efficiency and

conservation. (SE-0035 4)

Comment: It’s obvious the enormous amount of time, money, and energy that’s been put into

what Dominion says is just one option, and I’m wondering how much is being spent to seek

alternatives. This could be an opportunity for Dominion to be an innovative force in seeking true

clean energy. (DT-0044 1)

Comment: A nuclear reactor will deplete valuable water resources from the Lake Anna area. 

Why not go for renewable energy and consider the common good to achieve the same end? 

(SE-0031 1) (SE-0043 1)

Other Comments

Comment: The Kyoto Protocol limits the amount of carbon dioxide that can be put into the

atmosphere because of the concerns of the impact of carbon dioxide on global temperatures. 

Again, the U.S. is not participating. If the United States does choose to participate, then once

again we need an energy source that does not involve putting carbon dioxide into the air ... So

there's a growing awareness around the world that if we're going to be generating power in an

environmentally responsible way, nuclear is one of the options. (DT-0004 5)

Comment: Page 2-13 line 31 discusses that severe weather may occur in the area. These

weather events can contribute to power outages and disruption of road access. Increased

generation of power from a few large power plants in one location does nothing to improve

regional system transmission stability whereas decentralized generation would offer that benefit. 

(DW-0438 26)

Comment: Nuclear generation of energy causes more global warming than other energy

generation methods. More green house gases are released. (DW-0151 2)

Comment: Nuclear energy production causes more green house gasses than other energy

production methods. We are already seeing the results of global warming. (DW-0384 2)

Comment: This whole process [nuclear] seems far better to me than continuing to use fossil

fuels which pollute the atmosphere and prevent the United States from meeting the Kyoto

protocols. Russia has agreed to meet these protocols and they have a much dirtier atmosphere

than we do. (DW-1007 7)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-16 December 2006

5.2 Cost and Need for Power

Section 5.2 lists comments addressing cost and/or need for power. Commenters expressed the

opinion that nuclear power is expensive, and they were surprised that Dominion would spend

the money required to build new plants. They expressed concern that tax payer dollars would

be spent on this project, and that nuclear power is more expensive than other options. There

were comments expressing frustration that nuclear power is being subsidized by the

government. Concerns were expressed about the costs of mining, handling, using and storing

radioactive materials, and the long-term social and health costs in communities interacting with

these materials.

General Response: The regulations in 10 CFR 52.17 and 52.18 specify, respectively, that the

ER and EIS prepared for an ESP need not include an assessment of the benefits (e.g., need for

power) of the proposed action. Cost of power is part of the assessment of the need for power. 

Dominion chose not to address these matters in its ER, pursuant to 10 CFR 52.17(a)(2). 

Accordingly, these issues are outside the scope of this EIS. Nonetheless, these issues will be

reviewed at the CP or COL stage because they were not reviewed at the ESP stage. Further,

the NRC does not have any role in setting energy policy or otherwise providing funds for energy

research or development, nor do NRC environmental reviews implement energy policy. 

Accordingly, these issues are also outside the scope of this EIS.

Cost of Power

Comment: Nuclear power is a very bad investment. The Department of Energy itself reports

that the average nuclear power plant built in the United States ran 400 percent over budget ...

Nuclear energy has been historically and continues to be a terrible investment. (DT-0005 1)

Comment: That nuclear power is cheap is a fiction. It's cheap at the meter, but if the tax

subsidies are included, it is more expensive. (DT-0006 3)

Comment: And finally, don't build it [a processing plant] with tax dollars. Use private money. 

I want the person who turns on the switch to pay the penalty, and he'll be more inclined to

conserve. (DT-0006 8)

Comment: Building a nuclear power plant is expensive. It could be, as somebody said,

hundreds and it's probably in the billions, but I think it's going to take ten years to build the plant

from the time you begin the process. (DT-0011 2)
Comments Outside the Scope of the EIS

December 2006 5-17 NUREG-1811, Volume II

Comment: Something that wasn’t on the slides that we saw earlier that was on slides last year

when I was here at the scoping meeting was what the impact was going to be on the cost of

power in Virginia. You guys right now have a cap on your electricity base in Virginia. That's

going to be lifted in 2010, which is before these plants, if they're built, which I believe they will,

too; before they're built, those rate caps are going to come off, and any cost overruns on this

plant are going to be borne by shareholders and by ratepayers. That's something you guys

need to keep in mind. (DT-0016 1)

Comment: According to the Department of Energy, nuclear power is projected to be more

expensive than coal, more expensive than gas, and even more expensive than wind, not just

now but through the year 2025. It's going to continue to be the most expensive method of

generating electricity. (DT-0016 3)

Comment: That dome would drive up your costs, and I would think possibly your CEO wouldn't

want to drive up your costs. Just a guess. (DT-0033 6)

Comment: This administration’s clear policy is to ignore scientific fact and protect Wall Street’s

bottom line over the environment and public health. The first myth of nuclear power is that it’s

cheap. It is made to seem that way by the subsidies the government gives to the industry. This

hemorrhage of cash has totaled nearly $100 billion over the last 50 years. These subsidies are

in actuality a redistribution of tax money from working people to rich corporations so they can

avoid the true cost of doing business. (DT-0036 2)

Comment: I just got my natural gas bill: $114, $114 last month. I wasn’t even there for half of

it. My electric bill was $30. My wife lives in Lynchburg. Her electric bill was $50, and we have

no natural gas there. So my question is: why is Dominion spending the last four years putting

in purely natural gas plants? Please, I can’t afford it. (DT-0043 1)

Comment: Nuclear power is certainly not cheap in terms of dollars. (DW-0181 3)

Comment: Nuclear power is expensive and highly dependent on government subsidies.

(DW-0186 2)

Comment: Stop wasting taxpayer monies for the most expensive and dangerous means for

electrical power. (DW-0187 2)

Comment: I read that NRC plans to “prime the pump” of nuclear power expansion by providing

various incentives, rebates, and subsidies. If the nuclear power industry can’t manage to make

a go of it in the free market after 40+ years, and if North Anna’s two existing reactors can't turn

enough of a profit to make expansion there worthwhile, then this is simply corporate welfare.

(DW-0194 5)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-18 December 2006

Comment: Please stop wasting money on the most expensive electric power generation-which

is nuclear. (DW-0195 1)

Comment: Utilities that have fallen for the nuclear hype end up with enormous costs they then

foist off on the ratepayers as “stranded costs.” (DW-0198 5)

Comment: Construction of such a plant is extremely expensive. (DW-0306 3)

Comment: The only reason nuclear energy is cheap is because of the Federal subsidies that

the nuclear industry receives. I'm all for free trade, but this is Corporate Welfare. (DW-0333 3)

Comment: I oppose construction for the following reasons: I oppose taxpayer subsidization of

the nuclear industry. An industry that claims to be safe and economical should not have its

accidents and cost overruns underwritten by taxpayers. (DW-0409 4)

Comment: Section 6.0 should include a statement of the government subsidies and tax

incentives that are provided for nuclear fuel production, fuel and waste transport, and waste

disposal. (DW-0438 165)

Comment: We resent the use of our tax dollars to prop up an otherwise unprofitable

enterprise. (DW-0424 4)

Comment: Government subsidies to the nuclear industry – how much will these kilowatt hours

really cost? (DW-0432 7)

Comment: I could not find in the DEIS a definitive statement of the proposed project’s net

electrical output. How can one assess the cost/benefits without this core data? (DW-0438 1)

Comment: I could not find in the DEIS a mention of whether the proposed project would be a

regulated rate-based plant or a merchant plant. How can a Dominion customer assess the

cost/benefits without this core data? (DW-0438 2)

Comment: Page 1-2 line 41 mentions the thermal capacity of the plant but not the electrical

(useful) capacity. This major omission does not allow the reader to determine the efficiency of

the power plant. (DW-0438 9)

Comment: The upfront financial costs of mining, handling, utilizing, and storing radioactive

materials, and more importantly the long-term social and health costs for those communities

interacting with these materials, make the cost of nuclear energy astronomical and, in my view,

immoral. (DW-0537 3)
Comments Outside the Scope of the EIS

December 2006 5-19 NUREG-1811, Volume II

Comment: It [nuclear energy] is also extraordinarily expensive and has cost U.S. taxpayers

many billions of dollars. Efficiency measures can save businesses and other ratepayers

considerable money while foregoing the expense of building many new power plants. 

(DW-0593 3)

Comment: Information about how much of the cost will be borne by Dominion and how much

by taxpayers is absent. (DW-0594 10)

Comment: A cost estimate for the facility is not included and thus one can't do any cost-benefit

analysis for its capital and operating impacts. (DW-0594 11)

Comment: The chances for FINANCIAL disaster in this case are quite high, likely changing our

current electricity rates to very high rates. (DW-0614 8)

Comment: Nuclear power has to be subsidized by citizens because of its cost. ... Virginia does

not need nuclear citizen-subsidized energy. (DW-0641 2)

Comment: [N]uclear reactors are expensive. In a time of a nation-wide financial crisis, why are

we spending $200 million to build a nuclear reactor when we can save money by investing in

safer, more environmentally conscious and cheaper sources of energy such as hydrogen, solar

power and geothermal energy to name a few? (DW-0670 4)

Comment: And what about the fact that nuclear power plants don’t ever seem to pay for

themselves (and are either kept afloat by gouging consumers or by massive tax payer

subsidies). (DW-0729 6)

Comment: The NRC is in an unusual position, in that it has a detailed understanding of the

costs involved with nuclear power plants, including the decommissioning and hazardous waste

disposal. Should we really resume imposing these costs on ourselves and future generations?

(DW-0807 3)

Comment: I live within the impact zone of North Anna, and I don’t want to pay for the subsidies

involved. (DW-0861 4)

Comment: It is unfair to expect the taxpayers to subsidize the industry. (DW-0867 3)

Comment: It doesn't make economic sense. The lack of insurance through traditional private

means together with huge start-up costs would require government subsidy, at a time when

public resources are short and other more urgent programs are dying for lack of funds. 

(DW-0955 1)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-20 December 2006

Comment: Among my concerns are: COST -- Nuclear power plants are notoriously expensive

and always run over budget. Safer, cheaper alternatives to nuclear energy are possible and all

avenues should be investigated instead of just leading us all down the nuclear energy road. 

(DW-0998 4)

Comment: Nuclear power is not price competitive without government subsidies. The fast

track permitting process is indeed one such subsidy. (DW-1181 2)

Comment: I oppose the use of taxpayer funds to prop up the regulatory requirements of the

utility industry. They either pay for it and make a profit, or they don’t get it. (DW-1247 2)

Comment: The ESP application doesn't consider what the effect might be on the cost of power

in Virginia. (DW-MM3 4)

Comment: The ESP application also doesn’t consider what the effect might be on the cost of

power in Virginia or nationally, or the need for new generating capacity. (DW-MM4 8)

Comment: The history of nuclear power demonstrates that constructing nuclear reactors is

expensive, with final costs often running billions of dollars over budget – costs that are often

passed on to ratepayers. (DW-MM4 10)

Comment: The minute they mention that they have a reactor design, Wall Street will think it's

an intent to construct, and they will short your stock. Your own CEO stated it best. Hedge

funds will be knocking over each other trying to short your stock. The minute Wall Street thinks

you're going to build a nuclear power plant, your bonds turn to junk. That's Dominion’s own

CEO. That's not the environmentalists. (DT-0033 2)

Comment: What is the capital and operating cost associated with the dry coolers (Page 3-7

line 22)? (DW-0438 86)

Comment: Nuclear generation is the cheapest and cleanest dependable source of electricity in

Virginia. As Virginia continues to grow, cheap and reliable power will be needed. Affordable

electricity helps drive the economy. (SW-0003 2)

Comment: [D]espite the significant subsidies provided in the Energy Policy Act of 2005,

investments in new nuclear plants remain very risky. ...U.S. Department of Energy has clearly

and concisely stated that new nuclear plants are not expected to be economical. A 2003 study

by the Massachusetts Institute of Technology forecasted that the base case, real levelized cost

of electricity for new nuclear reactors being estimated at 85 percent capacity would be 6.7 cents

per kilowatt hour over a projected 40 year operating life which is more expensive than energy

from pulverized coal or natural gas. ...a 2005 assessment by Synapse Energy Economics
Comments Outside the Scope of the EIS

December 2006 5-21 NUREG-1811, Volume II

Incorporation showed that the levelized costs of electricity from a new 2,180 megawatt nuclear

power plant would be significantly higher than obtaining the same amount of energy from a

combination of wind and gas-fired capacity and energy efficiency measures. (ST-0008 2)

Comment: [T]he project offers no conclusive evidence that there are benefits from this project

for the region. There's no clear cost benefit analysis, so how do we know that this is good? 

(ST-0036 12)

Comment: The low-cost energy produced from these generating facilities has enhanced the

state's economic climate, enabling Virginia to attract new business growth. Existing companies

have also benefitted from a lower cost energy environment that has allowed them to remain

competitive and expand operations in the Commonwealth. (ST-0031 3)

Comment: Information about how much of the cost will be borne by Dominion and how much

by taxpayers is absent. (SE-0049 2)

Need for Power

Comment: Hundreds of articles have made the point that the day of reckoning is coming to us

when the required source of energy may not be sufficient to meet the demand. So unless we

increase the supply here domestically, the question is: are we going to be ready when that

happens? Will we start from scratch at that particular point to develop new energy sources

when really it’s already too late? (DT-0011 4)

Comment: Even with expanded conservation and efficiencies, as I said before, we're going to

need 45 percent more electricity over the next 20 years. (DT-0027 10)

Comment: The impacts will be less if the possible additional reactors are replacements for the

present Units 1 and 2 when the current operating licenses expire. (DT-0029 6)

Comment: There will be a need for additional electrical generating capacity in this county

irrespective of conservation efforts. (DT-0029 11)

Comment: And it is imperative that we consider need, how to reduce our need, and

alternatives in this process. (DT-0044 4)

Comment: I’m reassured because our nation needs more baseload energy generation, and

tonight's hearing is one step to a process that brings us closer to resolving our need for more

clean, economical, and reliable power. (DT-0046 2)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-22 December 2006

Comment: There is no demonstrated need for the additional energy that these nuclear

reactors would supply. (DT-0047 7)

Comment: One reality that is easy for anyone to understand is that Virginia already has an

excess of energy production capacity. This is a socioeconomic issue, because Virginia has

already built up excess production of air-polluting coal and gas power plants. Now we are

asked to accept the risk of nuclear production and waste disposal for the generation of other’s

power. (DT-0061 2)

Comment: It is indisputable that we are facing an enormous energy crisis because of the

pending end of the oil era. However, switching to nuclear only introduces a plethora of other

problems already mentioned. (DW-0198 9)

Comment: It’s time to re-think our energy needs and start protecting our country and

environment. (DW-0395 3)

Comment: Virginia does not need the extra electricity. Most of the power produced at the

plant would be sold to other states. (DW-0408 8)

Comment: An evaluation of the need for power and who benefits is crucial to determining

whether the ESP application should be considered at all. In fact, the first question that should

be asked is whether residents of Virginia will receive any of the benefit of new reactors. 

(DW-0437 68)

Comment: Virginia currently has an excess electric generation capacity for its in-state needs

but continues to approve new fossil-fueled generating units that primarily will serve out-of-state

customers while increasing air pollution, water resource consumption and transmission line

impacts in Virginia. Neither the State of Virginia nor any of its major power generating

companies has undertaken substantial initiatives to encourage or provide safe, clean renewable

energy resources or to promote energy conservation. (DW-0589 10)

Comment: New nuclear reactors are not needed and would adversely impact the region.

(DW-0623 5)

Comment: Currently Virginia has a surplus of energy, so a new nuclear power plant would

generate energy which would likely be sold out of State, thereby increasing the risks to

Virginians without any benefits. (DW-0670 5)
Comments Outside the Scope of the EIS

December 2006 5-23 NUREG-1811, Volume II

Comment: Virginia currently has a surplus of electrical generating capacity, so excess power

will likely be sold outside the state rather than being used in-state to lower prices. Local

residents will be forced to live with the risks of the nuclear plant without getting the benefits.

(DW-0925 2)

Comment: Nuclear Power should not be used because: We use power so frivolously and

inefficiently now that we do not need additional generators. (DW-0829 8)

Comment: Under Section 1.3 Purpose and Need for the Proposed Action, there is no

discussion of the need of his facility. It is interesting to note that Virginia has had over

10,000 megawatts permitted since 1999 under a deregulated energy market. Most of these are

already under construction or in operation. This additional generation has gone far and above

any future need for the Commonwealth thereby making this additional generation unnecessary.

The risks to public safety and welfare by adding units three and four must be weighed against

the benefits. But with no need for the proposed generation, where is the benefit to citizens of

the Commonwealth. (DW-1157 15)

Comment: Sustained growth of the United States’ economy is dependent on having adequate

power available. This necessitates the addition of new base load plants to the energy mix in the

near future. (DW-1167 3)

Comment: The ESP application doesn’t consider what the effect might be on the cost of power

in Virginia, or the need for new generating capacity. (DW-MM3 5)

Comment: In the U.S. studies show that it’s not possible to maintain the existent percentage of

unlimited energy sources, let alone increase this percentage, with[out] the contribution of

nuclear power. That means that just to maintain the current level of economic development and

environmental quality, we will need to be build new nuclear power plants. (DT-0025 3)

Comment: When 11 year old ASA is 30, we're going to need 45 percent to 50 percent more

electricity than we have today, even assuming efficiency and conservation. So we’re going to

need more renewables, more than the two percent of electricity that we get today from wind and

solar. We're going to need more nuclear, more than the 20 percent that we get today from

nuclear energy. We're going to need electricity from all the sources we can get to meet the high

tech economy, the growing population and the quality of life that we would like for our children

at that time. (DT-0027 2)

Comment: Nuclear power is the only large scale, emission free electricity source that we have

today that can be readily expanded to meet our growing economy. (DT-0027 7)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-24 December 2006

Comment: I have always believed in using Nuclear Fuel for supporting the electrical need of

the United States. (DW-0440 2)

Comment: The early site process preserves the option to build new nuclear power plants,

helping ensure that we will have a diverse, secure, sustainable energy supply to power our

future. We need reliable ... affordable ...clean sources of energy for Virginia and America. 

(DW-0668 2)

Comment: The supply and demand projections show that the real shortage of electricity

without nuclear power is waiting to happen in the coming decade or two. (DW-0812 4)

Comment: Need for new reactors needs re-evaluation. (SE-0010 1)

Comment: Nuclear energy is important to the Commonwealth of Virginia and my constituents

in Virginia's 7 th Congressional District. Dominion's nuclear stations in Virginia provide

34 percent of the electricity used by customers and play a significant role in providing safe and

reliable electricity that is important to Virginia's growing economy. ...Because more baseload

electricity will be required in the future, it is important that nuclear energy remains an option to

meet this growing demand. (SW-0002 2)

Comment: We expect that the demand for electricity will increase substantially in the next

decade and we need to our part to be ready for that. (ST-0009 1)

Comment: Nuclear energy is important to Virginia. Dominion's North Anna and Surry power

stations provide 34 percent of the electricity used by customers in this state. These stations

provide safe, reliable and affordable electricity that is important to our growing economy.

...Because more electricity will be required in the future, it is important that nuclear energy

remains an option to meet this growing demand. (SW-0013 2)

Comment: [What is the basis for saying] that we're going to need a whole lot more electrical

generating capacity in the future. Hey, what's the basis for this? (ST-0002 5)

Comment: The document does not address the life cycle costs of power and the amount of

government subsidy involved. (SE-0045 4)

Comment: [W]e have expanded our nuclear portfolio and Wall Street hasn't really hurt us that

bad about that, you know, and it is about money and it is about what's good for the community,

not just a group community. (ST-0023 3)
Comments Outside the Scope of the EIS

December 2006 5-25 NUREG-1811, Volume II

Comment: [Regarding selling of power out of State,] one of the greatest concerns in the

western part of Virginia these days has been the fact that we have a line coming in from West

Virginia bringing electricity into the state, not the converse. (ST-0034 3)

Comment: [I]s it Virginia that's going to need it, or are you going to be exporting it elsewhere? 

Well, then I say not in my backyard. (ST-0002 6)

5.3 Emergency Preparedness

This section lists comments related to emergency preparedness. Commenters raised concerns

that it may not be possible to develop an effective emergency plan, or to evacuate the affected

members of the public.

General Response: Emergency preparedness is a safety issue that is addressed in the NRC

Safety Evaluation Report (ADAMS Accession No. ML052710305) issued in September 2005. 

The Safety Evaluation Report is available on the NRC’s website at www.nrc.gov. The NRC

evaluates emergency plans for nuclear power reactors to determine whether there is

reasonable assurance that adequate protective measures can and will be taken in the event of

a radiological emergency. For an ESP, the Commission must determine, in consultation with

the Federal Emergency Management Agency, whether the information submitted by the

applicant indicates that there are physical characteristics that could pose a significant

impediment to the development of emergency plans. In the NRC Safety Evaluation Report for

the North Anna ESP site, the staff determined that no such impediments are present. The

emergency planning issues that were raised during the environmental review were forwarded to

the appropriate NRC safety project manager for consideration and appropriate action.

Emergency planning is a fundamental element of the Commission’s defense-in-depth safety

philosophy. The NRC will not issue a license to operate a nuclear power reactor unless it finds

that there is reasonable assurance that adequate protective measures can and will be taken in

the event of a radiological emergency (see 10 CFR 50.47). This is a safety finding under the

NRC’s Atomic Energy Act responsibilities. Safety issues, however, are generally outside the

scope of the environmental review because the NEPA process focuses on the environmental

impacts of the proposed action rather than on issues related to safety, which are not necessarily

associated with environmental impacts. This is discussed in greater detail in the introductory

remarks to Chapter 5 of Volume II of this EIS.

Nonetheless, accidents involving radioactive material can have environmental impacts. 

Consequently, the impacts of postulated accidents are analyzed in Section 5.10 of Volume I of

this EIS. Under NEPA, the analyses are to reflect “reasonably foreseeable” consequences

even though the likelihood of accidents is low. In its evaluation of severe accidents, for
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-26 December 2006

example, the staff considered incident response principles. The NRC staff used the MACCS2

code to estimate the environmental impacts of severe accidents. The MACCS2 code analysis

takes into account a delay time prior to simulating the relocation of the affected segment of the

population, which is a mitigation measure. Further, the MACCS2 code estimates the economic

costs of the short-term relocation of people simulated in the code. These analytical

assumptions are not intended to be linked to specific elements of detailed and site-specific

emergency plans for a nuclear power reactor, but are intended to reflect the reasonable

expectation that action will be taken to protect the public. Further consideration of emergency

response measures in the EIS is not warranted.

Comment: In order to build a nuclear power plant, there must be an evacuation plan approved

by the NRC, as I understand it. Unfortunately the NRC accepts evacuation plans that can't

work, and here are two examples. One, at the time of the Three Mile Island accident,

3400 people were ordered to evacuate. One hundred and forty-four thousand tried to leave

clogging highways all the way to New York. Not workable. Two, when the Shoreham Nuclear

Power Plant on Long Island was being built in the early ‘80s, the Long Island Lighting

Company’s evacuation plan called for residents to evacuate to upstate New York. Upstate New

York residents were interviewed about this and some said they would shoot Long Islanders on

sight. ... This same plan called for decontaminating fleeing vehicles with Handiwipes and spray

Fantastik. I know this because I lived there at the time and heard these very words spoken by

power company officials at an NRC hearing. The plan also called for evacuating people

according to their license plate numbers. One day the even numbers could go. The next day,

the odd numbers. Studies have shown that in the event of a nuclear accident, emergency

workers would leave their duties and go home to rescue their families. The same for school bus

drivers. So calling these evacuation plans acceptable is without merit. And, by the way, we

kept the Shoreham plant from opening. (DT-0009 5)

Comment: The fifth issue ... are the zones that are around Ground Zero in case of a

meltdown, the ten mile evacuation zone. A 17.5 mile fatality zone, but those people are not in

the evacuation plan. You see where I'm getting at. A 50 mile peak injury radius. (DT-0009 6)

Comment: There is in fact no safe and effective plan to evacuate the vicinity which recognizes

that many citizens will require assistance and transportation. (DT-0054 3)

Comment: Finally, the question of accidents, I have been told that the potential for accidents is

small. I personally live only 15 miles (or less) from Surry Nuclear Power Plant as does my

University, the College of William and Mary. A few years ago, due to concern about meltdown

or terrorist attack, iodine pills were distributed to the Williamsburg community surrounding the

College, students living in dorms, were exempt from this. While residents of Williamsburg

received annual bulletins regarding evacuation procedures, students do not. If these blatant
Comments Outside the Scope of the EIS

December 2006 5-27 NUREG-1811, Volume II

exclusions were made, what other errors in evacuation procedures, meltdown prevention, or

security measures were made? (DT-0061 4)

Comment: What is the evacuation plan going to be for those within 40 miles of this plant which

includes portions of Charlottesville? Washington, D.C., itself is only 90 miles away down wind.

What a poor choice of location for our national security! My thoughts would be that the people

who are considering this have already had their brains polluted enough not to be thinking

clearly. (DW-0181 5)

Comment: What is the evacuation plan for the neighboring community and for

Washington, D.C., Richmond, and Charlottesville? (DW-0187 5)

Comment: [Comment regarding Dominion's ESP application rather than the NRC Draft EIS]

I also feel that route alerting needs to be addressed in the Emergency Planning Section as well,

if sufficient sirens are not currently yet in place. (DW-0191 3)

Comment: My family and all the rest of living things are close enough downwind (from the

predominate prevailing westerlies) that should there be an accident, there would be no way to

warn us in time. (DW-0192 3)

Comment: I'd like to know what plan NRC has for evacuating my county of Louisa, plus nearby

cities like Charlottesville, Richmond, and Washington D.C. (less than 100 miles downwind) if

anything goes wrong with waste transport, or there is a reactor failure, or a terrorist attack

occurs. If NRC and the Dept of Homeland Security don't have these plans in place, there is no

point in even talking about expanding a ripe target like North Anna. (DW-0194 4)

Comment: What is your evacuation plan? I live within 70 miles of the current plant and have

never received evacuation info. Washington, D.C. is less than 90 miles downwind. What

evacuation plans are in place? (DW-0195 4)

Comment: Can Washington, D.C. be evacuated without a tremendous loss of lives in the event

of a radiation leak or an explosion? (DW-0413 2)

Comment: Transportation is entirely inadequate for not only construction phase of the

proposed facilities, but certainly in the event of the need for an evacuation. (DW-0431 4)

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. (DW-0438 79)

Comment: Sections 5.5.3.1 and 5.5.3.2 do not consider evacuation impacts. (DW-0438 153)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-28 December 2006

Comment: Sections 5.5.3.4 and 5.5.3.5 should assess the impact on recreation and local

housing if there is a nuclear accident at the facility. (DW-0438 156)

Comment: The project itself has real problems including...ability to support construction

personnel, and emergency evacuation. ... We mention above the road situation relative to the

movement of 5,000 construction personnel – what would happen if an evacuation was required

of ten or twenty times that many people? Local infrastructure can't support this project. 

(DW-0594 6)

Comment: There isn’t a sufficient emergency evacuation plan for Route 33. It is two lanes

wide. How is it that you do not have an evacuation plan with such a limited way to get out?

Most of us live very near Route 33 and according to your plan we have to get to Patrick Henry

High school in Ashland. 18 miles away on a two lane road. this is not good. We need to hold

town meetings in churches in the area to make the facts clear with this community. 

(DW-0626 2)

Comment: Emergency plans for dealing with an accident or terrorist attack are inadequate,

and rely on teachers, bus drivers, doctors, and other civilians to facilitate an evacuation, without

taking into account the possibility of role abandonment. Studies of the Three Mile Island

accident, which took place in 1979 in Pennsylvania, found that doctors and other key workers

abandoned their posts up to 25 miles from the site to tend to their families or save themselves.

In the case of a more severe accident, heroic actions would be required to successfully carry

out an evacuation. (DW-MM4 16)

Comment: Emergency plans for dealing with an accident or terrorist attack are inadequate,

and rely on uninformed teachers, bus drivers, doctors, and other civilians to facilitate an

evacuation, without taking into account the possibility of role abandonment. Studies of the

Three Mile Island accident, which took place in 1979 in Pennsylvania, found that doctors and

other key workers abandoned their posts up to 25 miles from the site to tend to their families or

save themselves. (DT-0053 9)

Comment: Page 2-1 line 24 mentions that I95 passes within 16 miles of the site. Later

sections do not adequately detail the impact on I95 during upset conditions at the plant or upset

conditions on the road. The DEIS fails to demonstrate that a plant upset would not adversely

impact I95 or US1 which is THE major north-south corridor in the Mid-Atlantic region. 

(DW-0438 11)

Comment: The DEIS says that emergency plans are okay in part because there are two

hospitals in Spotsylvania. THERE ARE NO HOSPITALS IN SPOTSYLVANIA! Mary

Washington Hospital in Fredericksburg is the primary hospital serving this area and it is getting

stretched thin. (DW-0594 12)
Comments Outside the Scope of the EIS

December 2006 5-29 NUREG-1811, Volume II

Comment: [Comment related to Dominion’s ESP application rather than the NRC Draft EIS] 

First and foremost the information in Part 2 - Site Safety Analysis, Chapter 2 - Site

Characteristics, Section 2.1.3 pertaining to population distribution. This information references

the most recent Evacuation Time Estimate (ETE) for the NAEP is based on the Census 2000

data and the total population is noted as 20,292. This information is contradictory to the

information noted in Chapter 4, Section 4.4.1.1 Groups Vulnerable to Physical Impacts,

4.4.1.1.1 People - This section notes the area within 10 miles of the ESP to be estimated to be

populated by approximately 15,500 people. This information references Section 2.5, 2.5.1.1. 

The information contained in Section 2.5 is current data. This information is contradictory in it's

self, which leads to believe that there are more contradictions other than these since the data

referenced is from various time spans dating back to the mid-1980s. (DW-0191 1)

Comment: There's been no real analysis...for the innumerable people that may need to be

evacuated in the event of a nuclear incident. ...How is Route 208 going to evacuate any

meaningful number of people? It can't. The other roads in the area can't. (ST-0036 4)

Comment: [With the addition of construction and operations traffic from the new unit],

[e]mergency evacuation would be impossible on this small 2-lane road if there was a nuclear

disaster or terrorist attack. (SW-0005 3)

Comment: What would happen during an emergency evacuation caused by a terrorist attack?

The roads could not handle this situation. (SE-0004 17)

Comment: We request that VDOT upgrade the roads at the Lake so that they are adequate for

the evacuation of the current and expected population. We request that VDOT, Dominion and

the Public develop a traffic management plan relevant to evacuation. (SW-0004 10)

Comment: 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. (SE-0045 6)

Comment: Emergency Evacuation surrounding the entire lake in Louisa, Spotsylvania and

Orange Counties. Only 2 lane roads surround the lake. ...The applicant, state and federal

governments should work together to...increase the road width’s, etc. prior to any new

construction beginning as a result of the ESP or COL that accommodates the emergency

evacuation of 7,000 to 8,000 Dominion employees/construction workers together with all the

local residents and recreational users of the lake. (SE-0003 2)

Comment: The recent past raises serious concerns about Virginia Dominion Power's ability to

meet emergency situations in the Commonwealth. After hurricane Isabel, it took ten days and

power crews from Arkansas and Alabama to get the Norfolk area up and running again. More
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NUREG-1811, Volume II 5-30 December 2006

recently, tropical storm Ernesto left some without power for five to six days. Those kinds of

response times would be deadly in the event of a nuclear accident or facility attack and seem to

me to be unacceptable risks to take. (SW-0021 4)

Comment: [I]t [the EIS] doesn't provide sufficient detail on the planning and consideration for

potential nuclear incidents, not just likely nuclear accidents. (ST-0036 1)

Comment: [To ensure that the proposed construction of a 3rd & 4th reactor will minimize the

adverse affect to the quality of life for those that live and use Lake Anna, we also ask that you

further evaluate the following concerns prior to your making a final decision on the

ESP]...Emergency evacuation on small 2 lane roads. Need for expanded road system to

accommodate new workers and subdivisions. (ST-0014 15) and (SE-0022 27) 

5.4 Safety

This section lists comments that primarily focus on safety. The comments near the beginning of

the section express general safety concerns and concern related to safety of operating reactors,

although there is one comment that refers to the nuclear industry’s “enviable safety record.” 

The remaining comments generally express concerns about the extent of the safety review

contained in the EIS. The subjects of all of the these comments have been determined to be

out of the scope of the EIS.

General Response: The EIS sets forth the NRC staff evaluation of the effect facility

construction and operation at the North Anna ESP site would have on the environment. The

staff’s evaluation covers the effects of normal operation and design basis accidents, which

would occur if plant systems, structures, and components (SSCs) important to safety function

as designed, and severe accidents, which would occur only if plant SSCs do not function as

designed. This concept extends to other matters covered by NRC safety requirements, such as

emergency preparedness programs. Whether any particular SSC is correctly designed or would

correctly function, or whether any program would be correctly implemented, makes no

difference to this evaluation because their failure is presumed in the severe accident analysis. 

Stated another way, consideration of comments on the adequacy of SSCs or other safety

measures would not result in a severe accident different than that already considered in the

EIS. Accordingly, comments regarding the adequacy of plant safety are outside the scope of

the EIS.

The environmental setting of the site is described in Chapter 2 of the EIS. Certain factors that

relate to safety issues are also relevant to the environmental review; these factors include

seismology, hydrology, demography, and meteorology. Regulations governing the

environmental review are in 10 CFR Part 51, and the regulations covering the safety review are
Comments Outside the Scope of the EIS

December 2006 5-31 NUREG-1811, Volume II

in 10 CFR Part 52. For this reason, the environmental review is distinct and separate from the

safety review. Site safety issues and emergency preparedness are addressed in the NRC

Safety Evaluation Report (ADAMS Accession No. ML052710305) for the North Anna ESP site

issued in September 2005 and its supplement issued in September 2006 (Accession No.

063170371). These reports are available on the NRC’s website at www.nrc.gov. To the extent

that comments are directed to NRC review processes, a response is provided in Section 2.2 of

Volume II of this EIS.

General Safety Concerns

Comment: [It] is now a source of concern to me knowing that the Nuclear Regulatory

Commission seems willing to accept this draft EIS, which according to Public Citizen, People's

Alliance for Clean Energy and others, neglects to address crucial safety issues. (DT-0009 1)

Comment: I thought you said ... the NRC would discuss security issues with the Atomic Safety

and Licensing Board, but there was no place in the Security Review process, at least at any

point in the research or formative stage, for public comment. If that is the case, then I object

strenuously. Safely is probably the greatest concern for the public out of all of the issues arising

in the permitting process. How can you think to shut us out of that discussion? That is wrong,

wrong, wrong! (DW-0410 2)

Comment: The Enron factor. Although I am willing to allow that nuclear power could be

provided in a safe, clean and efficient manner (in theory), I am uncomfortable with leaving my

family's safety in the hands of corporate managers who are trained to think of profit first. If the

economic cycle reverses and the plants become unprofitable, the temptation to take a few

shortcuts could be very strong. (DW-0955 3)

Comment: I don't believe you when you say you have the ability to protect the public and

insure our safety. (DW-0614 2)

Comment: I live a short distance from the site and I am concerned about safety issues related

to the plant operations. (DW-0832 2)

Comment: I live in Richmond, Virginia and am very concerned with the safety of nuclear

power. (DW-0847 2)

Comment: [Nuclear power] has come out on top after the challenges of the seventies and

eighties with an enviable safety record. (DW-0812 3)

Comment: Here in Louisa, there are already 2 nuclear units which have safely produced power

for 30 years without incident. The power company has dealt with incidents such as transformer
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-32 December 2006

failure, low water levels, and leaks in a safe and reliable fashion. They have defended the plant

against possible intrusions and have built up a substantial security team to aid the operators. 

This has all been done in a very professional manner. (DW-1007 2)

Comment: The Davis-Besse plant near-disaster is a case in point [near accident], and in that

situation, both the NRC and the utility, First Energy, were extremely negligent in inspecting the

plant and in following up with necessary maintenance and repairs. (DW-0198 4)

Comment: Page 1-5 line 28 mentions the North Anna Dam. Shouldn’t an analysis be done

and included herein on the safety and environmental impacts if the Dam is breached? 

(DW-0438 8)

Comment: Dominion has set high standards for safety throughout their fleet, personnel safety,

industrial safety and that which directly affects my department and what I do-- radiological

safety. (ST-0022 1)

Comment: [Sharing comment from a plant vendor] "You know, I just want to thank somebody

and tell them how much I appreciate the safety and everything, all the checks that we go

through." (ST-0037 1)

Comment: [T]he draft EIS contains only one page on the geology of the ESP site at North

Anna. ...The draft EIS plainly omits critical information about seismology in the central Virginia

area. ...The proposed construction of two or more reactors in close proximity to two existing

nuclear reactors in an active earthquake zone must not be permitted. (SW-0008 1)

Comment: I want to acknowledge you all for having created power plants that are

user-friendly...You have an admirable safety record that I think is the envy of all kinds of other

industries out there. ...your record is fantastic, and I thank you for that. (ST-0038 1)

Comment: To bound the possible effects of Unit 3 cooling on Lake Anna water levels and

downstream releases, the NRC analysis purports to examine the simulated impacts of operating

Unit 3 wet-dry cooling during what was a critical drought period between April 2001 and

February 2003. This simulation is hardly encouraging. Operation of Unit 3 with wet-dry cooling

would have dropped the minimum lake level experienced during this period by an additional

1.7 feet, to 243.5 MSL. That is only 1.5 feet above the minimum operational plant intake level of

242 ft MSL, where the North Anna reactors would be forced to shut down. Given possible

errors and plausible variances in the model’s input data, we do not believe this provides a

sufficient or safe operating margin. (SE-0040 9)
Comments Outside the Scope of the EIS

December 2006 5-33 NUREG-1811, Volume II

Comment: I worked inside the fence at North Anna for five years, and can tell you after many,

many hours spent in the control room, that North Anna is one of the safest, best run, and best

protected industrial facility anywhere in the country. (ST-0026 1)

Safety Review

Comment: The lack of detailed safety discussions in the socioeconomic sections is a major

flaw in the ESP process. Thus the DEIS cannot be effectively used as a decision-making tool. 

(DW-0438 58)

Comment: There are no operating experience records for this generation of reactor. ... there

can be problems that small scale operation cannot predict. (DW-0570 2)

Comment: In other words, what are the compounding effects on safety and the environment of

the proximity of other reactors? The description of the affected environment correctly

emphasizes the presence of NAPS Units 1 and 2 on the site (paragraph 2-1); however the

possible interactions between existing reactors with the proposed reactors do not appear to be

addressed where they would need to be, for example in Chapter 5.10.1, Design-Basis

Accidents, in Chapter 5.10.2, Severe Accidents; or Chapter 6, Fuel Cycle, Transportation and

[De]Commissioning, especially Section 6.1.1.6, Radioactive Wastes. What, for example, will be

the effect of these additional reactors on the safety of the two existing reactors? (DW-0685 2)

Comment: What is the comparative safety record of large and small clusters of reactors?

(DW-0685 3)

Comment: What are the effects on safety, and on the concept of “defense in depth” of greater

maximums of full power operation at a given site? (DW-0685 4)

Comment: [Comment regarding Dominion's ESP application rather than the NRC Draft EIS] 

The information in Tables 2.5-16 - Table 2.5-21 all specifically state that the information is from

1989 EPRI data. This information is over 16 years old. Certainly there is more current

information from EPRI - this information is closer dated for the use for previous construction at

North Anna Power Station than for new units not yet constructed. No information is provided

which stipulates what the data is based on. The other remaining Tables do not include this date

reference on or within the data, which leads you to believe that the basis of this data is also

more than 15 years old. (DW-0191 5)

Comment: Dominion's ESP application for North Anna contains no safety assessment of the

facility and, therefore, cannot demonstrate a low probability of accidental releases of fission

products. (DT-0034 12)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-34 December 2006

Comment: Page 2-40 line 11 states that the WHTF “is physically separated from the rest of

Lake Anna by a series of d[i]kes”. What is the susceptibility of the WHTF to earthquakes,

hurricanes, and other natural or terrorist disasters? (DW-0438 55)

Comment: [Comment regarding Dominion's ESP application rather than the NRC Draft EIS]

Tables 2.5-1 through 2.5-6 discuss the fault that runs through this region, however the data that

is provided is based on Crone & Wheeler of 2000 prior to the relatively recent strong earthquake

(tremors) that occurred in early May of 2003 and on December 9th, 2003 in this region. Also, the

information referenced in Figure 2.5-14 Seismic Source Zones and Seismicity in Central &

Eastern North America is based on magnitude information from 1987 data, which is over

18 years old. Figure 2.5-19 Bechtel Group EPRI Sources, no date on this data is noted other

than the Bechtel/EPRI data, which is, dated 1987-1989. The opening letter in Appendix J -

Down Hole Seismic Report & Data to Mr. J. A. Price is dated March 17th, 2003, which is also

before both of these previous events. Since these events have occurred in this specific region,

and significant boring will occur during construction, I feel that this information should be

re-evaluated using current data, and not based on data that is over 18 years old. (DW-0191 4)

Comment: I cannot understand why seismic activity in the Lake Anna area was ruled out from

the DEIS process. NRC material indicates that seismic features are to be considered in an EIS

for an ESP. Given the earthquake of last year, and the number of faults in this area, it is

irresponsible to exclude consideration of seismic features at the North Anna site. (DW-0630 2)

Comment: The DEIS omits critical information about seismology in the Central Virginia Area—

The proposed construction of two or more reactors in close proximity to two existing nuclear

reactors in an active earthquake zone beggars understanding. (DT-0034 2 and DW-1163 1)

Comment: Dominion failed to adequately address the seismic history of the proposed ESP

site. The Draft EIS contains only one page on the geology of the ESP site at North Anna.

Section 2.4 alludes to two previous environmental reports prepared for North Anna Units 1 and

2 (done by Dames and Moore for VEPCo in 1969) and the never constructed North Anna

Units 3 and 4 (Dames and Moore 1971). It has come to our attention through recent

conversations with the June Allen, M. Ed., former President of the North Anna Environmental

Coalition, that there were “multiple problems beginning 33 years ago” with regard to the seismic

faults underlying the North Anna station. According to information and belief, false statements

were filed in that matter which were uncovered too late to affect the permitting decision. The

ESP DEIS states that seismological data will be addressed in the safety evaluation report. 

Nevertheless, we hereby request that the DEIS record include and consider all documents in

the case filed by North Anna Environmental Coalition during the extensive litigation brought

during the 1970s. (DW-1163 5 and DT-0034 6)
Comments Outside the Scope of the EIS

December 2006 5-35 NUREG-1811, Volume II

Comment: On December 9, 2003, there was a 4.5 Richter Scale earthquake in central Virginia,

just one day after the NRC’s first hearing on the ESP in Mineral. ...The horizontal acceleration

which occurs during earthquakes presents unacceptable risks for a technology as sensitive as

nuclear power. The proposed construction of two or more reactors in close proximity to two

existing nuclear reactors in an active earthquake zone beggars understanding. (DW-1163 6)

Comment: The site permit regulation which Dominion must adhere to is predicated on the type

of nuclear power unit. But since “Dominion has not selected a particular reactor design,” the

power unit is as yet undetermined. In order to evaluate the radiological dose consequences as

stipulated in 10 CFR §100.21 (c)(2), the NRC must have the preliminary safety analysis report

(PSAR) which would be submitted with Dominion’s application for a construction permit. As

stipulated in 10 CFR §50.34(a)(1), the PSAR applicable to North Anna would include: “(ii) A

description and safety assessment of the site and a safety assessment of the facility. It is

expected that reactors will reflect through their design, construction and operation an extremely

low probability for accidents that could result in the release of significant quantities of

radioactive fission products.” Dominion’s ESP application for North Anna contains no safety

assessment of the facility and, therefore, cannot demonstrate a low probability of accidental

releases of fission products. (DW-1163 10)

Comment: There are several areas of safety that have not been addressed from construction

effects to the damage done to the lake, not to speak of dealing with the waste storage.

(DW-0404 1)

Comment: NRC Safety report [is] not reviewed by Commonwealth of Virginia Departments or

the public...There should be a draft safety report public comment period, similar to the ESP

process, so the public and state agencies have a chance to review and comment on the NRC’s

safety findings. ...There are those sections that should definitely be reviewed by the Va. Dept of

Water Resources, Fish & Game together with Transportation Dept and inaccurate statements in

the safety report that should be corrected. (SE-0003 13)

Comment: The public must be involved with the safety of the nuclear reactors, whether it is at

the plant, at the dam, together with how, where and how long the spent nuclear fuel is stored.

...It is essential that the public can review the safety report prior to the closing of the public

comment period for ESP process. (SE-0033 2)

Comment: We also request that the public be involved in reviewing a draft safety report, read

the EPS prior to its final issuance and that's there's an automatic extension of the public

comment period whenever revision of the EPS occurs. (SE-0022 36) and (ST-0014 23)

Comment: The public should be involved with the safety evaluation report and be able to

comment. That doesn't occur right now. The NRC does their own thing. (ST-0014 3a)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-36 December 2006

5.5 Security and Terrorism

This section lists comments that primarily focus on security and terrorism. The comments near

the beginning of the section express concerns about physical security at nuclear power plants

and security of nuclear materials. The remaining comments generally express concerns about

terrorism and the potential impacts associated with terrorist attacks. The subjects of all of the

these comments have been determined to be outside the scope of the EIS.

General Response: The NRC is devoting substantial time and attention to terrorism-related

matters including coordination with the Department of Homeland Security. As part of its mission

to protect public health and safety and provide for the common defense and security pursuant to

the Atomic Energy Act, the NRC staff is conducting vulnerability assessments for the domestic

utilization of radioactive material. In the time since the horrific events of September 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. 

Major NRC actions include the following:

& Ordering plant owners to sharply increase physical security programs to defend against

a more challenging adversarial threat.

& Requiring more restrictive site access controls for all personnel.

& Enhancing communication and liaison with the intelligence community.

& Improving communication among military surveillance activities, NRC, and its licensees

to prepare power plants and to effect safe shutdown, should it be necessary.

& Ordering plant owners to improve their capability to respond to events involving

explosions or fires.

& Enhancing readiness of security organizations by strengthening training and

qualifications programs for plant security forces.

& Requiring vehicle checks at greater stand-off distances.
Comments Outside the Scope of the EIS

December 2006 5-37 NUREG-1811, Volume II

& Enhancing force-on-force exercises to provide a more realistic test of plant capabilities

to defend against an adversary force.

& Improving liaison with Federal, State, and local agencies responsible for protection of

the national critical infrastructure through integrated response training.

& Working with national experts to predict the realistic consequences of terrorist attacks on

nuclear facilities, including one from a large commercial aircraft. For the facilities

analyzed, the results confirm that the likelihood of both damaging the reactor core and

releasing radioactive material that could affect public health and safety is low.

The Commission has determined that security and terrorism are outside the scope of an NRC

environmental review for the following three reasons. First, the Commission does not currently

have a method or theory with which to perform a meaningful analysis of the environmental

impacts of terrorism with respect to a particular facility. Second, in the absence of specific

information indicating that a terrorist attack on a specific facility is likely to occur, NEPA does not

require consideration of postulated terrorist attacks. Third, the public aspect of the NEPA

processes conflicts with the need to protect certain sensitive information because (1) a review of

terrorism under NEPA would involve examination not only of how terrorist attacks could cause

maximum damage but also how they might best be thwarted, and (2) confidentiality in this area

protects against the risks that terrorism poses to public health and safety.

Physical Security and Security of Nuclear Materials

Comment: Questions about the adequacy of current security regulations and performance are

ignored. (DW-MM2 4)

Comment: Even a “minor” accidental discharge could have serious effects due to the densely

populated suburbs of Washington. (DT-0054 4)

Comment: Security of the surrounding cities is another main concern for those of us living in

areas that would be affected adversely by the plant. (DW-0802 3)

Comment: The issue of security also has profound implications. (DW-0817 6)

Comment: Nuclear Power should not be used because: An attack or sabotage by terrorists

would be a disaster to eclipse the Indian Ocean Tsunami. (DW-0829 4)

Comment: What area the implications for national security if nuclear plants do not know what

to do with the waste? (DW-1181 4)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-38 December 2006

Comment: Should they [the reactors] be closed or partially closed for security purposes?

(DT-0038 5)

Comment: The Draft EIS fails to evaluate the environmental impacts and security threat of

indefinitely storing the additional irradiated fuel that will be generated by the proposed reactors

onsite. (SE-0038 7)

Comment: I will say this about the security force and the security department at the North

Anna Power Station. The security force is a formidable force. Our security officers are

motivated. (ST-0021 1)

Terrorism

Comment: Nearly 31⁄2 years after September 11th, 2001, legislation to improve security at

nuclear plants has not been enacted, and security improvements by the nuclear industry have

been shown to have significant gaps and flaws. Security guards are often ill-trained and

ill-equipped. Mock assaults designed to test guards and keep them on their toes are often done

in an unrealistic manner, with months of advanced warning, and with added security forces that

are not normally present to defend against a real attack. (DW-MM4 14)

Comment: Nearly 31⁄2 years after September 11th, 2001, legislation to improve security at

nuclear plants has not been enacted, and security improvements by the nuclear industry have

been shown to have significant gaps and flaws. Security guards are often ill-trained and

ill-equipped. Mock assaults designed to test guards and keep them on their toes are often done

in a unrealistic manner, with weeks of advanced warning and limited attack scenarios. Further,

the company testing security also guards nearly half the plants in the country, creating a conflict

of interest that prevents meaningful security analysis. Eight state attorneys general submitted

comments to the NRC in January 2005 calling for vastly improved security standards. 

(DT-0053 7)

Comment: One possible security measure to protect the reactor from assault by aircraft is to

place a reactor below ground level. Therefore, an analysis in the Draft EIS of the suitability of

the site to place the reactor containment below-grade level should be done, which would require

an in-depth analysis of geological and hydrological conditions at the site. (DW-0437 66)

Comment: I truly believe we fail miserably when it comes to making these materials secure.

Los Alamos is a perfect example of a failure on the part of those responsible to keep materials

out of the wrong hands ... or being unable to account for secretive material vital to the nation’s

security. Are we going to further risk the security of the United States by expanding the

opportunities for those who would harm us? (DW-1013 2)
Comments Outside the Scope of the EIS

December 2006 5-39 NUREG-1811, Volume II

Comment: 9/11 has presented us with serious, new chances for terrorism. And I do not think it

is wise for our community to allow these two new nuclear reactors to be built and more waste to

be brought into our midst. (DT-0007 4)

Comment: Also, if we are truly concerned about terrorists, isn’t this a great temptation for

them? (DT-0008 7)

Comment: The issue of terrorist attack. Who can assure use that a plant won't be bombed,

invaded or hit by a plane, and that the fuel rods won't be exposed resulting in a devastating fire? 

No one. In 2003, Senator Harry Reid said that the NRC had done nothing to improve safety and

security at our nation's nuclear power plants. The NRC’s response at that time was since it

couldn't calculate the risk of terrorist attack, it would not consider it a risk factor in opening new

power plants. (DT-0009 4)

Comment: Another thing that mystifies me is that apparently the analysis of terrorism was

done by regulations proposed in 1996, and we need to be up to date on this. It's bizarre that

our government was raising the possibility of terrorism every few days last summer and fall, and

that now somehow this branch of government, the NRC, overlooks it in this analysis. 

(DT-0010 4)

Comment: I don't understand why we in Central Virginia have to house four nuclear reactors. 

It seems like that's just inviting a terrorist attack. It seems that the two that we have is probably

enough, and with the problem of nuclear fuel, it's probably too much. (DT-0013 3)

Comment: I care about the risks of nuclear power on a personal level and on a global level. 

I need to say specifically to NRC folks here that I don't believe you when you say the issue of

terrorist attacks on the plant will be addressed in another part of the process. So I don't believe

you when you say you have the ability to protect the public and insure our safety. (DT-0017 1)

Comment: The Draft EIS fails to evaluate the environmental impacts and security threat of

indefinitely storing the additional irradiated fuel that will be generated by the proposed reactors

onsite. (DW-0437 33 and DW-0589 8)

Comment: I submit that a Lake Anna site is not suitable for a nuclear reactor. The War on

Terrorism is a top priority for this administration. President Bush devoted 40 percent, four, oh,

percent, of his State of the Union message to the War on Terrorism. You, the NRC, are a part

of the government, and you have a part in the war on terrorism. The proliferation of nuclear

reactors does not mesh with the goal of preventing a disastrous terrorist strike on the United

States...You have been warned by the government, by the President, by Homeland Security,

the CIA, and the 9/11 Commission report that the threat of a terrorist attack is very real. You

should not be authorizing a new reactor near any metropolitan area, especially Washington,
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-40 December 2006

which is a prime symbolic target. You should not renew permits for current reactors, and you

should shut down the Indian Point reactor that is a mere 35 miles from Times Square. 

(DT-0022 1)

Comment: Right now the nuclear bureaucrats in Washington are paving the way to allow

construction of reactors that lack the very containment domes that they were lauding after 9/11.

... If you looked after 9/11, how were we attacked? We were attacked by the air. What has

NRC done in its inestimable wisdom? They've shored up our defenses from the ground.

Nothing has been done to secure these plants from airliner attack. (DT-0033 4)

Comment: Does the range of severe accidents that could occur at the North Anna site with the

addition of reactor Units 3 and 4 (DEIS, Section 5.10.2) include an external attack on the scale

of the one that occurred on September 11, 2001 at the World Trade Center in New York City,

where hijacked aircraft were employed to destroy two very large office towers? If not, would

such an attack be bound by the accidents considered in the Draft EIS, or would such an event

require a unique analysis? (DW-0437 67)

Comment: And when I heard tonight that one of the ways that Dominion protects us from

terrorists is to hire armed guards to patrol the lake that doesn’t make me feel safer, and if our

current power source has to be guarded by a virtual private army, I think we should start looking

for a new power source. (DT-0037 3)

Comment: I believe that siting two new reactors at the North Anna area constitutes a terrorist

threat. When the U.S. was attacked on September 11th, the terrorists didn't need to go to Iraq to

find those weapons of mass destruction. They used our technology against us. By licensing

and building additional nuclear power plants, we are further increasing the risk of another

terrorist attack. (DT-0041 6)

Comment: The site’s proximity to Washington, D.C. presents an extremely attractive target for

terrorist attack. (DT-0054 5)

Comment: [T]he current administration and Congress has refused to take the proper measures

– any measures – to make nuclear and chemical plants safe from terrorist attack. (DT-0058 4)

Comment: The addition of two more nuclear reactors would make for an even more appealing

terrorist target. (DW-0165 5)

Comment: The highly radioactive spent fuel will most likely be stored at the North Anna site

and will be vulnerable to terrorist attack. (DW-0186 4)
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December 2006 5-41 NUREG-1811, Volume II

Comment: Therefore the North Anna cask storage site, located less than 100 miles from our

nation’s capitol, would be a prime target for terrorists, continuing to place those of us who live in

this area at highest risk. (DW-0196 4 and DW-0744 4)

Comment: Finally, there is the fact that nuclear plants are prime targets for terrorists.

(DW-0198 7)

Comment: There are issues of general safety, not to mention the terrorist invitation potential. 

(DW-0309 6)

Comment: At this time or terror threats, building a nuclear power plant is reckless. 

(DW-0384 4)

Comment: Nuclear power has proven a dangerous way to go. Increased threat of terrorism

and the possibility of catastrophic accident should all be considered before the U.S. Nuclear

Regulatory Commission decides to build more nuclear plants. (DW-0397 6)

Comment: Sitting at North Anna, less than three hours away from the nation's capital makes it

a primo target for terrorists. (DW-0408 6)

Comment: I oppose construction for the following reasons: 9/11 has shown us that terrorists

can use our own resources against us. It is too easy for terrorists to cause a horrible nuclear

accident by attacking the reactors or irradiated waste at North Anna. (DW-0409 3)

Comment: I assert that a Lake Anna site is not suitable for a nuclear reactor due to the

catastrophic environmental damage that might ensure from a terrorist strike on the nuclear

facility, including damage to places downwind of Lake Anna [maps included], such as

Washington, D.C. The treat of such a strike on an energy plant is often stated by top

government officials ... you also have a part in the war on terrorism. ... Therefore: (1) You

should not authorize new nuclear reactors near or upwind of major metropolitan areas,

especially Washington, which is a prime symbolic target for terrorists. (2) You should not renew

or extend operating permits for current reactors near or upwind of major metropolitan areas,

such as the old ones here at Lake Anna. (3) You should shut down the Indian Point reactors,

which are a mere 35 miles from Times Square in New York City and which have one spent fuel

pool that is mostly above ground. ... It is your duty to protect the public by removing these

targets from us and by barring new ones. (DW-0410 1)

Comment: In view of the fact that the CIA is positively predicting a major terrorist attack in the

near future, it is positively foolhardy to put four nuclear reactors together at North Anna about

50 miles from Washington, D.C., creating a target for a stupendous terrorist attack. This is a
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-42 December 2006

private facility that anyone with an AK47 could go into and shoot up the place. What kind of

security and evacuation plan is on the books for this? (DW-0413 1)

Comment: We fail to understand why the NRC is not considering the security implications of

new plants post 9/11, especially in the light of the fact that the nation's capital, a highly symbolic

terrorist target, is often downwind of North Anna. (DW-0424 2)

Comment: My concerns about increasing Virginia’s and America’s reliance on nuclear energy

are based on ... the chance for terrorists to take advantage of any of those [fuel cycle] steps.

(DW-0426 7)

Comment: I would like to express my concern over creating additional potential targets for

terrorists. If we build more nuclear reactions in North Anna, that may increase how attractive it

looks to terrorists, especially given its proximity to Washington, D.C. Every transport of

radioactive waste from North Anna to Yucca Mountain on our nation's highways is an additional

opportunity for terr[or]ist action. I am confused by our President's repeated statements that

terrorists are considering targets such as nuclear facilities, followed by statements that the

future of America's energy needs lies in nuclear energy. (DW-0426 18)

Comment: Safety and Terrorism – this is clearly a socioeconomic issue that should be

addressed in an EIS given the proximity to large population centers including Washington, D.C. 

(DW-0432 5)

Comment: Nuclear power plants have known vulnerabilities to terrorist attack and sabotage.

According to the 9/11 Commission Report, al Qaeda specifically discussed targeting U.S.

nuclear plants. Fuel storage pools, dry storage facilities, and reactor control rooms are not

designed to withstand the type attack that occurred on September 11, 2001. The Government

Accountability Office (GAO) concluded in recent testimony before the U.S. Senate that cargo

and general aviation airfields, three of which are located very close to the North Anna Site

(DEIS, page 2-10), are more vulnerable to security breaches than commercial airports. Ignoring

the threat because it is “highly speculative” does not make the threat go away, and indicates

one shortfall of using an exclusively risk-based approach. (DW-0437 65)

Comment: The lack of analysis and discussion of security against terrorist threats is a major

omission. This subject is clearly part of today’s “human environment”. It is ironic that on the

morning of the Louisa public hearing that the federal government announced that the U.S. is still

the target for such acts yet the ESP process seems to ignore any analysis and disclosure on

this subject. (DW-0438 57)
Comments Outside the Scope of the EIS

December 2006 5-43 NUREG-1811, Volume II

Comment: Section 4.5.1.1 fails to account for the fact that the construction and new plant

operation will provide increased access to the site which could increase the potential for

accidents and terrorism. (DW-0438 96)

Comment: Why isn’t the independent spent fuel storage facility underground (Page 4-40

line 10)? This would help protect it from air attacks. (DW-0438 114)

Comment: Especially in this time of terrorism we do not need more nuclear plants. 

(DW-0493 2)

Comment: Up to four reactors in one site will invite sabotage and terrorism. Surely, this is not

a good strategy. (DW-0570 3)

Comment: I don't believe you when you say that the issue of terrorist attacks on the plant will

be “addressed” in another part of this process. (DW-0614 1)

Comment: With rising tensions and increasing threats of new terrorist attacks inside the

United States, it seems a VERY poor time to be thinking of building more reactors at North

Anna. (DW-0614 6)

Comment: I am horrified that this is even considered in light of nuclear disasters that have

happened in the past, such as Three Mile Island. I do not want to raise my children in the

shadow of a terrorist target. (DW-0654 3)

Comment: I feel this form of power is extremely unwise in our present political climate. The

potential for terrorists to infiltrate the reactor's construction process seems great and dangerous,

to me. (DW-0655 2)

Comment: Why are we considering building new nuclear reactors? This is a step backward. 

Do you remember Three Mile Island? Chernobyl? Nuclear reactors are not safe due to

potential accidents or incidents of terrorism. Al Qaeda recently called on its people to plan more

terrorist activities outside of Iraq, including more potential violence within the United States. It is

a proven fact that Al Qaeda has considered attacks against nuclear reactors. ... Exposes on

national news show that reporters can easily walk right into nuclear facilities and be there for

long periods of time before a guard even approaches them, plenty of time to detonate a bomb. 

(DW-0670 3)

Comment: If there is any situation where we need to pay attention to the threats of terrorism, it

is with accumulations of radioactive materials at easily visible sites on American soil, especially

near major urban targets like New York City and Washington, D.C. The increase in risk

resulting from the increase in high level nuclear waste on the site that would be caused by one
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-44 December 2006

or two additional reactors needs to be part of a realistic assessment of risk, and a realistic

environmental impact assessment. Please include it in your next draft. (DW-0685 11)

Comment: What precautions are being taken regarding the potential risk of attacks against the

power plant? (DW-0729 3)

Comment: Nuclear power plants are ideal terrorist targets making us all that much more

vulnerable at a time in our history when we need to secure the safety of our people.

(DW-0741 3)

Comment: Shortly after the 9/11 attacks there was fear that nuclear power plants could

become targets for terrorists. This could still happen. (DW-0822 5)

Comment: During the meeting, we found out there are ground guards and ground based

security, but no air security. All this radioactive trash is a tempting target for a dirty terrorist

bomb, especially since we are only 75 wind miles from the heart of DC. When the winds come

from south-southwest (as they often do), Washington, D.C. is directly downwind from the North

Anna Nuclear Plant. ... Terrorists do suicide missions. ... And North Anna has no protection

against these. (DW-0823 3)

Comment: Are you all nuts???? We already have a big target sign on our state for terrorists

since we border DC, do you want to add another reason for Virginia to be a “place” of interest?

(DW-0846 2)

Comment: We can figure out better ways to boil water that do not come with terrorist threat. 

(DW-0861 2)

Comment: Terrorism. I have never really worried about this with regard to Lake Anna. There

are larger targets closer to major population centers. However, with two or three reactors, it

would be much more attractive. (DW-0955 4)

Comment: Among my concerns are: The possibility of terrorists attacking nuclear power

plants--we already know Al Qaeda has considered hitting nuclear facilities. Security at existing

nuclear plants leaves much to be desired. These plants should be secured before any other

reactors are even thought about. (DW-0998 3)

Comment: Here in the DC suburbs, we are not too far from the site [North Anna] to be

concerned about nuclear ...sabotage. (DW-1019 3)
Comments Outside the Scope of the EIS

December 2006 5-45 NUREG-1811, Volume II

Comment: In a time of increased terrorist threats, new nuclear power plants increase physical

and economic risks to central Virginia residents, Dominion customers and shareholders, and 

nuclear industry employees. (DW-1099 2)

Comment: I am also worried about the increased terrorist risk. (DW-1151 4)

Comment: Fuel rods have gone missing in the past years, and until the nation has a safe and

secure means to store spent fuel, the rods pose a risk to the environment and in a worst-case 

scenario, could end up in the wrong hands. (DW-MM1 8)

Comment: In a time of increased terrorist threat, new nuclear power plants increase physical

and economic risks to central Virginia residents, Dominion customers and shareholders, and

nuclear industry employees. Al Qaeda is known to have considered nuclear power plants as a

target for an attack. Terrorist threats and heightened Threat Advisory Levels (Orange and Red

level) may lead to severe restrictions on public access to Lake Anna, which could impact local

businesses dependent on public use of the lake. This has already happened at over a dozen

lakes with nuclear plants around the country. Adding additional reactors to the North Anna

facility could also increase its attractiveness as a terrorist target, increasing the frequency and

likelihood of lake closures. (DW-MM4 6)

Comment: Our industry is one of the few industries that’s regulated by the federal government

in the area of security. Since 9/11, we've updated our security requirements according to the

NRC's mandates twice, most recently in October of last year. And we meet security

requirements because it's important not only to protect our workers, but to protect their families

and their neighbors. That’s why we do it. We have three ways that we protect our plants, our

workers, and our neighbors: structural security at our plants, very strong structures;

technological security with access detection equipment; and we have human security, 8000 well

trained, well armed officers at 64 sites across the country. Three ways, three redundant ways

to protect our plants. (DT-0027 9)

Comment: The concentration of four domed reactors makes an inviting target for those who

constantly plot attacks against the United States of America. (SW-0021 2)

Comment: [T]he document fails to adequately address the potential for a terrorist act. ...and

North Anna is a possible target. The fuel and waste storage areas at North Anna are especially

vulnerable to a terrorist attack. How is this in the public interest to worsen the situation? 

(ST-0036 2)

Comment: It [building new reactors] would also add to current problems of radioactive waste

and security from terrorism. (SE-0035 2)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-46 December 2006

Comment: Where are the NRC safety protections for terrorist attacks against the plant and

dam. If the dam is blown up and breaks, the Lake Anna water will run downstream. ...The

public must be involved with the safety of the nuclear reactors, whether it is at the plant, at the

dam, together with how, where and how long the spent nuclear fuel is stored. (SE-0022 5)

Comment: [H]as NRC correctly analyzed...the vulnerability of the North Anna site to...terrorist

threats...what are the impacts if terrorists manage to blow a hole in the dam, suddenly draining

the lake and disabling the three units that depend wholly or in part on cooling water withdrawals

from the lake, or attack the spent fuel storage pools. ...a recent 9th Circuit Court decision

directing the NRC to analyze the reasonably foreseeable environmental impacts of a terrorist

attack on a California reactor’s spent fuel storage facility suggests that such analysis should be

part of the NEPA coverage for the North Anna ESP. (SE-0040 18)

Comment: Since Chapter 8 should address system design alternatives the EIS 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. (SE-0045 40)

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 has

stated that a terrorist attack on a nuclear facility can be “postulated”. (SE-0045 31)

Comment: A successful attack, a terrorist attack, such as the one that was thwarted this week

could halt new construction even after significant expenditures are made and sight preparation.

...Robert Mueller, the FBI Director, testified before the Senate Select Committee in 2005 stating

"Another area we consider vulnerable and target rich is the energy sector particularly nuclear

power plants. al-Qaeda planner Sheikh Mohammed had nuclear power plants as part of his

target set and we have no reason to believe that al-Qaeda has reconsidered." (ST-0008 3)

Comment: I ask you to look at the collaterals that go along with it. ...the power plants that

Pakistan, and Korea, and others have put out, that this is the material for nuclear bombs. 

(ST-0038 4)

5.6 NRC Oversight

This section lists comments related to the NRC staff oversight of nuclear power plants.

General Response: The existence of and the authority granted to the NRC are the result of

legislation enacted by the Congress: the Atomic Energy Act of 1954, as amended, and the
Comments Outside the Scope of the EIS

December 2006 5-47 NUREG-1811, Volume II

Energy Reorganization Act of 1974, as amended. Under that authority, the NRC has

established its regulatory framework in Title 10, Energy, of the Code of Federal Regulations and

in guidance such as Regulatory Guides, Standard Review Plans, Review Standards, and Office

Instructions.

NRC staff activities to fulfill its NEPA responsibilities are governed by NRC rules and regulations

(see 10 CFR Part 51) and the regulatory guidance developed in support of 10 CFR Part 51. 

Development of the framework and conduct of such activities are performed in open and

transparent forums that actively involve interested stakeholders (whereever they may reside),

provide for public scrutiny, result in regulatory positions, and allow for change in positions based

on fact.

Setting energy policy is not within the purview of the NRC. Implementing and executing a

regulatory structure to provide for, among other things, the safe use of nuclear material, the

protection of public health and safety, the protection of the environment, and the common

defense and security, are within the purview of the NRC. The Commission and its staff take this

obligation seriously. When laws, such as the Price Anderson Act, directing NRC actions are

enacted, the NRC ensures that programs exist to comply with the laws.

The Commission recognizes that other stakeholders have important roles in assisting the NRC

in fulfilling its independent responsibilities and obligations. Clearly these stakeholders include

license holders, plant operators, other government officials, and the public. The NRC’s

oversight and inspection programs are expected to result in an effective regulatory structure. 

There are numerous examples, such as the events of September 11, 2001, and the DavisBesse reactor vessel head corrosion, that demonstrate how robust and resilient NRC programs

are and how regulatory improvements are implemented. 

Comment: “The Nuclear Regulatory Commission should have [to] but do [did?] not identify or

prevent the corrosion at Davis Besse [nuclear plant near Toledo, Ohio] because its oversight did

not generate accurate information on plant conditions.” (DT-0005 4)

Comment: As a nuclear engineer, I understand nuclear power and the only thing I worry about

is the regulation of this effort. As a federal employee, I also understand the actions of

government. As far as I am concerned, the Nuclear Regulatory Commission is the best of the

regulation agencies within the government. This does NOT mean that more can't be done to

strengthen the NRC. (DW-0360 4)

Comment: We respectfully remind the NRC that they are public servants whose number one

priority is, or should be, the safety of the public. (DW-0424 5)
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NUREG-1811, Volume II 5-48 December 2006

Comment: NRC is supposed to be looking after our interests, not the interest of Dominion,

which sometimes I question, I think they're looking after the interest of Dominion. (ST-0002 3)

Comment: The Nuclear Regulatory Commission shortcomings are also troublesome in that we

may be putting nuclear economic interests ahead of safety and public confidence. It was

27 years ago that President Carter's Commission found a mind set at the Nuclear Regulatory

Commission that was preoccupied with the licensing of plants and not giving primarily

consideration to overall safety issues. (ST-0008 4)

Comment: [S]hortcomings of the U.S. Nuclear Regulatory process were clearly implicated in

the 2001 near accident at the Davis Besse plant in Ohio. (ST-0008 5)

Comment: For a long time I felt that the NRC was doing this [protecting the public health and

safety], but they've moved to be a rah-rah club for the nuclear industry. And they've moved

away from our common goal, to protect us, our health and safety, our defense. Anybody with

Defense would say you don't build another one of these potential targets. You protect the

environment? You can't protect the environment by creating the most lethal poison that's going

to be around for 100,000 years. (ST-0024 1)

5.7 Comments in Support of or Opposed to Nuclear Power

This section lists comments expressing support of or opposition to nuclear power as their

primary focus. The comments in Section 5.7.1 support nuclear power, and those in

Section 5.7.2 are opposed to it. These comments express the opinions of the commenter and

provide no information warranting staff evaluation in the EIS. The subjects of all of these

comments have been determined to be out of the scope of this EIS.

General Response: The ESP process is not a public referendum or vote. Rather it is a

process designed to assure that applicants meet applicable NRC safety requirements before a

permit is granted. The ESP process also ensures that the ESP complies with the requirements

of NEPA.

In addition, the Energy Reorganization Act of 1974, which created the NRC from the regulatory

arm of the abolished Atomic Energy Commission, ensured that the NRC would not have a

promotional role regarding nuclear power; that is now the domain of the U.S. Department of

Energy.

Based on the foregoing, comments either in favor of, or opposed to, nuclear power do not

provide new information, and no changes were made to this EIS as a result of these comments.
Comments Outside the Scope of the EIS

December 2006 5-49 NUREG-1811, Volume II

5.7.1 Support for Nuclear Power

Comments below express support for nuclear power. They express the opinion that nuclear

energy is safe, clean, reliable, cost effective, and necessary for baseload power generation.

They state that nuclear power reduces global warming and supports nonproliferation by taking

uranium out of Russian warheads. Commenters express the view that use of nuclear power

helps leave a better world for the future by reducing greenhouse emissions and helps reduce

carbon dioxide emissions in America. Commenters also express the view that nuclear power

has a proven safety record.

General Support

Comment: Every power source has economic and environmental costs, and there is no such

thing as zero risk. (DT-0014 2)

Comment: Being a victim of high methyl concentrations in my blood due to eating fish from our

local grocery stores and seafood markets, I’m acutely aware of the environmental problems

induced by effluent from coal generated plants. (DT-0014 3)

Comment: From casually and professionally studying the concepts from coal fly ash

composition using particle accelerators to other power sources, to the accidents at Three Mile

Island and Chernobyl ... I have concluded that nuclear power has significantly lower

environmental and economic cost than coal-fired, other fossil fuels, and other means of

generating electricity for our transmission grid. Some of the world's top environmentalists,

including Wyeth-Ayerst, James Lovelock, Patrick Moore who is the co-founder or one of the

co-founders of Greenpeace, Bishop Hugh Montefiore who is a long time board member of the

Friends of Earth, also agree. (DT-0014 4, DT-0014 5)

Comment: In fact, I will argue that nuclear power is the only energy source which takes full

responsibility for all of its waste and fully costs them in its product of electricity. This itself gives

rise to a negative perception. Since the wastes are retained rather than being discharged into

the environment and forgotten, many are stored in particular places, and they are represented

incorrectly as an unsolved problem. (DT-0014 8)

Comment: I am extremely proud of the very significant contribution that nuclear science and

technology makes every day to improve our quality of life. This contribution is most time very

quiet, unglamorous, and very much behind the scenes, and most people truly aren't aware of it. 

In particular, I think that nuclear power is an unsung hero, that every day it generates more than

35 percent of the electricity in Virginia, safely, cleanly, inexpensively, and reliably...I know that

nuclear power is the most environmentally sound, large-scale option for new energy investment. 

Nuclear power minimizes environmental impact by using a small land area and a small amount 
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-50 December 2006

of fuel to produce a large energy output. Furthermore, it accomplishes these without releasing

any hazardous emissions, and the byproducts of nuclear power are the most manageable of

energy waste burn-ups being thoroughly contained in retrievable and reusable. (DT-0025 1)

Comment: The diversity of supply, including nuclear, helps keep us on an energy reliable and

affordable track and helps reduce our dependence on foreign energy supplies. And Dominion

isn’t alone in this endeavor. (DT-0027 3)

Comment: Today more than 100 nuclear power reactors are important to America's energy

diversity mix. They provide us with reliable electricity, affordable electricity, safe electricity, and

emission free electricity. (DT-0027 11)

Comment: With potential hydro sites limited, nuclear power is the most efficient and

economical source of the generation. (DT-0029 12)

Comment: We need more nuclear power. (DT-0043 2)

Comment: I'm here tonight to voice my support for one of the most misunderstood

technologies of today’s time, the generation of electricity using nuclear energy. (DT-0046 1)

Comment: We believe that nuclear energy is safe, clean, reliable and cost effective, and as

such, it should continue to be an important part of a balanced energy mix. (DT-0052 2)

Comment: In fact, nuclear energy is in many ways better and safer than conventional power

producers like coal, gas and oil. There are virtually NO air pollutants from nuclear power. 

There are virtually NO water pollutants from nuclear power. And there is very little solid waste

generated by these plants. Therefore, they are environmentally much cleaner. (DT-0063 1)

Comment: More nuclear plants are needed to offset coal, oil, and especially natural gas plants. 

(DW-0360 1)

Comment: I support expanding the use of nuclear power in the United States. Constructing

new reactors would be good for Virginia’s environment, good for taxpayers, and good for

residential and commercial ratepayers. (DW-0370 8)

Comment: I would prefer that Dominion meet its power capacity needs using clean, safe, and

cost-effective energy like nuclear. (DW-0370 9)

Comment: I would like to see more Nuclear Fuel Plants so that coal, natural gas, etc., could be

used in other areas. (DW-0440 3)
Comments Outside the Scope of the EIS

December 2006 5-51 NUREG-1811, Volume II

Comment: Numerous comments have been made advocating that solar and wind power be

employed instead of nuclear power. Currently available solar and wind equipment would

require approximately 40 square miles of land to produce 1000 MW of power. This is much

larger than the area which will be disturbed by the proposed nuclear installation. Although this

proceeding cannot properly consider a different type of power plant than the one proposed, the

LARGE environmental impact of a comparable solar or wind installation would preclude their

consideration on environmental grounds. ... Solar and wind systems do not enjoy large

economies of scale. Systems sized for individual homes or businesses are not much more

expensive per kilowatt than large scale installations. Net metering of these sources is typically

available, so that expensive battery systems are not required. Those individuals who wish to

get their power from these sources are free to do so, without imposing additional costs on those

Dominion ratepayers who cannot afford it. (DW-0645 1)

Comment: The cost (both environmentally and economically) of operating an environmentally

clean nuclear generator is considerably less than that required for fossil fuel plants, which

generate smog, acid rain, and other pollutants. Both the fossil fuel and nuclear power plants will

have potential environmentally negative aspects. However, weighing all the alternatives

available with current off the shelf technology, I would opt to champion the cause of nuclear

power generation over fossil fuels from an economical and environmental points of view. 

(DW-0757 3 and DW-0760 2)

Comment: Nuclear energy is far cleaner and more efficient then the feasible alternatives. 

(DW-0879 2)

Comment: The other primary forms of producing energy have a negative impact on climate

change and that is a serious problem for mankind. (DW-0976 3)

Comment: I saw the first nuclear power plants go into service in Virginia in 1972 and always

felt that nuclear power was the cleanest and safest source of energy for electric power

generation. (DW-1007 1)

Comment: I wish ... to elaborate more on my support for nuclear electricity generation in

general. Therefore, when considering all the other options that are available at present, I am in

favor of nuclear energy to supply the remainder. It does not pollute the atmosphere, it is

economically attractive, it has a proven track record of safety and efficiency and it can provide

electricity in the ways renewable sources and conservation cannot. (DW-1148 8)

Comment: I am also bothered by all of the air pollution from electrical generating plants and

automotive exhaust. (DW-1235 1)
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NUREG-1811, Volume II 5-52 December 2006

Comment: I am a 1000% supporter of nuclear power! I do not understand how France, The

Netherlands, China and many other countries can have a very successful and safe nuclear

industry and the Sierra Club can claim that this is not a safe technology! Our own nuclear navy

is very active and safe! In my humble professional opinion the Sierra Club will whine about

solar power because it takes sunshine away from plants and trees! So let it be known that in

every possible way I, and so many others that I share the wonderful natural world with, support

nuclear power, the building of nuclear power plants and the future of nuclear power. 

(DW-1235 2)

Comment: To quote from the form letter sent by the opponents: “I would prefer that Dominion

meet its power capacity needs using clean energy like wind or biomass.” If Dominion proposed

to build a wind farm with a capacity of 1000 MWe at the North Anna site, I am sure the NIMBYs

would be loud and vehement in their opposition. (DW-1248 3)

Comment: Please add the attached 33 signatures to the 540 signatures supporting the

NA-YGN petition that were already provided to NRC staff at the NRC public hearing held last

February 17, 2005 in Louisa Co. As stated at the hearing, all these signatures supporting

Dominion's proposed new nuclear reactors at North Anna, were obtained in only one day. 

(DW-0417 1)

Comment: I am extremely proud of the very significant contribution the nuclear science and

technology makes every day to improve our quality of life. ...It's an unsung hero that every day

generates more than 35 percent of the electricity that we consume in Virginia and it does that

cleanly, safely, inexpensively and reliably. ...Nuclear power minimizes environmental impact by

using a small amount of land area and a small amount of fuel to produce a large energy output. 

Furthermore, it accomplishes this without emitting any negative gas emissions and furthermore,

the byproducts of nuclear power are the most manageable of energy waste products because

they are totally contained, transportable and reuseable. (ST-0013 2)

Comment: I firmly believe that nuclear power is going to lead the way in the 21st century until

there is something viable, better for the majority of the power we consume because we

consume a lot. (ST-0023 5)

Comment: Nuclear energy is safe, clean and reliable and is an important part of a balanced

energy mix. Currently, nuclear provides about one-fifth of our nation's electricity and about

one-third of Virginia's. In Virginia, the power output of the North Anna plants represent about

seven million metric tons of carbon dioxide emissions avoided each year. (ST-0012 1)

Comment: I wanted to give to the NRC 1,190 signatures that the NA-YGN, the North American

Young Generation in Nuclear, has collected for the last three or four weeks and this is from
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December 2006 5-53 NUREG-1811, Volume II

people all over the area and actually from all over North American in support of nuclear power

and the new nuclear in Virginia in particular. (ST-0013 1)

Comment: [N]uclear energy doesn't spew its waste into the air, or spill it into the water. The

residents of Lake Anna never have to breathe it, they never have to see it, they never have to

smell it, you never have to taste it. ...It will never aggravate a child's asthma, or speed up global

warming, and it will never disrupt the flight path of migrating birds. ...When I decide what I want

my legacy to be, I don't want it to be a hot earth with droughts and melting ice caps, hurricanes,

disappearing glaciers. I'd rather it be clean, efficient, environmentally friendly nuclear power. 

(ST-0027 2)

Comment: We do need, in the nuclear industry, the NRC and all of us involved, to push

forward the concept of the generic plans for reactor plants, so that reactor plants can be built

swiftly, efficiently, consistent with good, safe practices. That is coming forward, but needs to be

pursued much more rapidly. (ST-0034 4)

Comment: We believe that nuclear energy is safe, clean, reliable and cost effective, and as

such, it should continue to be an important part of a balanced energy mix. (SW-0009 2)

Baseload Power Needed

Comment: Solar and wind will not produce baseline power, period...Now, they're great at

producing peak power and maybe we should consider them for that, but for base power, we

need nuclear power, and that's just the end of that argument. (DT-0043 3)

Comment: I emphasize baseload generation because many opponents to nuclear power seem

to miss this significant factor. I agree that solar and wind power should continue to provide

more and more power as a percentage share of total power generated. Although these

technologies are maturing, getting a large concentration of energy is not possible due to the

distributed nature of the ultimate energy source, the sun and the wind. Even when solar and

wind power is applied to its fullest extent, these sources cannot meet the country's overall

demand for electricity. The only environmentally conscious solution to adding baseload

generation is nuclear power. (DT-0046 3)

Comment: Now if we do not have nuclear power, what does that leave? Solar, wind, tidal,

etc.... These technologies are either not available or mature enough (or both). The most

mature, wind power, is noisy, expensive, and can not supply BASELINE power. It might be

great for peak power with more research and maturation, but it will never supply BASELINE

power. The same problem exists for solar except that it is even less mature and again, cannot

supply BASELINE power. This leaves nuclear to supply BASELINE power. I highlight

BASELINE power because this is where Public Citizen apparently is missing the point. What do
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NUREG-1811, Volume II 5-54 December 2006

they suggest to replace BASELINE power when they kill fossil fuel and nuclear? The source of

the power of course says nothing about conservation. Conservation should be the most

important item on the energy list, but remember, you CANNOT conserve yourself to zero power

usage! The only source that can supply BASELINE power and NOT foul our atmosphere is well

regulated nuclear power. (DW-0360 3)

Comment: I am in favor of using solar and wind generation to maximum potential. However,

much like hydroelectricity in the past, the number of economically and environmentally feasible

locations is limited. And, as one member of the audience pointed out, these sorts of energy

sources cannot be guaranteed to be available 100% of the time and are thus unreliable. And

although it may seem incredible to say that solar and wind are unenvironmental, it is not

inaccurate to say that these technologies require significant land area and opposition to their

visual pollution has already arisen. No energy generation technology is perfect, and none ever

will be. I am clearly in favor of conservation. ... All these things put together should clearly

indicate to any rational person that renewable energy sources and conservation practices alone

cannot provide all the energy this nation requires. Neither now, nor in the future. (DW-1148 9)

Comment: In order for Virginia to continue to be a place for families to live and businesses to

thrive, we need reliable, safe, clean and affordable energy. Nuclear has been providing much

of this energy in Virginia for the last 30 years and it's been doing it safely and economically. As

we move forward, we will need all forms of non-polluting energy to cover our current energy

needs, not just the renewables, not just nuclear, but all of them. ...That's why I support the idea

of expanding the use of nuclear energy in Virginia particularly at North Anna Power Station. 

(ST-0020 8)

Comment: I think that nuclear power is an unsung hero, that every day generates more than

35% of the electricity we consume in Virginia, safely, cleanly, inexpensively and reliably. 

(SE-0025 1)

Energy Independence

Comment: I favor a goal of energy independence in this country. I think it's a goal that

everyone would want. Nuclear power supplies 20 percent of our nation's energy. Coal-fired

plants is 51 percent, which causes problems as you know, and natural gas is 17 percent of our

energy. (DT-0011 1)

Comment: Nuclear power decreases our need for foreign oil and provides us with the best

future means to generate hydrogen to potentially provide a new fossil fuel, independent, and

environmentally friendly means of powering our vehicles. Let us resolve to use the appropriate

energy sources based on its true market costs and benefits. (DT-0014 9)
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December 2006 5-55 NUREG-1811, Volume II

Comment: This kind of an initiative must occur if we are to lessen our country's dependence

on fossil fuels. (DW-0858 3)

Comment: Currently, nuclear power provides about one-fifth of our nation’s electricity and

about one third of Virginia's. (DW-0863 1)

Comment: [N]uclear power plants such as North Anna provide safe, reliable and affordable

electricity that is important to our economy, and helps our Commonwealth and Nation achieve

greater energy independence. (SW-0012 2)

Comment: I would like to speak in favor of moving nuclear energy forward as rapidly as we

can. ...We need energy independence, and nuclear is the way to go. It is a clean form of

energy. (ST-0034 1)

Environmental Aspects

Comment: The decisions that need to be made about where energy is going to come from are

very, very complex. No matter what kind of energy we decide to use or you decide to use, there

are always going to be impacts. There are impacts from any energy source. (DT-0004 3)

Comment: That is, in spite of the misinformed and skewed claims of the small minority of

career anti-nuclear activists, nuclear power has perhaps the smallest impact on the

environment, including water, land, habitat, species and air resources. And life cycle emission

analyses show that per kilowatt hours, the impact of nuclear energy is among the lowest of any

form of electricity generation, including wind and solar. (DT-0020 4)

Comment: Several people have said nuclear power does not emit greenhouse gases. Last

year alone nuclear energy prevented 700 million tons of carbon from going into the atmosphere. 

That’s the equivalent of taking all the carbon out of nine out of ten cars on the road across

America. (DT-0027 8)

Comment: So you can fight against nuclear power, but you trade it for global warming. 

(DT-0028 1)

Comment: Over the past couple of years I’ve been reading the press and have been

impressed by the trend I’ve seen that favors construction of new nuclear power plants. There

are various things behind this. The first reason is the support that nuclear power is gaining from

a variety of environmentalists. (DT-0032 1)
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NUREG-1811, Volume II 5-56 December 2006

Comment: Of all energy sources, nuclear energy has the lowest impact on the environment,

including water, land, habitat, species, and air resources. Nuclear energy is the most

eco-efficient of all energy sources because it produces the most electricity in relation to its

minimal environmental impact. (DT-0046 7)

Comment: Nuclear power is a very positive power source for the future offering clean power

generation with little or no greenhouse gas emission. I want nuclear power to help America

lead the world in CO2 reduction initiatives to leave the world a better place for my children.

(DW-0442 2)

Comment: In practical terms, nuclear energy is the best possible answer to the environmental

and economic hardships that the people of the world are already experiencing. ... The time to

support nuclear energy, and the government and the industry to act is overdue. The time to

build advanced nuclear reactors is now. ... nuclear energy must be harnessed by building many

more modern nuclear plants for the current and coming generation to enjoy cleaner

environment, economic prosperity, and less dependence on foreign oil. (DW-0812 1)

Comment: Since coal fired generation produces large amounts of NOx, SOx, lead, mercury,

and other pollutants, the proposed plant will reduce such air and water pollution proportional to

it's capacity. This reduced pollution may be reflected in air or water quality improvements

around the proposed site, or in other areas of the state depending on the particular coal plant

which is not dispatched on any given day. Should the Commission determine that any of the

potential environmental impacts are other than SMALL, it should take into account the positive,

long term improvement in air and water quality that would ensue from the reduced operation of

coal fired facilities to reduce the net impact. (DW-0645 2)

Comment: Clean air benefits are why support for nuclear energy is widespread among leaders

in government, business and academia and is growing among many environmentalists. Six out

of 10 self-described environmentalists favor nuclear energy. (DW-0668 1)

Comment: Coal, gas, oil, and biomass all eject pollutants into the atmosphere for all to

breathe. Every particulate of waste that these energy sources have ever created is out there

and in many cases, never will be retrieved. True, trees and plants will clean some of these

pollutants from the atmosphere, but proving how much and how fast is next to impossible. 

(DW-1148 10)

Comment: Of all energy sources, nuclear energy has the lowest impact on the environment,

including water, land, habitat, species and air resources. Nuclear energy is the most

eco-efficient of all energy sources because it produces the most electricity in relation to its

minimal environmental impact. Nuclear energy is efficient and cost- effective due to its high
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December 2006 5-57 NUREG-1811, Volume II

plant performance coupled with modernized plants, low production cost, future price stability,

and clean air compliance value. (SW-0006 2)

Comment: I know that nuclear power is the most environmentally sound, large-scale option for

new energy investment. Nuclear power minimizes environmental impact by using a small land

area and a small amount of fuel to produce a large energy output. Furthermore, it accomplishes

this without releasing any greenhouse gas emissions. (SE-0025 2)

Safety

Comment: As nuclear technology relates to electricity generation, we wanted to tell everyone

the success story that is nuclear power in our country. Nuclear energy is safe, clean, and

reliable as an important part of a balanced energy mix. (DT-0020 1)

Comment: My health and safety net of my family and friends always come first. I also believe

that we as society must be good stewards of the environment. I would not work in this industry

[nuclear] if it violated these principles. (DT-0020 8)

Comment: As a former project manager responsible for preparing the safety evaluation reports

for licensing certain nuclear plants, I think you covered about as much as you could regarding

the safety issues in Section 5 based on the limited information available on the assumed plant

parameter. (DT-0029 2)

Comment: James Lovelock, who has been mentioned previously. He says, “Nuclear energy

from its start in 1952 has proved to be the safest of all energy sources.” That was in 2004, mind

you, after the 9/11/2001 incidents. (DT-0032 2)

Comment: Patrick Moore writes as follows: “nuclear energy is the only non-greenhouse gas

emitting power source that can effectively replace fossil fuels and satisfy global demand.”

(DT-0032 3)

Comment: This is the safest form of power generation and least pollutant of the times. I would

recommend another plant at this site. (DT-0060 3)

Comment: As for the safety issue, the opponents keep talking about Chernobyl and Three Mile

Island. Well, that’s all they can talk about. That’s because nuclear power plants are designed

to be safe and are tightly regulated to prevent an impact on public health. They are built with

several barriers between radioactive material and the outside. In fact, NRC established safety

goals that the acceptable risk to the average individual within the vicinity of a nuclear plant

should be less than 0.001%, whether from an accident itself or from cancer resulting from

radiation exposure. (DT-0063 2)
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NUREG-1811, Volume II 5-58 December 2006

Comment: I recognize that several issues such as security are not addressed in the ESP

process and these things concern some of the area citizens. Many of these people are

concerned but not very well informed. The security [at] Dominion nuclear power plants has

been much better than at any other place that I've worked, including Shippingport Atomic Power

Station. Having worked in the safety analysis field of nuclear power for over 30 years, I am

convinced that many of the objections raised to nuclear power are grossly overstated. If nuclear

power was as bad as its vigorous opponents contend, then it would have been very obvious

years ago. (DW-1167 6)

Other Benefits

Comment: Nuclear plants by the end of this year will have rendered 10,000 warheads useless

by taking uranium out of those Russian warheads and using it as fuel to power U.S. cities.

That’s a significant nonproliferation goal that we’re achieving today and rendering warheads that

used to be aimed at our cities useless and now using them to power our cities. (DT-0027 12)

Comment: Nuclear power to include reprocessing like in the Integral Fast Reactor System as

developed at Argonne National Laboratory and demonstrated Argonne National Laboratory -

West, is the only source of power that should even be considered by any power company, the

NRC, and Public Citizen. I think once the REAL facts and the morals behind power generation

are given to the people, the citizens of this country will DEMAND no less that nuclear power and

the integral fast reactor system. (DW-0360 5)

Comment: [N]uclear is one of the best answers we have available today, particularly if you are

concerned about the members of your community that struggle to pay their electric bill every

month. (ST-0025 4)

Comments Against Opposition Groups

Comment: I have seen scare tactics and misinformation that characterized the campaign of

career anti-nuclear ideologues. Recently two venerated leaders of the Green, James Lovelock

of the United Kingdom and Patrick Moore, founder of Greenpeace, publicly criticized such

distortion of the facts. Lovelock has said that the fears these types of anti-nuclear organizers

have about the safety of nuclear energy are irrational and exaggerated, his words. Moore has

said that such groups have abandoned science and logic in favor of emotion and

sensationalism. I have found that in many cases, the misinformation campaign is intentional. 

(DT-0020 6)

Comment: I would like to suggest that you take the names and addresses of all of these

agitators and demonstrators opposing nuclear power and promptly TURN OFF THEIR

ELECTRICITY...FOREVER. AND require that they make up the taxes from our nuclear power
Comments Outside the Scope of the EIS

December 2006 5-59 NUREG-1811, Volume II

plant. They might just change their tune! They obviously don't understand that the world is

running out of fossil fuels and nuclear is the ONLY (safe and clean) solution. (DT-0063 7)

Comment: I’m pretty liberal, I'm a member of the ACLU, but on Nuclear power I have to break

from my usual stance. Don’t let the Environmental groups get you down. You have nuclear

energy supporters who are counting on you! (DW-0879 3)

5.7.2 Opposition to Nuclear Power

There were many comments received in opposition to nuclear power including four sets of

letters that were the same or very similar in content because they resulted from a letter writing

campaign. These are referred to by the staff as Draft mass mailing (DMM) comment letters and

are identified with the structure that includes letter 1 through 4 and the comment number within

the letter. Several forwarded mass mailing letters were received repeatedly, some numerous

times from the same commenters. Many of the comments received expressed fear of the safety

of nuclear power. Some commenters expressed their opinions of nuclear power as insanity,

disastrous, and flawed. There were negative comments aimed at the NRC and the U.S.

government. Many commenters stated that nuclear power is not the answer to U.S. energy

needs.

General Opposition

Comment: The summation of information is that nuclear energy is an irrational pursuit. It’s a

bad idea. So why after a 20-year hiatus is this great push to impose upon us this devil? 

(DT-0006 4)

Comment: And so I think nuclear power is a really bad kind of power, maybe one of the worst

invented. (DT-0008 1)

Comment: I'd like to keep our world safe, healthy, and beautiful for my generation and my

children's generation. How about you? (DT-0008 8)

Comment: I'll conclude by recommending that nuclear fission power plants be retired, and to

that end I kindly, respectfully, and most seriously urge anyone working for the Nuclear

Regulatory Commission to seek other employment where you can use your talents to provide

people with safe energy and a clean environment. (DT-0009 7)

Comment: Perhaps some of you, like me, were raised in the 1950s when we were taught that

the answer to all of society’s needs for clean, safe, cheap, unlimited energy was to be found

inside the atom. This is a hideous, perverted lie. (DT-0018 5)
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NUREG-1811, Volume II 5-60 December 2006

Comment: We are against breathing air full of radioactive particles, drinking water that poisons

instead of gives life, eating food that gives our children cancer for untold generations. How do

you explain the fact that we seem to be more willing to protect our fragile psyches from looking

honestly at the horror we are creating than doing whatever we have to do to protect our babies? 

We must stop hiding behind “we'll fix it tomorrow” or accidents never happen. We must speak

openly of the truth that we are talking about the end of life on this planet and perhaps the end of

life throughout the whole universe. We don’t really know. Because whether or not it comes by

terrorism or leukemia or poisoned air and water or the destruction of our DNA, death is the

inevitable end of this madness that is nuclear. We can do better, you all. We can do better. 

Don't you believe that these guys and ladies are smart enough and capable enough to figure

out ways to boil water that aren’t suicidal? I do. (DT-0018 8)

Comment: The 2004 Green Party of the United States platform calls for the dismantling of all

currently active nuclear power plants within five years. (DT-0041 5)

Comment: If this case, the end does not justify the means. If we were really smart, at this

point we’d say ?who gas” what a mistake, we’d carefully dismantle these things, and we’d look

to alternative energy sources. I was very glad to hear from the Dominion Power administration

that options continue to be open. (DT-0051 3)

Comment: Second, nuclear power generation is a messy, toxic business even when handled

well, and neither private industry nor the NRC has shown the fortitude for doing it well. 

(DT-0058 3)

Comment: My fervant wish is that the focus will shift, sooner rather than later, to invest in

finding “ways to boil water that are not suicidal.” Let the scientists and commissioners apply

their intelligence and expertise to this endeavor. (DT-0062 3)

Comment: I oppose new nuclear reactors there for the very environmental and safety reasons

which were not “allowed” during the early site permit process. (DW-0165 2)

Comment: No to any new nuclear plants!...Stop Now. (DW-0173 1)

Comment: We as citizens have the right to protest against anything else the DOE, would

submit, such as building more nuclear plants. We know about the energy executives giving the

Bush inaugural monies. This sends a clear message that the DOE, has further to go in

developing clean energy and saving the planet for future generations. Please note, many

groups will be watching in what is going to happen, with the energy issues. (DW-0177 2)

Comment: I am against all nuclear reactors from being built. (DW-0180 1)
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December 2006 5-61 NUREG-1811, Volume II

Comment: Do not license any new nuclear power plants. (DW-0188 1)

Comment: Please no new nuclear power plants for Virginia. I love this state. Help me protect

it for a very, very long time. Please. It just is not worth the risk. (DW-0197 1)

Comment: For the record we are all opposed to any nuclear expansion either here at North

Anna, or anywhere else in the world. (DW-0192 1)

Comment: No nuclear power plants in North Anna or anywhere else!...I am opposed to new

nuclear power. ... No nuclear power plants in North Anna or anywhere else! (DW-0274 2)

Comment: Nuclear energy must be phased out, not revived. (DW-0333 2)

Comment: This is a totally disastrous and ill conceived project and should be rejected. 

(DW-0335 2)

Comment: I understand the growing need for more energy, but I am opposed to getting this

energy from nuclear sources. (DW-0398 1)

Comment: I do not want any reactors at North Anna or Mineral or anywhere else. 

(DW-0404 6)

Comment: Nuclear is a flawed technology. (DW-0411 1)

Comment: My family is opposed to any new nuclear power plants being built for many

reasons. (DW-0412 1)

Comment: I have never forgotten [the Three Mile accident in 1979] as we lived close enough

to the plant to see the steam plume. What was true then, terrifying hundreds of people, is true

now. Spend millions of dollars for a plant carrying such a dangerous potential that it has the

power to wipe out populations? Not if I can speak out against it, and I am joined by many

others. (DW-0421 1)

Comment: Dominion Power and this Bush administration ought to know better. No more

nukes! Please consider all these factors in making a decision. (DW-0421 3)

Comment: As a citizen living in neighboring Albemarle County, I am strongly opposed to

building additional nuclear reactors in Louisa, or anywhere else in the country. (DW-0426 1)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-62 December 2006

Comment: I promise to fight Dominion Power, the US Nuclear Regulatory Commission, the

Bush Administration and all energy “fat cats” in this country from building any more potentially

dangerous and contaminating reactors in the United States. The people will be heard! 

(DW-0429 3)

Comment: Please do not begin this nuclear problem again, it is too powerful an issue to take

lightly!!!!! (DW-0585 2)

Comment: These proposed new reactors HAVE NEVER BEEN BUILT BEFORE ANYWHERE

IN THE WORLD. I do not like being a Guinea Pig for untested reactor designs. (DW-0614 7)

Comment: Please listen to the public! We do not want any additional nuclear power plants!

(DW-0619 2)

Comment: Charging off into additional nuclear power stations is NOT THE WAY TO GO!

y'HEAR?? (DW-0636 2)

Comment: I register my objection to approving any new nuclear plants, nuclear weapons, or

nuclear industrial applications. (DW-0648 2)

Comment: I am against new power plants, including at North Anna. (DW-0669 1)

Comment: I am against any new nuclear plants. (DW-0743 2)

Comment: I am completely opposed to the construction of any new nuclear facilities.

(DW-0777 1)

Comment: We neither want nor need them [more nuclear reactors]. (DW-0798 2)

Comment: Nuclear energy is NOT the way to go! ...NO NUCLEAR! (DW-0811 1)

Comment: I am writing in strong opposition to any new nuclear reactors at North Anna or any

location. (DW-0861 1)

Comment: What a lovely group of hornswogglers you are! Seems our government's nose is

growing longer than Pinocchio's. Why don't you just tell the TRUTH? There will come a time

when all of your lies are going to catch up with you and I hope that I'm around to escort you to

the prison of my choice. Why damage Virginia any more than you already have? I understand

that Iran is in the market for your services. Have a happy non-nuclear day. (DW-0866 1)

Comment: Please do not revisit nuclear power!! (DW-0867 1)
Comments Outside the Scope of the EIS

December 2006 5-63 NUREG-1811, Volume II

Comment: I have been opposing nuclear power since I was in college. ...I am eager for

progress in this area but I don’t see it. (DW-0976 2)

Comment: My first grandchild will be born in a few weeks. She does not need or want nuclear

energy. (DW-0980 2)

Comment: Please say no to more reactors. (DW-1091 3)

Comment: I am against any more nuclear power plants, not only in Virginia, but within the

continental United States. (DW-1166 3)

Comment: Thank you for your attention to this most serious matter [opposition to nuclear

power], and I look forward to receiving your response. Lest “we” forget, if you don't exercise

responsibility, its Siamese sister, freedom, will wither, as well. Sadly, now, it first needs to be

exorcised before its exercised. (DW-1265 2)

Comment: I'm a school teacher and I've been studying this - what I realized in the last couple

of years is that there is no magic in fissioning the atom. There is horrible death, there is the

potential for complete planetary destruction, and there is heat. (ST-0006 4)

Comment: [S]omething I find missing in this entire argument that we're going through, is a

conscience issue. We do have clean nuclear plants, and this is a plus. But the side issues are

still so sloppy, and I have a hard time living with it, and I think it's worth junking the entire

industry, because of the side issues, the parts that you have not dealt with. (ST-0038 6)

Comment: I vehemently oppose any new reactors. (SE-0010 4)

Cost

Comment: The nuclear operators are going to continue to cut costs in the highly competitive

electricity market by reducing their staff at nuclear facilities as much as they possibly can. 

(DT-0005 3)

Comment: It wasn't the anti-nuclear movement that really beat back, you know, your reactors. 

It was your own inability to manage construction and operating costs of your own reactors.

Forbes Magazine called you the greatest managerial disaster in the history of American

business. I don't suggest we go down that path again. (DT-0033 7)

Comment: It is a tremendous waste of money for a dangerous technology that is not

necessary. (DW-0309 7)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-64 December 2006

Comment: My tax dollars are subsidizing it to the tune of at least one billion and upwards

dollars and yet I am adamantly opposed to it. (DW-0404 4)

Comment: I sincerely hope those who make these decisions will think of the future of our

planet and not just give in to those who will make a profit. (DW-0789 2)

Comment: Nuclear Power should not be used because: Government subsidies of

development, the fuel cycle, promotion, security, and insurance make it impossible to compare

the costs of nuclear, fossil, and renewable power. The same for the unknown cost of

decommissioning and guarding old reactors after they have become too brittle to use. 

(DW-0829 7)

Energy Needs

Comment: Nuclear power does nothing to fix the country's fractured energy system. In fact, it

only reinforces the inefficient system by creating a new generation of massive plants located far

from the customers served in most instances. (DW-0641 1)

Comment: We need to get serious about our long-term energy demands and Nuclear Reactors

are not the answer. (DW-0710 2)

Comment: Nuclear power isn't the answer to our energy problems. (DW-1069 2)

Comment: With so many other forms of energy available to harness, it is criminal to continue

to build nuclear reactors. (DW-1091 1)

Safety

Comment: I want to know when we all bought into the idea that having enough energy to meet

our needs meant that we also had to have terrorist threats or lethal poisoning of radioactivity for

tens of thousands of years. (DT-0018 6)

Comment: Now, we don't know that the next reactor that they're going to build there will even

have that dome. (DT-0033 5)

Comment: We know that nuclear power is not safe for citizens and the environment. 

Otherwise why can you not find a private insurance company to fully insure against the costs of

a major nuclear accident? (DT-0038 2)

Comment: Nuclear power perpetuates us living in fear, fear for our environment, our safety,

our health, and our future. (DT-0044 3)
Comments Outside the Scope of the EIS

December 2006 5-65 NUREG-1811, Volume II

Comment: We do not believe that nuclear power is safe. This might be said about other

means for generating electrical energy, but the world has witnessed the consequences of a

nuclear disaster. It simply is not worth the risk. (DT-0047 9)

Comment: In this current atmosphere of terror alerts and due to the failure to secure currently

operating nuclear power plants, I find the desire to permit the building of a new nuke plant to be

utter insanity. (DW-0306 2)

Comment: The literature is rife with details of premature corrosion of various components of

reactors. (DW-0309 4)

Comment: The risks of nuclear facilities to the health, safety and welfare to the public and

environment far outweigh any benefits. (DW-0406 3)

Comment: We are not ready to safely use nuclear power. ... We live in a finite world, and

simply cannot continue to grow industry ad infinitum. (DW-0577 2)

Comment: How many other times have we been overconfident in the safety of our technology? 

DDT and CFC's come to mind as examples of technologies we thought were risk-free but turned

out to lead to increased health problems. (DW-0426 15)

Comment: There are many unresolved safety...issues. (DW-0188 2)

Comment: Nuclear power is the most unsafe form of electricity generation. (DW-0193 2)

Comment: Questions about the adequacy of current security regulations and performance are

ignored. (DW-0401 4)

Comment: Nuclear energy is unsafe and it does have considerable lifecycle polluting

emissions. (DW-0593 2)

Comment: It [nuclear energy] threatens society with its danger. (DW-0811 2)

Comment: Nuclear reactors present an unacceptable risk for the public. (DW-0186 3)

Comment: Prevent another Chernobyl...do the right thing for America and the future of our

children. (DW-0749 3, DW-0750 3)

Comment: I would hope that there is no attempt to start up the construction of nuclear power

plants in this country. They are among the most dangerous pieces of industrial equipment on

the planet, with environmental consequences lasting for thousands of years. (DW-0807 1)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-66 December 2006

Comment: Having lived through the TMI accident as a child and knowing many people who

now have cancer in our area I urge you to now allow any new nuclear power plants. 

(DW-0819 2)

Comment: I do not believe that nuclear power is good for our communities or our environment,

and I strongly oppose it. If we care about the safety of our communities and the health of our

environment, we should not be expanding nuclear energy. (DW-0822 4)

Comment: My three grandchildren live near Three Mile Island and I constantly worry about that

threat to their lives...If there were some way we could assure people there would be no nuclear

accidents, no threat from radioactivity released into the environment and a safe way for

disposing of nuclear waste, my position would change. (DW-1042 2)

Comment: I really believe that terrorist threats and unsolved issued of radioactive waste make

new nuclear plants folly to consider. (DW-1078 2)

Comment: I oppose construction for the following reasons: Nuclear power has never been

shown to be as safe or as economical as the nuclear industry has promised. (DW-0409 2)

Comment: Nuclear Power should not be used because: The spread of nuclear power

expertise through the world enables hostile nations to convert that expertise to weapons'

development. (DW-0829 6)

Comment: Nuclear Reactors are ... not SAFE (they let out tons of radiation) the spent cores

are a danger and we still have nothing to do with them except drop them on innocent IRAQI

WOMEN AND CHILDREN or use it to irradiate food which is just poison. (DW-0180 3)

Comment: Nuclear Power should not be used because: An accident would be a disaster to

eclipse the Indian Ocean Tsunami. (DW-0829 3)

Comment: There has not been one single nuclear plant that has not had leaks, spills,

accidents or near accidents, incurring tremendous cost in attempts to fix them (not always

successful). (DW-0198 2)

Comment: I am shocked that there is even a consideration of this highly potential disaster. 

Nuclear power has never been safe. (DW-0181 2)

Comment: [T]he consequences should there be a problem are tremendous with operation and

should not be overlooked. (DW-0407 2)
Comments Outside the Scope of the EIS

December 2006 5-67 NUREG-1811, Volume II

Comment: [T]he cost to future generations of one slight mis-step leading to nuclear

catastrophe definitely outweighs any benefits these new reactors would produce. (DW-0408 9)

Comment: The addition of two new nuclear reactors makes no sense at all, and creates an

accident waiting to happen. (DW-0413 5)

Comment: My concerns about increasing Virginia's and America's reliance on nuclear energy

are based on ... the possibility of an accident within the power plant. (DW-0426 4)

Comment: I live within a half-hour's drive of the reactor, and would be immediately affected by

any serious malfunction. (DW-0660 2)

Comment: It [nuclear power] is highly dangerous, not the least to Washington, DC, which is in

its radiation radius, should anything go wrong -- and things can and have gone wrong! 

(DW-0805 5)

Comment: I am concerned about the potential for a major nuclear accident, endangering

citizens in Charlottesville as well as Richmond and Washington, D.C. This is [not?] an

acceptable safety risk! (DW-0827 4)

Comment: Here in the DC suburbs, we are not too far from the site [North Anna] to be

concerned about nuclear accidents. (DW-1019 2)

Comment: As residents of nearby Charlottesville, we already feel vulnerable to the possibility

of a catastrophic accident. (DW-0424 3)

Comment: Three-eighths of an inch of stainless steel that was bulging and fatigued stopped an

accident of major proportion in Ohio. The first accident that happens in the United States during

the period of time that this process is going on will stop the additional reactors at the North Anna

nuclear power plant, just like the accident at Three Mile Island canceled 100 reactors that were

on order at that time. (DT-0005 5)

Comment: The issue of accidents. Are nuclear power plants safe from meltdowns, as in

Chernobyl, or partial meltdowns, as in Three Mile Island? Nothing assures me that meltdowns

of any kind can't happen again. (DT-0009 3)

Comment: I am also opposed for safety reasons. Accidents do still happen around the world. 

(DW-0165 4)

Comment: Remember Three Mile Island, it DID happen in the U.S. (DW-0195 5)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-68 December 2006

Comment: I am a resident of Louisa County who lives 10 miles as the crow flies from the North

Anna plant, and it is clear to me that nuclear reactors present an unacceptable risk for the

public. There have been many documented near-catastrophes in addition to the disaster at

Chernobyl and the near meltdown at Three Mile Island. (DW-0196 2 and DW-0744 2)

Comment: I respectfully submit my heartfelt request that we TURN AWAY from deadly

nuclear, and turn our awesome creativity toward energy sources that do not make the world a

dangerous place. (SE-0037 1)

Comment: When did we all buy into this idea that having enough energy to meet our needs

meant that we also had to become a terrorist threat, that we had to face terrorist threats? These

nuclear reactors are cocked and loaded nuclear bombs, essentially. ...We don't need to have

lethal poisoning for millions of years just to boil water. We don't have to have our children, and

our futures dying of leukemia and cancers just to boil water. This is not an either/or proposition. 

We can do both. We can have our electricity, and have a safe world. ...We have to stop hiding

behind oh, we'll fix it tomorrow. Let's let another generation pay for it, or accidents never

happen. ...there aren't enough green and white balloons in the universe to make it true that

nuclear is safe, and that nuclear is clean. We live in an era of perverse cynicism. (ST-0006 2)

Environmental Aspects

Comment: I may be near the end of my life, but we have to be good stewards for this earth.

We need to be thinking about them. And almost every major environmental group in the world

is opposed to nuclear power. (DT-0047 10)

Comment: There will always be adverse impacts on the environment when a nuclear plant is

built! No more!!! (DW-0097 2)

Comment: As you well know, creating the [reactor] cores requires BURNING COAL, so

Nuclear Reactors are not CLEAN. (DW-0180 2)

Comment: Please, no new nukes, further expansion of current levels, or anything other than a

turn to earth friendly and people friendly energy!! (DW-0783 1)

Political Aspects

Comment: The Greens are a worldwide movement and each Green Party on the planet is

opposed to building new nuclear reactors. We object to the secret meetings during which the

Bush administration formulated the current energy policy, including the renewed push for

nuclear energy which brought us all here tonight. The Green Party denies President Bush's
Comments Outside the Scope of the EIS

December 2006 5-69 NUREG-1811, Volume II

recently stated contention that nuclear power is a safe, clean, and renewable energy source. 

Nuclear power is not clean, nor is it safe, nor is it renewable. (DT-0041 1)

Comment: Because you see opposition here now. It's going to continue. It's going to continue

as the debate intensifies in Central Virginia, as it intensifies in Virginia, and as it intensifies

across our country, because people want to be involved in their energy future. They don't want

a decision coming down from Washington, D.C., that is, you know, coercive, that has been

coerced by the Bush administration and the nuclear energy industry and their lobbyists and

friends in Congress. (DT-0042 2)

Comment: Clearly dirty politics are at work here from the nuclear industry. What in heavens

name were PRO-nuclear representatives from CHICAGO doing in Louisa, Virginia on 2/17/05??

Clearly, the nuclear industry is keen to give the impression of a PRO-nuclear grassroots

movement. Which does not exist. The whole thing reeks of corruption and deceit. 

(DW-0830 3)

Nuclear Waste

Comment: Symbolic light show presentation showing the relationship between nuclear waste

and time. (DT-0012 2)

Comment: The NRC and Dominion are determined to build more nuclear reactors, and that

means more nuclear waste, and that's great. ... Nuclear power is expensive, radioactive, and

totally unreasonable and illogical, just like me. (DT-0023 1)

Comment: Something with the impact that nuclear energy has and the potential that it has to

be de-static (in spite of its positive effect), and the as yet unsolved problem of clean-up really

does ever preclude its use as an energy source. (DT-0051 2)

Comment: No new nuclear power plant should be build ever, and all those that exist should be

shut down. Nuclear energy has been hyped as being clean, green, and cheap, and it is none of

those things. The fact that nuclear waste remains lethal for hundreds of thousands of years,

much longer than any nation has lasted is all the reason any sane person needs to ban any kind

of nuclear use or production. WHO is going to monitor the waste??? None of the ideas of

dealing with it make any sense - shooting it into space, burying it under an earthquake-fault

ridded mountain. (DW-0198 1)

Comment: Given the lack of adequate plans for nuclear waste disposal, I oppose the

construction of any nuclear reactors at this time. (DW-0983 2)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-70 December 2006

Comment: I am opposed to nuclear power anywhere on earth for three reasons. One, the

power plants are safe until they fail, and then they can be catastrophic. Everything fails. 

(DT-0006 1)

Comment: We don’t need more nuclear waste and more nuclear time bombs. (DW-0743 4)

Comment: We have enough trouble disposing of the waste we're already creating without

making the problem worse by building new facilities. (DW-0777 2)

Comment: We have no right to build another one [plant] until we can handle our waste! 

(DW-0780 2)

Comment: I think it is a big mistake to invest in nuclear power when we have no way to

dispose of the waste and it's so dangerous. (DW-0789 1)

Comment: No more nukes/stop the old ones. We all live at Yucca Mountain... (DW-1249 1)

Comment: I am opposed to nuclear power in general primarily because of the hazards

involved in disposal of the irradiated fuel generated by reactor[s]. (DW-0407 1)

Comment: Nuclear Power should not be used because: The fuel cycle produces “small”

amounts of radiation at every stage. (DW-0829 2)

Comment: If it's clean, take responsibility for your own waste. (ST-0024 7)

5.8 Miscellaneous Out Of Scope Comments

The following comments are miscellaneous in nature and did not fit well into any of the subject

categories that were formed as a result of the bulk of comments received. The subjects of all

these comments have been determined to be outside the scope of the EIS. 

Comment: Page 5-42 on taxes mentions utility deregulation. Would the new units be merchant

plants or rate-based? (DW-0438 154)

Response: The staff does not have information with which to respond to this question, which is

outside the scope of this EIS.

Comment: Is Dominion ready to go for a COL for unit 3 right away? (SE-0027 12)
Comments Outside the Scope of the EIS

December 2006 5-71 NUREG-1811, Volume II

Comment: [I]s Dominion ready to go for a COL soon after they get an early site permit,

because I think the public is due an answer on this question, and Dominion should be forthwith

and tell us what their plans are. (ST-0028 10)

Response: In a letter dated November 22, 2005, Dominion stated that it had selected the

ESBWR design for the preparation of a COL application. The letter did not provide an expected

date for the submittal of the application.

Comment: We have experienced through the years major changes in Lake Erie. The major

concern, as you well know, is the dead zone. It is being investigated still after 2 years

observation and still to my knowledge considered a mystery. I wonder if there is any correlation

between the dead zone, which is expanding every year, and what could happen to Lake Anna if

any nuclear waste or power plants are built here in Virginia. (DT-0056 1)

Comment: I ask for a binding individual contract...The contract should address, in comparison

with the baseline body of water previously described, water quality, water temperature, water

level. There should be no restriction as to forming a class action by the parties, there should be

a limit of liability 5% of the wholesale value of station output during defined environmental

infractions. The individual contracts should be offered to all abutters (including private access

abutters) and run with the land as would a deed covenant. The reason for this is simple - it

introduces an economic incentive for Dominion Resources / Virginia Power to live up to its

environmental commitments locally, and directly reimburse abutters for station operational

indiscretions. (SW-0015 5)

Comment: [I]ndemnify the local stakeholders, through the use of reliable technology and

binding individual contractual obligations. ...Now for this next generation of nuclear power

construction require to the extent feasible, fail safe standards of engineering design and

environmental neutrality. (SW-0015 8)

Response: NRC is not responsible for landowner relations with Dominion. Accordingly, no

changes were made to this EIS as a result of these comments.

Comment: The DEIS does not inform the public that private insurance will not provide total

coverage for this kind of facility and that, in fact, taxpayer funds are used to self insure. 

(SE-0049 5)

Comment: The insurance companies don't provide unlimited insurance for anybody for

anything. When you buy a policy, you buy X amount of liability, and that's what you pay for. 

And the nuclear industry is not any different from the coal industry, or the chemical industry, or

the drivers of their cars, except that Congress gets involved in mandating how that insurance is

apportioned. (ST-0025 5)
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-72 December 2006

Comment: My late father was an insurance agent. He told me “If a company can't find

affordable insurance, then the business isn't safe.” Since North Anna and other plants can't

seem to find a free market insurer, that means the free market is telling us all that nuclear power

is too risky. Let's listen to the free market! (DW-0194)

Comment: The only reason the nuclear industry can even afford its insurance is that the Price

Anderson Act limits liability ridiculously below the likely cost of an accident. It would be cost

prohibitive for the industry to be insured against the actual cost of a meltdown. (DT-0036 3)

Comment: If you deem nuclear power is safe, why cannot you find a private insurance

company to insure against an accident? (DW-0187 3)

Comment: Our government is heavily subsidizing the insurance on our nuclear reactors,

because insurance companies will not insure these reactors without government subsidies, and

without these subsidies, in free markets, the reactors would not operate. My question is this: 

what do the insurance companies know about the risk of these reactors that the NRC does not

know, or is not including in its risk assessment? (DW-0685 12)

Comment: Cleanup costs for a major nuclear accident are estimated to be around $500 billion,

not including broader economic shockwaves. The nuclear industry’s liability for such an

accident is capped at around $10 billion, leaving taxpayers with a $490 billion bill, ratepayers

with a bankrupt utility, and surviving residents without a home. (DW-MM4 13)

Comment: A major nuclear accident could leave an area the size of Pennsylvania

uninhabitable for decades. The area around the Chernobyl nuclear plant, site of a major

accident in 1986, is still closed to public access and radiation levels are still high. Cleanup

costs for a major nuclear accident are estimated to be around $500 billion, not including broader

economic shockwaves. The nuclear industry’s liability for such an accident is capped at round

$10 billion, leaving taxpayers with a $490 billion bill, ratepayers will a bankrupt utility, and

surviving residents without a home. (DT-0053 8)

Comment: Louisa County, the officials...[have] gotten $212 million from Dominion, and how

much has Louisa County saved? Anybody know the answer? Zero. ... So it's a windfall, but

they're blowing it. (ST-0024 4)

Comment: Nukes, if they're safe, get your own insurance, very simple. If the nuclear plant is

safe, get private insurance. (ST-0024 6)

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? (SE-0045 25)
Comments Outside the Scope of the EIS

December 2006 5-73 NUREG-1811, Volume II

Comment: [Adding proposed Unit 3 at North Anna] suggests a disturbing vulnerability in

Virginia’s electrical supply. Units 1 and 2 already account for about 15% of the state’s electric

power generation, and adding Unit Three’s 1560 MWe would probably boost the NAPS

contribution to 25% or more of the state’s total. Putting the state’s public safety and economy at

the mercy of a prolonged heat wave, or possible sabotage of the North Anna dam, does not

suggest to us a responsible energy policy for the State. (SE-0040 10)

Comment: Pending approval of the North Carolina Utilities Commission, Dominion will join the

PJM interconnection. PJM is the largest regional transmission organization (RTO) in the

U.S., and currently coordinates the movement of electricity in all or parts of Delaware, Illinois,

Indiana, Kentucky, Maryland, Michigan, New Jersey, Ohio, Pennsylvania, Tennessee,

Virginia, West Virginia, and the District of Columbia. The Final EIS should include an analysis

of what the PJM will mean for Virginia ratepayers, including the fact that Dominion is likely to

export the electricity generated by the new reactors at North Anna to other states such as New

Jersey where electricity prices are twice as high as Virginia and revenues will be greater. 

(DW-0437 69)

5.9 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 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, “Early Site Permits,

Standard Design Certifications, and Combined Licenses for Nuclear Power Plants.”

68 FR 40025. “Early Site Permits, Standard Design Certifications, and Combined Licenses for

Nuclear Power Plants; Proposed Rule.” Federal Register. Vol. 68, No. 128. July 23, 2003.

Atomic Energy Act. 42 USC 2011, et seq.

Dominion Nuclear North Anna, LLC (Dominion). 2005. Letter from E. Grecheck (Dominion) to

NRC, Dominion Submittal of ESP Application Schedule, November 22, 2005.

Energy Reorganization Act. 42 USC 5851, et seq.
Comments Outside the Scope of the EIS

NUREG-1811, Volume II 5-74 December 2006

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

Price Anderson Act. 42 USC 2210.

U.S. Nuclear Regulatory Commission (NRC). 2005. Safety Evaluation Report for an Early Site

Permit (ESP) at the North Anna ESP Site. NUREG-1835. Accession No. ML052710305. 

Available at http://www.nrc.gov/reactors/new-licensing/esp/north-anna.html.

U.S. Nuclear Regulatory Commission (NRC). 2006. Supplement to the Final Safety Evaluation

Report for an Early Site Permit (ESP) at the North Anna ESP Site. September 2006. 

Accession No. ML06317371.
December 2006 NUREG-1811, Volume II 6-1

6.0 Commenter Reference Tables

The comments received regarding the North Anna Early Site Permit (ESP) Draft Environmental

Impact Statement (EIS) are documented in the U.S. Nuclear Regulatory Commission (NRC)

Agencywide Documents Access and Management System (ADAMS) under accession number

ML0514720560. They are also available individually and under one of the following four

ADAMS files (beginning with the page shown in Table 6-2):

Pages (1 - 495) ML051390174

Pages (496 - 984) ML051390179

Pages (985 - 1531) ML051390185

Pages (1532 - 2504) ML051390190

The comments received regarding the Supplemental Draft Environmental Impact Statement

(SDEIS) are documented in ADAMS under accession number ML063060459. They are also

available in individual ADAMS files (listed in Tables 6-4 and 6-5).

Comments received through the public comment period were organized into categories by topic

in Chapter 3 (Comments Within Scope), Chapter 4 (ESP Process, NEPA Compliance, and

Comments Supporting or Opposing the ESP), and Chapter 5 (Comments Outside the Scope of

the EIS). Some of the comments could conceivably fit in more than one category but are

provided only once. Comments that covered several topics but that did not fit simply into the

categories of “in support of” or “in opposition to” nuclear power or the ESP were usually

subdivided by topic. 

Regarding the numbering of the comments, comment numbers were initially assigned in

sequential order to portions of verbal or written statements. In some cases, decisions were

made that the preliminary assignments did not meet the criteria as comments; in other cases,

two sequential comments were combined into one comment or one comment was subdivided to

address different aspects. As a result, although most comment number assignments follow the

verbal or written comment sequentially, a few are not and should not be construed as missing.

Draft EIS Comments

Three tables were developed to facilitate cross referencing comments received on the Draft EIS

with the commenters. Table 6-1 provides a listing of commenters in alphabetical order, along

with the assigned identifiers for the following:

• DT for verbal transcript comments received during the February 17, 2005, Public Meeting

on the Draft EIS (includes written comments provided at the meeting)

• DW for written comments (DW). 
NUREG-1811, Volume II December 2006 6-2

Those commenters who provided more than one set of comments are listed multiple times,

once for each set of comments. In instances where the commenter represented an agency or

an organization, both the commenters and the agency are listed. Table 6-1 also lists the

accession number associated with the specific set of comments and the page number on which

the comments begin. Two petitions were received, one supportive of and one opposed to the

ESP. These documents are referenced as DT-0052 and DT-0053 by the title of the

organizations identified on the petition, and are listed at the end of Table 6-1.

In Table 6-2, the list is sorted sequentially by transcript and written commenter number,

providing the assigned identification number and the commenter or organization where

appropriate. This table also lists the accession number for the document containing the specific

set of comments and the page number on which the comments begin. Table 6-3 identifies the

commenters who sent the NRC mass mailing form letters or who extracted essentially verbatim

portions from the form letters. The comments associated with the form letters are identified as

being from mass mailing (DMM) letters 1 (DMM-1) through 4 (DMM-4), and these designations

rather that the individual signers are used to identify each of the mass mailing comments. 

The DMM-1 comments are further divided in the list (but not in Appendix E) based on the

subject line used for the same letter text. Comments using the subject line “Please find an

alternative to the North Anna nuclear project” were assigned DMM-1A; those using subject line

“Reconsider the Lake Anna Early Site Permit” were assigned DMM-1B; and those using the

subject line “No nuclear power plant in North Anna” were assigned DMM-1C.

SDEIS Comments

Three tables were developed to facilitate cross referencing comments received on the SDEIS

with the associated commenters. Table 6-4 provides a listing of commenters in alphabetical

order along with the assigned identifiers for the following:

• ST for verbal transcript comments (received at the August 15, 2006, Public Meeting)

• SW for written comments including those received at the Public Meeting

• SE for e-mailed comments received by the NRC.

Those who provided more than one set of comments are listed multiple times, once for each set

of comments. In instances where the commenter or commenters represented an agency or an

organization, both the commenter and the agency are listed. Table 6-4 also lists the accession

numbers of the public meeting transcript and the individual comment letters and e-mail

messages. One petition in support of the ESP was received and is referenced as SW-0009 by

the title of the organization identified on the petition.

In Table 6-5, the list is sorted in numerical order by transcript, written, and e-mailed comments

followed by the commenter (and organization where appropriate), the accession number, and

the comment date.
December 2006 NUREG-1811, Volume II 6-3

Table 6-1. Draft EIS Index Arranged Alphabetically, Sorted by Commenter Name

Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

Jim and Kim Ackerman DW- 0690 ML051390185 1087

Jean and Bill Ackor DW- 1037 ML051390190 1747

Michelle Acton DW- 0474 ML051390179 665

Antje Adams DW- 0303 ML051390174 310

Jim Adams DW- 0823 ML051390185 1241

Jim Adams DT- 0050 ML051390190 2356

Lynn Adams DW- 0542 ML051390179 765

Roger Adams DW- 0921 ML051390185 1433

Roger Adams DW- 0910 ML051390185 1416

Shannon Adams DW- 1209 ML051390190 2078

Nancy Adamson DW- 0537 ML051390179 758

Lauren J. Agreela DW- 0397 ML051390174 405

Felix Aguilar DW- 0234 ML051390174 241

Felix Aguilar DW- 0102 ML051390174 102

Linda Alberda DW- 0754 ML051390185 1153

Martin Albert DW- 0511 ML051390179 720

Evan Albright DW- 0201 ML051390174 208

Michael Aleman DW- 0767 ML051390185 1166

Karla Alfano DW- 0521 ML051390179 732

John Alge DW- 1258 ML051390190 2131

Nicole Allard DW- 0393 ML051390174 401

Michael Allen DW- 0705 ML051390185 1102

Monica Allen DW- 0128 ML051390174 128

Monica Allen DW- 0280 ML051390174 287

Matthew Allenbaugh DW- 1192 ML051390190 2061

Seamus Allman DT- 0036 ML051390190 2320

Charles Alvarez DW- 0235 ML051390174 242

Charles Alvarez DW- 0048 ML051390174 48

Disamodha Amarasinghe DW- 0518 ML051390179 727

Dean Amel DW- 1054 ML051390190 1786

Eleanor Amidon DW- 0414 ML051390174 445

Revathi Ananthakrishnan DW- 0717 ML051390185 1114

Corina Anderson DW- 0205 ML051390174 212

Corina Anderson DW- 0046 ML051390174 46

Ellen Anderson DW- 0650 ML051390185 985

Ron Anderson DW- 0943 ML051390185 1486

Stephen Anderson DW- 0481 ML051390179 674

Joseph Anthony DW- 0470 ML051390179 659

Joseph Anthony DW- 0618 ML051390179 902

Carlton Apperson DW- 0624 ML051390179 914

Michael Appia DW- 0696 ML051390185 1093

Joe Apple DW- 0963 ML051390190 1542

Lee Archard DW- 0619 ML051390179 905
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-4

Barbara Arcure DW- 0285 ML051390174 292

William Arguto, U.S. Environmental Protection Agency DW- 0422 ML051390174 472

William Arguto, U.S. Environmental Protection Agency DW- 1272 ML051390190 2145

Nancy Asman DW- 0651 ML051390185 988

Neil Asselin DW- 0202 ML051390174 209

Neil Asselin DW- 0064 ML051390174 64

Anjali Athavale DW- 0603 ML051390179 872

Mark Atkinson DW- 0955 ML051390185 1520

Mha Atma S. Khalsa DW- 0738 ML051390185 1136

Rachel Atwood DW- 0052 ML051390174 52

Peggy Augustus DW- 0798 ML051390185 1197

Christopher Austin DW- 1032 ML051390190 1736

Douglas Austin DW- 1043 ML051390190 1759

Carl Avers DW- 0471 ML051390179 660

Burt Avery DW- 0967 ML051390190 1554

Diana Bach DW- 0802 ML051390185 1201

Dwight Baker DW- 0645 ML051390179 957

Alex Balboa DW- 0252 ML051390174 259

Alex Balboa DW- 0005 ML051390174 5

Jean Balckwood DW- 1140 ML051390190 1987

Rhea Baldino DW- 0461 ML051390179 638

Keith Baldwin DW- 0627 ML051390179 919

Richard H. Ball DW- 0589 ML051390179 845

Richard Ball DT- 0021 ML051390190 2273

Wanda S. Ballentine DW- 0198 ML051390174 204

Wanda S. Ballentine DW- 0061 ML051390174 61

Ashok Bankley DW- 0812 ML051390185 1218

Elizabeth Barger DW- 0556 ML051390179 783

David Barish DW- 0729 ML051390185 1126

Robert Barnes DW- 1057 ML051390190 1795

Sherry Barnes DW- 0131 ML051390174 131

Brenda Barnhart DW- 0278 ML051390174 285

James Barrett DW- 1201 ML051390190 2070

Andy Barton DW- 0865 ML051390185 1327

Lenore Bassett DW- 0811 ML051390185 1217

Sally Bastian DW- 0799 ML051390185 1198

Barbara Beck DW- 0990 ML051390190 1620

Battlefields Sierra Group, Larry Gross DW- 0444 ML051390179 611

Battlefields Sierra Group, Larry Gross DW- 0594 ML051390179 855

Mary Bejer DW- 0123 ML051390174 123

Carrie Bell DW- 0522 ML051390179 733

Ray Bell DW- 0321 ML051390174 328

Jill Bender DW- 1257 ML051390190 2130

Margaret Benfield DW- 1198 ML051390190 2067

Jaime Bennett DW- 0986 ML051390190 1608
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-5

Michael Bennett DW- 0031 ML051390174 31

Michael Bennett DW- 0208 ML051390174 215

Lesey Bensinger DW- 0037 ML051390174 37

Gloria Berg DW- 1002 ML051390190 1653

Laurie Beringer DW- 1156 ML051390190 2011

Sally Berk DW- 1180 ML051390190 2049

Rachel Bernatz DW- 0718 ML051390185 1115

Michael Bernier DW- 0852 ML051390185 1304

Glen Besa DW- 0847 ML051390185 1293

Gree Bessette DW- 0312 ML051390174 319

Sharon Best DW- 1105 ML051390190 1923

Julie Betterley DW- 1211 ML051390190 2080

Nate Beuttenmueller DW- 038 ML051390174 38

Ken Bezilla DW- 0409 ML051390174 429

Rachana Bhatia DW- 0380 ML051390174 388

Gretchen Biernot DW- 0643 ML051390179 953

Dianne Bigler DW- 1233 ML051390190 2105

Heidi Bilardo DW- 0989 ML051390190 1617

Sama Bilbao y Leon DW- 0417 ML051390174 458

Mark Bir DW- 1204 ML051390190 2073

Angela Black DW- 1231 ML051390190 2102

Krista Blackwood DW- 1145 ML051390190 1992

Joe Blaszcak DW- 1178 ML051390190 2047

Anne Bloomburg DW- 0453 ML051390179 624

Scott Blossom DW- 0580 ML051390179 824

Blue Ridge Environmental Defense League, Louis Zeller DT- 0034 ML051390190 2316

Blue Ridge Environmental Defense League, Louis Zeller DW- 1163 ML051390190 2025

Audrey Blumeenau DW- 0096 ML051390174 96

Audrey Blumeenau DW- 0227 ML051390174 234

Susanna Blunt DW- 0317 ML051390174 324

Kevin Blythe DW- 0531 ML051390179 748

Rachel Bobbitt DW- 0462 ML051390179 639

Carol Bock DW- 0956 ML051390185 1521

Dan Bodnaruk DW- 0560 ML051390179 789

Joel Boggan DW- 1251 ML051390190 2124

Connie Boitano DW- 0766 ML051390185 1165

David Bokel DW- 0540 ML051390179 761

Jay Bolan DT- 0024 ML051390190 2283

Mary Lou Bolas DW- 1022 ML051390190 1710

Jay R. Bolon DW- 0190 ML051390174 191

Gina Boltz DW- 0314 ML051390174 321

Julie Bond DW- 0804 ML051390185 1203

Julie Bond DW- 0725 ML051390185 1122

Victoria Bonsignore DW- 0369 ML051390174 377

David Boone DW- 0699 ML051390185 1096
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-6

Jean Bordwin DT- 0055 ML051390190 2460

Eric Borgersen DW- 0616 ML051390179 899

Elizabeth Borkowski DW- 0983 ML051390190 1600

Deborah L. Bors DW- 0193 ML051390174 196

Julie Boswell DW- 0761 ML051390185 1160

Linda Boswell DW- 0781 ML051390185 1180

Tom Boughan DW- 0746 ML051390185 1145

Bill Bourdin DT- 0011 ML051390190 2240

Lauren Bouyea DW- 0170 ML051390174 171

Lucy Bovasso DW- 1186 ML051390190 2055

Jacqueline Bowman DW- 0492 ML051390179 689

Jamie Bown DW- 0080 ML051390174 80

Michele Boyd and Joseph P. Malherek, Public Citizen DW- 0686 ML051390185 1069

Michele Boyd, Public Citizen DW- 0437 ML051390179 523

Michelle Boyd DT- 0019 ML051390190 2269

Brianne Boylan DT- 0035 ML051390190 2319

Brianne Boylan DW- 0165 ML051390174 165

Katie Boyle DW- 0813 ML051390185 1219

Carl Brackett DW- 0379 ML051390174 387

Sean Brady DW- 0703 ML051390185 1100

Linda Braham DW- 1085 ML051390190 1879

Katie Brazier DW- 0906 ML051390185 1412

Margaret Breslau DW- 0612 ML051390179 887

Jim Brian DT- 0010 ML051390190 2234

Dennis A. Bried DW- 0791 ML051390185 1190

Cary Brief DW- 0180 ML051390174 181

Lindsay Broockman DW- 1244 ML051390190 2117

Dan Brook DW- 0274 ML051390174 281

Jimmy Brooks DW- 1254 ML051390190 2127

Kim Brooks DW- 0224 ML051390174 231

Steve Brooks DW- 0997 ML051390190 1640

Benjamin T. Brown DW- 0829 ML051390185 1251

David E. Brown DW- 1151 ML051390190 2002

Virginia Brown DW- 1241 ML051390190 2114

Amoret Bruguiere DW- 0848 ML051390185 1296

Ann Brummer DW- 1137 ML051390190 1982

Julie Bruning DW- 1229 ML051390190 2100

James A. Bryan DW- 0685 ML051390185 1060

Keith Bryan DW- 1049 ML051390190 1775

Kelly Bryan DW- 0960 ML051390190 1533

Jennifer Bryant DW- 0588 ML051390179 842

Peter Buck DW- 0929 ML051390185 1452

Peter Buck DW- 0009 ML051390174 9

Brian Buckley DT- 0026 ML051390190 2290

Thuy-Vy Bui DW- 0536 ML051390179 757
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-7

Kyle Bunting DW- 1060 ML051390190 1804

Debbie Burack DW- 0209 ML051390174 216

Debbie Burack DW- 0078 ML051390174 78

Scott Burger DW- 0977 ML051390190 1584

Kim Burgess DW- 0204 ML051390174 211

Kim Burgess DW- 0021 ML051390174 21

Kerry Burkhardt DW- 0054 ML051390174 54

Kerry Burkhardt DW- 0203 ML051390174 210

David Burkhart DW- 0289 ML051390174 296

Mecca Burns DT- 0062 ML051390190 2475

Mary Burress DW- 1196 ML051390190 2065

Lori Burris DW- 1136 ML051390190 1981

Caryl Burtner DW- 0835 ML051390185 1257

Mark J. Burwinkel DW- 0946 ML051390185 1495

Carolyn Bushey DW- 1045 ML051390190 1763

Lisa Butch DW- 0345 ML051390174 352

Brian Butcher DW- 0163 ML051390174 163

Brian Butcher DW- 0392 ML051390174 400

Brian Butcher DW- 0764 ML051390185 1163

Kirk Butler DW- 0573 ML051390179 813

Morgan Butler, and Richard A. Parrish, Southern

Environmental Law Center

DW- 1122 ML051390190 1958

Roy Butler DT- 0060 ML051390190 2468

Sarah Byrne DW- 0647 ML051390179 962

Lori C DW- 0974 ML051390190 1575

Lori C DW- 0478 ML050770019 671

Joseph Calhoun DW- 0697 ML051390185 1094

Whitney Cali DW- 1101 ML051390190 1913

Stephen Calkins DW- 0339 ML051390174 346

Susie Callahan DW- 0841 ML051390185 1275

Paxus Calta DT- 0005 ML051390190 2220

Paxus Calta DW- 0114 ML051390174 114

Brigit Campana DW- 1026 ML051390190 1720

David Campbell DW- 0895 ML051390185 1393

David Campbell DW- 0475 ML051390179 666

Kenneth Campbell DW- 0529 ML051390179 742

Kenneth Campbell DW- 0527 ML051390179 738

Matthew Campbell DW- 0505 ML051390179 708

Nancy Campbell DW- 0398 ML051390174 406

Victoria Campbell DW- 0115 ML051390174 115

Victoria Campbell DW- 0216 ML051390174 223

Robert Cannon DW- 0584 ML051390179 834

Alan Carlson DW- 0885 ML051390185 1369

Judith Carlson DW- 0083 ML051390174 83

Nancy Carpenter DW- 0575 ML051390179 815
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-8

Cindy Carper DW- 0911 ML051390185 1417

Cindy Carper DW- 0903 ML051390185 1405

Nell Carr-Young DW- 0920 ML051390185 1430

Jimmy Carrell DW- 1041 ML051390190 1755

Sandra Carrubba DW- 0151 ML051390174 151

Sandra Carrubba DW- 0384 ML051390174 392

Lynne Carruth DW- 0882 ML051390185 1360

Ellie Carter DW- 1112 ML051390190 1944

L. Carter DW- 0156 ML051390174 156

Yvonne E. Carter DW- 1206 ML051390190 2075

Bill Casino DT- 0039 ML051390190 2327

Donna Cassano DW- 0333 ML051390174 340

Anje Cassel DW- 1075 ML051390190 1849

Virginia Cassidy DW- 0099 ML051390174 99

Virginia Cassidy DW- 0354 ML051390174 361

Alice Catlin DW- 1015 ML051390190 1689

Michael Cavanaugh DW- 1256 ML051390190 2129

Joe Cecil DW- 0517 ML051390179 726

Laura Celestine DW- 1023 ML051390190 1713

Kevin Chaney DW- 0450 ML051390179 619

Susan Chappell DW- 1039 ML051390190 1749

Sue Chase DT- 0009 ML051390190 2230

Bryan Chauveau DW- 1239 ML051390190 2112

Todd Chenore DW- 0803 ML051390185 1202

Eileen and Victor Chieco DW- 0926 ML051390185 1447

Erin Christiansen DW- 0751 ML051390185 1150

Pat Churchman DW- 0958 ML051390185 1527

Richard Churray DW- 1014 ML051390190 1686

Andrea Cimino DW- 0387 ML051390174 395

Andrea Cimino DW- 0094 ML051390174 94

Beth Clark DW- 0673 ML051390185 1028

Diane Clark DW- 0562 ML051390179 793

Loralee Clark DW- 0452 ML051390179 621

Scott Clark DW- 0838 ML051390185 1266

Dick Clark DT- 0029 ML051390190 2302

Kirk Clayton DW- 0755 ML051390185 1154

Kirk Clayton DW- 0153 ML051390174 153

Audrey Clement DW- 0463 ML051390179 642

Della Cleve DW- 0794 ML051390185 1193

Della Cleve DW- 0672 ML051390185 1025

Marione M. Cobb DW- 0196 ML051390174 202

Marione M. Cobb DW- 0744 ML051390185 1143

Merrill Cole DW- 0033 ML051390174 33

Merrill Cole DW- 0266 ML051390174 273

Darlene Coleman DW- 0498 ML051390179 697
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-9

Fletcher Collins DW- 0490 ML051390179 685

Janet Collins DW- 0524 ML051390179 735

John Coltrinari DW- 1217 ML051390190 2088

Commonwealth of Virginia, Office of Environmental

Impact Review, Ellie L. Irons

DW- 0439 ML051390179 555

Jennifer Conner DT- 0023 ML051390190 2282

James Conroy DW- 0572 ML051390179 812

Peggy Conroy DW- 0262 ML051390174 269

Dana Cook DW- 0844 ML051390185 1284

David Cook, Jr. DW- 0218 ML051390174 225

Sherri Cook DW- 0876 ML051390185 1346

Christina Copeland DW- 0533 ML051390179 752

Caryn Corriere DW- 0771 ML051390185 1170

Caryn Corriere DW- 0154 ML051390174 154

Caryn Corriere DW- 0174 ML051390174 175

Domelza Costa DW- 0318 ML051390174 325

Patrick Costello DW- 0377 ML051390174 385

Tracy Ann Costello DW- 1092 ML051390190 1893

Cheryl Costigan DW- 0385 ML051390174 393

Cheryl Costigan DW- 0179 ML051390174 180

Bert Courson DW- 1171 ML051390190 2037

Matthew R. Courter DW- 1135 ML051390190 1980

John Covey DW- 0752 ML051390185 1151

Joel Cox DW- 0566 ML051390179 800

Katrina Cox DW- 0659 ML051390185 1000

Beth Craig DW- 0639 ML051390179 944

Mike Craig DW- 0883 ML051390185 1363

Susie Crate DW- 1003 ML051390190 1656

Keith Croghan DW- 0504 ML051390179 705

Amber Crooks DW- 0245 ML051390174 252

Mark and Sandra Crossler DW- 1189 ML051390190 2058

Allison Crowell DW- 0821 ML051390185 1239

John Cruickshank DT- 0047 ML051390190 2349

Jon Cruickshank DW- 0886 ML051390185 1370

Steven Culp DW- 1147 ML051390190 1994

Ryan Cunningham DW- 0878 ML051390185 1352

Carol Curran DW- 0784 ML051390185 1183

Julie Curry DT- 0051 ML051390190 2485

Priya Curtis DW- 0415 ML051390174 446

Jana Cutler DT- 0041 ML051390190 2334

Jana Cutlip DW- 0171 ML051390174 172

Sue D’Onofrio DW- 0998 ML051390190 1643

Rachael Daigle DW- 1183 ML051390190 2052

John Daily DW- 1237 ML051390190 2110

Gerald Dalton DW- 0298 ML051390174 305
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-10

Jerry Dalton DW- 0084 ML051390174 84

Kathy Dammarell DW- 0683 ML051390185 1056

Lyn Darnall DW- 1093 ML051390190 1896

Beth Davies DW- 0810 ML051390185 1216

Laura Davimes DW- 1011 ML051390190 1679

Andrew Davis DW- 1224 ML051390190 2095

Jennifer Davis DW- 0582 ML051390179 830

John Davis DW- 0912 ML051390185 1418

Ryan Davis DW- 0008 ML051390174 8

Ryan Davis DW- 0290 ML051390174 297

Susan Davis DW- 0477 ML051390179 670

Thomas Alex Davis DW- 0408 ML051390174 428

Teresa Dawson DW- 0605 ML051390179 876

Donald Day DT- 0002 ML051390190 2337

Elena Day DW- 0164 ML051390174 164

Elena Day DT- 0042 ML051390190 2339

Kathy Day DW- 0611 ML051390179 886

Carol DeAntoni DW- 0135 ML051390174 135

Brian Deasy DW- 0640 ML051390179 947

Jerome Decker DW- 1120 ML051390190 1956

D. D. Delaney DW- 0877 ML051390185 1349

Stephen Dell’Aria DW- 0655 ML051390185 992

Diane Dennette-Shaw DW- 1059 ML051390190 1801

Tom Dennison DW- 0464 ML051390179 645

Chad Derosier DW- 0282 ML051390174 289

Martha Desrosiers DW- 0495 ML051390179 692

M. L. Devore DW- 1078 ML051390190 1858

Ed Dewitt DW- 0028 ML051390174 28

Richard Diamond DT- 0013 ML051390190 2245

Marcia Dickinson DW- 0681 ML051390185 1050

Charlote Diedrich DW- 0948 ML051390185 1501

Pat Dietch DW- 0514 ML051390179 723

Sama Dilbaoy Leon DT- 0025 ML051390190 2286

Robin Dina DW- 1252 ML051390190 2125

Lorna Doering DW- 0693 ML051390185 1090

Gregory Doggett DW- 0896 ML051390185 1396

Gregory Doggett DW- 0544 ML051390179 767

Karin Doggett DW- 0526 ML051390179 737

Dominion Nuclear North Anna, LLC, Eugene Grecheck DW- 0423 ML051390174 476

Dominion Nuclear North Anna, LLC, Eugene Grechek DT- 0004 ML051390190 2215

Anne Donley DW- 0994 ML051390190 1631

Jennifer Doob DW- 0727 ML051390185 1124

Jennifer Doob DW- 0134 ML051390174 134

Carolyn Doswell DW- 0178 ML051390174 179

Cathy Douthit DW- 0407 ML051390174 427
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-11

Fred Dove DW- 0866 ML051390185 1330

Ray Dribble DT- 0003 ML051390190 2207

Claudia Duffy DW- 0776 ML051390185 1175

Matt Duffy DW- 0969 ML051390190 1560

Katy Duke DW- 1218 ML051390190 2089

John Dukovich DW- 0868 ML051390185 1332

Mary Dunbar DW- 0950 ML051390185 1505

David Dunkleberger DW- 1267 ML051390190 2140

Stephen Dunne DW- 0010 ML051390174 10

Renee Duprey DW- 0217 ML051390174 224

Andrew Dzikiewicz DW- 0879 ML051390185 1355

Gordon Early DW- 1143 ML051390190 1990

Buddy East DW- 1071 ML051390190 1837

Khaalen East DW- 0069 ML051390174 69

Khaalen East DW- 0355 ML051390174 362

Laura East DW- 0667 ML051390185 1014

Lorah East DW- 0563 ML051390179 796

Constantina Economou DW- 0534 ML051390179 755

Joseph Edwards DW- 0931 ML051390185 1456

Ron Edwards DW- 1006 ML051390190 1665

Robert Egbert DW- 1097 ML051390190 1905

Liz Ehrich DW- 0601 ML051390179 866

Patricia Eichenberger DW- 1102 ML051390190 1916

Patricia Eichenberger DW- 0449 ML051390179 618

Sandy Eichert DW- 0073 ML051390174 73

Sandy Eichert DW- 0207 ML051390174 214

Jim Eldon DW- 0930 ML051390185 1455

Mark Elliott DW- 0628 ML051390179 920

Elena Ellis DW- 0192 ML051390174 195

Thomas Ellis DW- 0991 ML051390190 1623

Mimi Elrod DW- 0959 ML051390185 1530

Eliza Beth Engle DW- 0897 ML051390185 1399

Garrett English DW- 0884 ML051390185 1366

Joseph O. Erb DW- 1167 ML051390190 2033

Robyn Erickson DW- 0609 ML051390179 884

M. Esseltine DW- 0353 ML051390174 360

Gregory Esteve DW- 0351 ML051390174 358

Gregory Esteve DW- 0105 ML051390174 105

Dinda Evana DW- 0836 ML051390185 1260

Alma Evans DW- 0347 ML051390174 354

Dinda Evans DW- 0279 ML051390174 286

Jeanne and John Evans DW- 1273 ML051390190 2148

Michael Evans DW- 070 ML051390174 70

Michael Evans DW- 0241 ML051390174 248

Devin Evert DW- 0704 ML051390185 1101
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-12

Laura Ewen DW- 1031 ML051390190 1733

James Facette DW- 0326 ML051390174 333

Deborah Fahrner DW- 0191 ML051390174 192

David Fairman DW- 0320 ML051390174 327

Marcia Fairman DW- 1177 ML051390190 2046

Marcia Fairman DW- 0675 ML051390185 1032

Linda Falkerson DW- 0981 ML051390190 1594

Leo Fanning DW- 0442 ML051390179 606

Rebecca Faris DT- 0018 ML051390190 2257

C. R. Farley DW- 0648 ML051390179 963

Rebecca Farris DW- 0861 ML051390185 1318

J. R. Feagin DW- 0445 ML051390179 614

Ross Feitlinger DW- 0502 ML051390179 703

Brett Feldman DW- 0107 ML051390174 107

Brett Feldman DW- 0291 ML051390174 298

Dale Richard Felker DW- 0004 ML051390174 4

Dale Richard Felker DW- 0382 ML051390174 390

Leslie Fellows DW- 1082 ML051390190 1870

Robert Fener DW- 0309 ML051390174 316

Joyce and Terry Fernandez DW- 1259 ML051390190 2132

Elizabeth Field DW- 0019 ML051390174 19

Zack Fields DW- 0777 ML051390185 1176

Dough Finkelnburg DW- 0087 ML051390174 87

Albert Fioretti DW- 0888 ML051390185 1376

Michael Fish DW- 0158 ML051390174 158

Joanne Fisher DT- 0056 ML051390190 2461

Mary Fisher DW- 1212 ML051390190 2081

Anna Fitzgerald DW- 0434 ML051390179 509

Kurt Flage DT- 0049 ML051390190 2353

Catherine Fleischman DW- 0973 ML051390190 1572

Paul Fleisher DW- 0800 ML051390185 1199

Bruce Flinchum DW- 1245 ML051390190 2118

RaVani Flood DW- 0367 ML051390174 375

Bobbie Dee Flowers DW- 0129 ML051390174 129

Bobbie Dee Flowers DW- 0343 ML051390174 350

Todd Flowers DW- 0185 ML051390174 186

Todd Flowers DT- 0046 ML051390190 2347

Erin Foley DW- 1174 ML051390190 2040

Scheherazade Folley-Regusters DW- 0674 ML051390185 1029

Ned Fongemie DW- 0350 ML051390174 357

Sam Forrest DT- 0006 ML051390190 2223

Janice Foss DW- 0082 ML051390174 82

Janice Foss DW- 0304 ML051390174 311

Ariele Foster DW- 0512 ML051390179 721

Janet Fotos DW- 0311 ML051390174 318
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-13

Sue Frankel-Streit DT- 0037 ML051390190 2323

Sue Franket-Streit DW- 0168 ML051390174 169

Dorothea Fransson DW- 0051 ML051390174 51

Dorothea Fransson DW- 0337 ML051390174 344

Chad Freckmann DW- 1181 ML051390190 2050

Misha Fredericks DW- 0547 ML051390179 770

Matthew Freeman DW- 0617 ML051390179 900

Sarah Craig Freeman DW- 0630 ML051390179 922

Ariela Friedman DW- 0362 ML051390174 370

Paul Friedman DW- 0976 ML051390190 1581

Jeffri Frontz DW- 0770 ML051390185 1169

Jeffri Frontz DW- 0111 ML051390174 111

Roberta Froome DW- 0712 ML051390185 1109

Liz Fuerst DW- 0213 ML051390174 220

Lisa Fues DW- 0561 ML051390179 790

K. Kenneth Fujishiro DW- 0760 ML051390185 1159

Sydney Funsinn DW- 0758 ML051390185 1157

Brian Gallagher DW- 0663 ML051390185 1006

Yvonne Garcia DW- 0532 ML051390179 751

Barbara Gardner DW- 0980 ML051390190 1591

Mike Garnet DW- 0372 ML051390174 380

Brandi Gartland DW- 0293 ML051390174 300

Nancy Gathing, DW- 1132 ML051390190 1977

Nancy Gathing DW- 0233 ML051390174 240

Richard L. Geddes DW- 0441 ML051390179 602

Richard L. Geddes DW- 0443 ML051390179 607

Richard L. Geddes DW- 1214 ML051390190 2083

Richard L. Geddes DW- 0399 ML051390174 407

Nicole Germans DW- 1000 ML051390190 1647

Elizabeth Gilchrist DW- 0787 ML051390185 1186

Margaret Gilges DW- 0467 ML051390179 652

Sarah Gillespie DW- 0557 ML051390179 784

Sarah Gillespie DW- 0625 ML051390179 915

Kerry Girardin DW- 1222 ML051390190 2093

Deke Gliem DW- 1139 ML051390190 1986

Alan Gold DW- 1019 ML051390190 1701

Rebecca Golden DW- 0152 ML051390174 152

Rebecca Golden DW- 0095 ML051390174 95

Aviv Goldsmith DW- 0438 ML051390179 537

Aviv Goldsmith DW- 0649 ML051390179 965

Beth Goldstone DW- 0055 ML051390174 55

John Golembieski DW- 0257 ML051390174 264

Robyn Good DW- 0678 ML051390185 1041

Michael Goodman DW- 0850 ML051390185 1302

Jesse Gore DW- 0249 ML051390174 256
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NUREG-1811, Volume II December 2006 6-14

Mary Jane Gore DW- 0420 ML051390174 469

Mary Gorka DW- 0570 ML051390179 808

Kay Goss DW- 1228 ML051390190 2099

Simone Gourguechon DW- 0150 ML051390174 150

Eric Gracyalny DW- 1148 ML051390190 1995

Ariel Graham DW- 0120 ML051390174 120

Ariel Graham DW- 0394 ML051390174 402

Kimberley Graham DW- 0138 ML051390174 138

Kathleen Grant DW- 0740 ML051390185 1138

Mariah Grant DW- 0859 ML051390185 1314

Terry Grant DW- 1121 ML051390190 1957

Joanna Gras DW- 1250 ML051390190 2123

Maurene Gray DW- 1115 ML051390190 1949

Eugene Grecheck, Dominion Nuclear North Anna, LLC DW- 0423 ML051390174 476

Eugene Grechek DT- 0004 ML051390190 2215

Jason J. Green DW- 0913 ML051390185 1419

Jason J. Green DW- 0226 ML051390174 233

Paul Greggs DW- 1110 ML051390190 1938

Probyn Gregory DW- 0574 ML051390179 814

Larry Gross, Battlefields Sierra Group DW- 0594 ML051390179 855

Lawrence Gross, Battlefields Sierra Group DW- 0444 ML051390179 611

Jeffrey Grossman DW- 0782 ML051390185 1181

Ravi Grover, P. O. Box 802103, Chicago, IL DW- 0851 ML051390185 1303

Ricky Grubb DW- 0545 ML051390179 768

Fred Gruber DT- 0048 ML051390190 2352

Paul Gunter, Nuclear Information Resource Service DW- 1154 ML051390190 2005

Paul Gunter, Nuclear Information Resource Service DT- 0040 ML051390190 2330

Britta Gustavson DW- 1261 ML051390190 2134

Christine Gyovia DW- 0654 ML051390185 991

Talbott Hagood DW- 1047 ML051390190 1769

Talbott Hagood DW- 0901 ML051390185 1403

Kimberly Anne Halizak DW- 1160 ML051390190 2020

Charles Hall and Adrienne Bodie DW- 0805 ML051390185 1204

Kathleen Halliburton-Ross DW- 1166 ML051390190 2030

Rebecca Hamil DW- 0389 ML051390174 397

Frank Hammond DW- 0702 ML051390185 1099

Dottie Hampton DW- 0785 ML051390185 1184

Alicia Hans DW- 0598 ML051390179 863

Carsten Hansen DW- 0701 ML051390185 1098

Linda Hanson DW- 0489 ML051390179 684

Ann Hardy DW- 0072 ML051390174 72

Christopher Hargrove DW- 0079 ML051390174 79

R. Michael Harman DW- 1169 ML051390190 2035

Linda Harrell DW- 0103 ML051390174 103

Ed Harris DW- 0753 ML051390185 1152
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December 2006 NUREG-1811, Volume II 6-15

Sarah Harris DW- 0294 ML051390174 301

Sarah Harris DW- 0122 ML051390174 122

Elizabeth Harshaw DW- 0546 ML051390179 769

Chris Hartleben DW- 1129 ML051390190 1972

Lindsay Hawks DW- 0817 ML051390185 1224

Sue Hayden DW- 0891 ML051390185 1385

Gina Hayes DW- 0541 ML051390179 764

Jim Head DW- 0119 ML051390174 119

Phil Hearne DW- 0638 ML051390179 941

James Heater DW- 1263 ML051390190 2136

Jennifer Heavilin DW- 0108 ML051390174 108

Jennifer Heavilin DW- 0308 ML051390174 315

Brian Hebeisen DW- 0743 ML051390185 1142

Brian Hebeisen DW- 0162 ML051390174 162

Jenny Heberlein DW- 0819 ML051390185 1237

Flemming Heegaard DW- 0975 ML051390190 1578

Roselind Heinekamp DW- 0691 ML051390185 1088

Steven Heinitz DW- 0396 ML051390174 404

Lillian Henderson DW- 1063 ML051390190 1813

Holly Hendrickson DW- 0581 ML051390179 827

Sarah Hepler DW- 0457 ML051390179 632

Sigrid Hepp-Dax DW- 1219 ML051390190 2090

Amber Herdez DW- 1141 ML051390190 1988

Laura Herndon DW- 0296 ML051390174 303

BettyJean Herner DW- 0053 ML051390174 53

Jeph Herrin DT- 0058 ML051390190 2466

David R. Herring DW- 0403 ML051390174 418

Kristie Hersey DW- 0586 ML051390179 838

Adrian P. Heymer, Nuclear Energy Institute (NEI) DW- 0435 ML051390179 511

Jean E. Hiatt DW- 0653 ML051390185 990

Walter Hill DW- 0908 ML051390185 1414

Dianne Hinch DW- 1168 ML051390190 2034

Dianne Hinch DW- 1162 ML051390190 2022

Mary Hirose DW- 0117 ML051390174 117

Mary Hirose DW- 0388 ML051390174 396

Ceri Hitchcock-Hodgson DW- 1124 ML051390190 1967

Ted Hochstadt DW- 0902 ML051390185 1404

Mary Hodge DW- 0520 ML051390179 731

Rita Hodge DW- 1184 ML051390190 2053

Rebecca Hoeschler DW- 1208 ML051390190 2077

Brendan Hoffman DW- 0088 ML051390174 88

Brendan Hoffman DT- 0016 ML051390190 2252

Lilli Hoffman DW- 0889 ML051390185 1379

Lilli Hoffman DW- 0494 ML051390179 691

Christoph Hogger DW- 1024 ML051390190 1716
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NUREG-1811, Volume II December 2006 6-16

Adrienne Hohenberg DW- 0277 ML051390174 284

Dee Hoke DW- 0167 ML051390174 168

Ronald Holberg DW- 1130 ML051390190 1973

Heidi Holeman DW- 0089 ML051390174 89

Holy Holily Holian DW- 1264 ML051390190 2137

Matthew Holland DW- 0858 ML051390185 1313

Katherine Hollins DW- 0893 ML051390185 1389

Daniel R. Holmes, Piedmont Environmental Council DW- 1157 ML051390190 2012

Rdolfo Holz DW- 0210 ML051390174 217

Daniel Homitz DW- 1066 ML051390190 1822

Marcia Hoodwin DW- 0694 ML051390185 1091

Delbert Horn DT- 0031 ML051390190 2306

Delbert Horn DW- 1149 ML051390190 1999

Rene Horst DW- 0361 ML051390174 369

Jacob Hosen DT- 0061 ML051390190 2473

Susanna Houston DW- 1173 ML051390190 2039

Jay Howard DW- 0579 ML051390179 821

John Howard DW- 1004 ML051390190 1659

Priya Hudson-DiTraglia DW- 1179 ML051390190 2048

Julie Huff DW- 0795 ML051390185 1194

Erica Hulstrom DW- 1113 ML051390190 1947

Janet Hunt DW- 0922 ML051390185 1436

Mitchell Hunt DW- 0365 ML051390174 373

Aurora E. Hunter DW- 1030 ML051390190 1732

Terrace Hutchinson DW- 0206 ML051390174 213

Brenda Hyson DW- 0822 ML051390185 1240

Megan Imbert DW- 1064 ML051390190 1816

Eric Indermuehle DW- 0371 ML051390174 379

John Ingle DW- 0313 ML051390174 320

Ellie L. Irons, Commonwealth of Virginia, Office of

Environmental Impact Review

DW- 0439 ML051390179 555

Ken Irwin DW- 0344 ML051390174 351

Ken Irwin DW- 0104 ML051390174 104

Pamela Irwin DW- 0937 ML051390185 1468

Melanie Jackson DW- 0790 ML051390185 1189

Sherelle Jackson DW- 0626 ML051390179 918

Tom Jackson DW- 0127 ML051390174 127

Tom Jackson DW- 0238 ML051390174 245

Toni Jackson DW- 0680 ML051390185 1047

Boswell Jacqueline DW- 1001 ML051390190 1650

Alicia Jaffe DW- 0695 ML051390185 1092

Anne Jameson DW- 0480 ML051390179 673

Andrew Janicki DW- 0359 ML051390174 366

Andrew Janicki DW- 0017 ML051390174 17

Paula Jaramillo DW- 0124 ML051390174 124
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December 2006 NUREG-1811, Volume II 6-17

Douglas Jaslow DW- 0945 ML051390185 1492

Jean Jearman DW- 0661 ML051390185 1002

Melody Jeffrey DW- 1017 ML051390190 1695

Don Jeffries DW- 0636 ML051390179 937

Beverly Jennings DW- 0730 ML051390185 1128

Steve Jerbi DW- 0100 ML051390174 100

Heath Johnso DW- 0971 ML051390190 1566

Bill Johnson DW- 0172 ML051390174 173

Brock Johnson DW- 1123 ML051390190 1966

Candace Johnson DW- 0057 ML051390174 57

Candace Johnson DW- 0323 ML051390174 330

Kerry Johnson DW- 0169 ML051390174 170

Letitia Johnson DW- 0634 ML051390179 935

Letitia Johnson DW- 0965 ML051390190 1548

Mark Johnson DW- 0036 ML051390174 36

Susan Johnson DW- 0567 ML051390179 801

Vicki Johnson DW- 0260 ML051390174 267

Anne Johnston DW- 0788 ML051390185 1187

David Johnston DW- 0797 ML051390185 1196

Timothy Johnston DW- 0255 ML051390174 262

Timothy Johnston DW- 0159 ML051390174 159

Karen Jones Squires DW- 1091 ML051390190 1892

Lauren Jones DW- 0578 ML051390179 820

M. A. Jones DW- 1249 ML051390190 2122

Virginia B. Jordan DW- 0421 ML051390174 471

James H. Jorgensen DW- 1150 ML051390190 2001

Kathy Joseph DW- 0483 ML051390179 676

Cassie Jurasits DW- 0658 ML051390185 999

Katarzyna DW- 0299 ML051390174 306

Katarzyna DW- 0106 ML051390174 106

Andrew Kalukin DW- 0622 ML051390179 912

Claire Kaplan DW- 0378 ML051390174 386

Jay Kardan DW- 0660 ML051390185 1001

Letitia Kashani DW- 1058 ML051390190 1798

Kat Katsos DW- 0600 ML051390179 865

Ruth Kaufman DW- 0602 ML051390179 869

Ferris Kawar DW- 0256 ML051390174 263

Thomas Kay DW- 0026 ML051390174 26

Thomas Kay DW- 0374 ML051390174 382

Nina Keefer DW- 0097 ML051390174 97

Nina Keefer DW- 0363 ML051390174 371

Dewey Keeton, III DW- 1048 ML051390190 1772

Dewey Keeton III DW- 0904 ML051390185 1408

Susan Keith DW- 1262 ML051390190 2135

Wayne Kelly DW- 0375 ML051390174 383
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NUREG-1811, Volume II December 2006 6-18

Wayne Kelly DW- 0140 ML051390174 140

Roger Kempton DW- 0258 ML051390174 265

Roger Kempton DW- 0077 ML051390174 77

Sarah Kendall DW- 0221 ML051390174 228

Sarah Kendall DW- 0067 ML051390174 67

J. Kennedy DW- 1203 ML051390190 2072

Mark Kennedy DW- 1138 ML051390190 1985

Charles Kern DW- 0571 ML051390179 809

John Kesich DW- 0824 ML051390185 1245

Diba Khan-Bureau DW- 0288 ML051390174 295

Clancey Kilcoyne DW- 0035 ML051390174 35

Pamela Kim DW- 0460 ML051390179 637

Jane Kimbrough DW- 0273 ML051390174 280

Jane Kimbrough DW- 0071 ML051390174 71

Jamie King DW- 0569 ML051390179 805

Julie Kissel DW- 0706 ML051390185 1103

Robbin Knapp DW- 0516 ML051390179 725

Sarah Knorr DW- 0552 ML051390179 777

Helen Kopp DW- 0306 ML051390174 313

Kelly Korenak DW- 0390 ML051390174 398

Dale Krewson DW- 0269 ML051390174 276

Andrea B. Krochalis DW- 0985 ML051390190 1605

Andrea B. Krochalis DW- 0535 ML051390179 756

Samuel Kroiz DW- 0808 ML051390185 1214

Douglas krueger DW- 0297 ML051390174 304

Douglas Krueger DW- 0161 ML051390174 161

Barry Kuhlik DW- 0867 ML051390185 1331

Christopher Kunkel DW- 1083 ML051390190 1873

Wendy Kupsaw DW- 1118 ML051390190 1954

Miriam Kurland DW- 1144 ML051390190 1991

Robert Kurtz DW- 0894 ML051390185 1392

Mark Lackey DW- 0577 ML051390179 819

Kevin Laffey DW- 0328 ML051390174 335

Kevin Laffey DW- 0034 ML051390174 34

Bill LaFleur DW- 0253 ML051390174 260

Pete Lafoillette DW- 0175 ML051390174 176

Pete Lafoillette DW- 0768 ML051390185 1167

Pete Lafoillette DW- 0719 ML051390185 1116

Ken Langslow DW- 0587 ML051390179 841

Sarah Lanzman DW- 1074 ML051390190 1846

Patricia Larch DW- 0093 ML051390174 93

Dorothy Laverdiere DW- 0455 ML051390179 628

Fred Lavy DW- 0509 ML051390179 716

Mary Lawrence DW- 0604 ML051390179 873

Martha Leahy DW- 0044 ML051390174 44
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December 2006 NUREG-1811, Volume II 6-19

Martha Leahy DW- 0283 ML051390174 290

Lauren Leake DW- 0664 ML051390185 1007

David Leavitt DW- 1127 ML051390190 1970

Dana Leeper DW- 1116 ML051390190 1950

Matt Legler DW- 0713 ML051390185 1110

Karen M. Lehman DW- 1195 ML051390190 2064

Sara Lemmon DW- 0098 ML051390174 98

David Lenehan DW- 0436 ML051390179 522

Andrew Leonard DW- 0015 ML051390174 15

Cornelia Lewis DW- 0488 ML051390179 683

Cynthia Lewis DW- 0783 ML051390185 1182

Lena Lewis DW- 0426 ML051390179 499

Steve Liebowitz DW- 1170 ML051390190 2036

Stacey Lighfoot DW- 0027 ML051390174 27

Stacey Lightfoot DW- 0284 ML051390174 291

Terry Lilley DT- 0044 ML051390190 2343

Kathi Lindsay DW- 1191 ML051390190 2060

Michael Loew DW- 1020 ML051390190 1704

David Longacre DW- 1044 ML051390190 1762

Tom Loper DW- 1234 ML051390190 2106

Jonathan Lotz DW- 0479 ML051390179 672

Rebecca Louis DW- 0214 ML051390174 221

James Lowestern DW- 1089 ML051390190 1890

Chrissie Lozano DW- 0568 ML051390179 802

Isaac Ludwing DW- 1182 ML051390190 2051

Charlotte Lundemo DW- 0707 ML051390185 1104

Charlotte Lundemo DW- 0358 ML051390174 365

Kristy Lutjen DW- 0914 ML051390185 1420

Joseph R. Lyle DW- 1235 ML051390190 2107

James P. Lynch DW- 1095 ML051390190 1900

Maggie DW- 0404 ML051390174 420

Robert MacDowell DW- 0637 ML051390179 938

Ivy Main DW- 0576 ML051390179 818

Arjun Makhijani DT- 0001 ML051390190 2292

Joseph P. Malherek and Michele Boyd, Public Citizen DW- 0686 ML051390185 1069

Ben Malloy DW- 0774 ML051390185 1173

Devan Malore DW- 0585 ML051390179 837

Mitchell Maness DW- 0395 ML051390174 403

Mitchell Maness DW- 0047 ML051390174 47

Mitchell Maness DW- 0130 ML051390174 130

Louise Mann DW- 0482 ML051390179 675

Juan Marchini DW- 1052 ML051390190 1784

Peter and Catherine Marciniak DW- 0933 ML051390185 1460

Lisa Marshall DW- 0485 ML051390179 680

Pete Marshall, Leah Marshall, and Miriam Picus DW- 0424 ML051390179 496
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NUREG-1811, Volume II December 2006 6-20

Barbara Martin DW- 0487 ML051390179 682

Heather Martin DW- 0554 ML051390179 779

Rena Martin-Errick DW- 0614 ML051390179 893

Rena Martin-Errick DT- 0017 ML051390190 2255

Christina Martinez DW- 1106 ML051390190 1926

Diana Martz DW- 1269 ML051390190 2142

James Masters DW- 0465 ML051390179 648

Carla Mathews DW- 1260 ML051390190 2133

M. Mathewson DW- 0126 ML051390174 126

KL Matlock DW- 0032 ML051390174 32

Thomas Matsuda DW- 0199 ML051390174 206

Thomas Matsuda DW- 0060 ML051390174 60

Tyla Matteson DT- 0038 ML051390190 2325

Tyla Matteson DW- 0510 ML051390179 717

Elaine Matthew DW- 0212 ML051390174 219

Annette May DW- 0606 ML051390179 879

Robert T. May DW- 1158 ML051390190 2018

Francisco Maya DW- 0219 ML051390174 226

James Mayes DW- 1221 ML051390190 2092

Paul Mayhew DW- 1080 ML051390190 1864

Anne Maziak DW- 0736 ML051390185 1134

Charlotte McAdams DW- 1067 ML051390190 1825

Elizabeth McAnally DW- 0292 ML051390174 299

Clare McBrien DW- 0793 ML051390185 1192

Lauren McCabe DW- 0972 ML051390190 1569

Kim McClamroch DW- 1227 ML051390190 2098

Joe McCloskey DW- 0549 ML051390179 772

Barney McComas DW- 0305 ML051390174 312

Lindsey McConnell DW- 0116 ML051390174 116

John McCoy DT- 0032 ML051390190 2311

Kris McCradic DW- 0039 ML051390174 39

Kris McCradic DW- 0739 ML051390185 1137

Amee McDermott DW- 0949 ML051390185 1502

Marion McDonald DW- 0815 ML051390185 1221

Marion McDonald DW- 0411 ML051390174 441

Marion McDonald DW- 0814 ML051390185 1220

Wendy McFadden DW- 0184 ML051390174 185

Wendy McFadden DW- 0772 ML051390185 1171

Mary Ann McFarland DW- 0662 ML051390185 1005

Yvonne McGhee DW- 1055 ML051390190 1789

Mary E. McGilligan DW- 0386 ML051390174 394

Mary E. McGilligan DW- 1270 ML051390190 2143

Colleen McGlone DW- 0307 ML051390174 314

Colleen McGlone DW- 0132 ML051390174 132

Gail McGlone DW- 0136 ML051390174 136
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December 2006 NUREG-1811, Volume II 6-21

Gail McGlone DW- 0366 ML051390174 374

Anne McGurk DW- 0459 ML051390179 634

Anne McGurk DW- 0425 ML051390179 498

Bill McLaughlin DT- 0059 ML051390190 2467

Beth McLeod DW- 0833 ML051390185 1255

Jon McMillan DW- 0934 ML051390185 1461

Tisha McMillan DW- 0666 ML051390185 1013

Jason McMillen DW- 0944 ML051390185 1489

Christopher Meder DW- 0246 ML051390174 253

Kirit Mehta DW- 0928 ML051390185 1449

Rich Meier DW- 0909 ML051390185 1415

Margaret Meister DW- 0486 ML051390179 681

Ana Najera Mendoza DW- 0014 ML051390174 14

Eric Mens DW- 0352 ML051390174 359

Jamsin Merida DW- 0530 ML051390179 745

Nazen Merjian DW- 0187 ML051390174 188

Nicole Mettler DW- 0491 ML051390179 686

Jennifer Meyer DW- 0186 ML051390174 187

Jennifer Meyer DW- 0831 ML051390185 1253

Marilyn Meyer DW- 1197 ML051390190 2066

Lillian Mezey DW- 0827 ML051390185 1249

Anne Mickel DW- 0633 ML051390179 932

Michael Mihok DW- 0232 ML051390174 239

Michael Mihok DW- 0066 ML051390174 66

Kathleen Mikulski DW- 0059 ML051390174 59

Kathy Mikulski DW- 0349 ML051390174 356

Cliff Miller DW- 1088 ML051390190 1888

Dianne Miller DW- 0763 ML051390185 1162

Glenn Miller DW- 0711 ML051390185 1108

Griff Miller DW- 1069 ML051390190 1831

Griff Miller DW- 0700 ML051390185 1097

Jason Miller DW- 0887 ML051390185 1373

Ruth Miller DW- 0689 ML051390185 1086

Susan Emge Milliner DW- 1038 ML051390190 1748

Stephen Mills DW- 0473 ML051390179 664

David Mitchell DW- 0538 ML051390179 759

Lee Mitchell DW- 0679 ML051390185 1044

Roy Mitchell DW- 0915 ML051390185 1421

Roy Mitchell DW- 1013 ML051390190 1683

Tori Mitchell DW- 1226 ML051390190 2097

Audrey Moeller DW- 1008 ML051390190 1670

Joe Montague DT- 0045 ML051390190 2345

Neah Monteiro DW- 1243 ML051390190 2116

Shaun Mooney DW- 0558 ML051390179 785

Shaun Mooney DW- 0559 ML051390179 788
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NUREG-1811, Volume II December 2006 6-22

Matt Moore DW- 0125 ML051390174 125

Matt Moore DW- 0335 ML051390174 342

Kimberly Moreno DW- 0472 ML051390179 661

John Morgan DW- 0900 ML051390185 1402

Katherine Morgan DW- 0620 ML051390179 906

Katherine Morgan DW- 0508 ML051390179 715

Allison Morris DW- 0596 ML051390179 859

Elijah Morrison DW- 1005 ML051390190 1662

Jessica Mottley DW- 1255 ML051390190 2128

Adrienne Moumin DW- 0327 ML051390174 334

Adrienne Moumin DW- 0261 ML051390174 268

Adrienne Moumin DW- 0074 ML051390174 74

Conway Moy DW- 0632 ML051390179 929

Allen Muchnick DW- 0880 ML051390185 1356

Reed Muehlman DW- 0656 ML051390185 995

Robert Mueller DW- 0984 ML051390190 1603

Victoria Mullins DW- 1076 ML051390190 1852

Bill Murphy DT- 0028 ML051390190 2301

Margaret Murphy DW- 0898 ML051390185 1400

Shirley Napps DW- 0731 ML051390185 1129

Michael Neil DW- 0765 ML051390185 1164

Michael Neil DW- 0141 ML051390174 141

James Nelson DW- 0807 ML051390185 1213

Teresa Nemeth DW- 0966 ML051390190 1551

Pamela Newton DW- 0938 ML051390185 1471

Vince Newton DW- 0677 ML051390185 1038

Chris Nicholas DW- 0503 ML051390179 704

Vicki Nichols Goldstein DW- 0970 ML051390190 1563

Rael Nidess DW- 1035 ML051390190 1743

Anne Nielsen DW- 1062 ML051390190 1810

Evelyne Noel DW- 0405 ML051390174 425

Evelyne Noel DW- 0197 ML051390174 203

James M. Nordlund DW- 1265 ML051390190 2138

Nuclear Energy Institute (NEI), Adrian P. Heymer DW- 0435 ML051390179 511

Nuclear Information Resource Service, Paul Gunter DW- 1154 ML051390190 2005

Nuclear Information Resource Service, Paul Gunter DT- 0040 ML051390190 2330

Jeanne O’Hara DW- 0953 ML051390185 1514

Margaret O’Keefe DW- 1155 ML051390190 2010

Julie Obermeyer DW- 1215 ML051390190 2086

Catherine OBrion DW- 0907 ML051390185 1413

Robert Oldham DW- 0832 ML051390185 1254

Jose Maria Olmos DW- 0688 ML051390185 1085

Thomas Olsen DW- 0864 ML051390185 1324

Lisa Osborn DW- 0665 ML051390185 1010

Carla Osborne DW- 0714 ML051390185 1111
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December 2006 NUREG-1811, Volume II 6-23

Bob Osland DW- 1207 ML051390190 2076

Amber Ostheimer DW- 1242 ML051390190 2115

Judith Ostrowski DW- 0476 ML051390179 667

Jim Oxyer DW- 0756 ML051390185 1155

Darren Pace and Aaron Eichorst DW- 0419 ML051390174 467

Rachel Page DW- 0644 ML051390179 954

Carolynn Pakeltis DW- 0762 ML051390185 1161

Anjili Pal DW- 0875 ML051390185 1343

Michelle Palladine DW- 0086 ML051390174 86

Michelle Palladine DW- 0264 ML051390174 271

Liz Palmer DW- 0466 ML051390179 649

Diana C. Parker DW- 0857 ML051390185 1311

Diana Parker DW- 0454 ML051390179 627

Floret Parker DW- 0999 ML051390190 1644

James Parker DW- 0599 ML051390179 864

Michelle Parker DW- 0979 ML051390190 1588

Michelle Parker DW- 1271 ML051390190 2144

Mark Parlette DW- 0982 ML051390190 1597

Richard A. Parrish and Morgan Butler, Southern

Environmental Law Center

DW- 1122 ML051390190 1958

Samuel Parrucci DW- 1096 ML051390190 1902

Richard Pasichnyk DW- 0368 ML051390174 376

Rob Pates DW- 0830 ML051390185 1252

A. Patrick DW- 0143 ML051390174 143

A. Patrick DW- 0316 ML051390174 323

Meaghan Patrick DW- 0215 ML051390174 222

Meaghan Patrick DW- 0013 ML051390174 13

Cynthia Patterson DW- 0749 ML051390185 1148

Kalin Patterson DW- 0750 ML051390185 1149

H. Paul Bigler DW- 0427 ML051390179 501

Dexter Payne DW- 0881 ML051390185 1359

Bob Pechman DW- 0528 ML051390179 739

Bob Peckman DW- 0780 ML051390185 1179

Robert A. Pedde and Lawrence A. Salomone,

Westinghouse Savannah River Co.

DW- 0818 ML051390185 1225

Robert Pedde, President, Westinghouse Savannah

River Co.

DW- 0416 ML051390174 447

Sharon Pederslie DW- 0356 ML051390174 363

Michaelene Pederson DW- 0671 ML051390185 1024

Lance Pedigo DW- 1051 ML051390190 1781

Kelle Peeplez DW- 0759 ML051390185 1158

Tina Pence DW- 0845 ML051390185 1287

Angela Burnett Penn DW- 0734 ML051390185 1132

Roberto Perez DW- 0551 ML051390179 776

France Perlman DW- 1152 ML051390190 2003
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-24

Ignacia Pessoa DW- 0923 ML051390185 1439

Emily and Jeremy Peters DW- 0778 ML051390185 1177

Ron Peterson and Family DW- 1053 ML051390190 1785

Scott Peterson DT- 0027 ML051390190 2297

Scott Peterson, NEI DW- 0668 ML051390185 1017

Connor Petren DW- 0331 ML051390174 338

Chell D. Pfeffer DW- 0091 ML051390174 91

Peggy Phan, Minneapolis, MN DW- 0300 ML051390174 307

Donna Phillips DW- 0657 ML051390185 996

Scot Phillips DW- 0259 ML051390174 266

Scott Phillips DW- 0076 ML051390174 76

Alva Pick DW- 0364 ML051390174 372

Piedmont Environmental Council, Daniel R. Holmes DW- 1157 ML051390190 2012

Donna Pienkowski DW- 0432 ML051390179 506

Donna Pienkowski DW- 0564 ML051390179 797

Lawrence Pierce DW- 0458 ML051390179 633

Joseph Pipik DW- 0418 ML051390174 465

Julie Pitre DW- 1012 ML051390190 1682

Elaine Plamquist DW- 0855 ML051390185 1307

Victoria Plummer DW- 1133 ML051390190 1978

Laura Poisson DW- 0548 ML051390179 771

Joseph Ponisciak DW- 1134 ML051390190 1979

Charles Pool DW- 1010 ML051390190 1676

Jason Pooler DW- 0853 ML051390185 1305

Sarah Pope DW- 0222 ML051390174 229

Judy Popelas DW- 0500 ML051390179 699

Joe Porfert DW- 1247 ML051390190 2120

Jami Porter Lara DW- 1187 ML051390190 2056

Caroline Pott DW- 0265 ML051390174 272

Phyllis Pownall DW- 1111 ML051390190 1941

Andrew Presgraves DW- 0590 ML051390179 851

Stephen Proctor DW- 1056 ML051390190 1792

Linda Prostko DW- 0745 ML051390185 1144

Linda Prostko DW- 0113 ML051390174 113

D. Prusik DW- 1025 ML051390190 1719

Barbara Pryor DW- 1086 ML051390190 1882

Cindy Pryor DW- 1034 ML051390190 1740

Public Citizen, Michele Boyd and Joseph P. Malherek DW- 0686 ML051390185

Blake Puhak DW- 0842 ML051390185 1278

Brian Quam DW- 0940 ML051390185 1477

Leah Quam DW- 0952 ML051390185 1511

Abigail Quesinberry DW- 0916 ML051390185 1422

Jill Quick DW- 1119 ML051390190 1955

Robin Rabens DW- 1238 ML051390190 2111

Juliana Radloff DW- 0724 ML051390185 1121
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-25

Shyla Raghav DW- 0272 ML051390174 279

Shyla Raghav DW- 0049 ML051390174 49

Karen Rakes DW- 0899 ML051390185 1401

Leah Rampy DW- 1061 ML051390190 1807

Jill Ramson DW- 1188 ML051390190 2057

David Randall DW- 0142 ML051390174 142

Dee Randolph DW- 0716 ML051390185 1113

Robert Rapice DW- 0519 ML051390179 730

Aislynn Raymond DW- 0507 ML051390179 712

Patricia Raynor DW- 0741 ML051390185 1139

Nancy Re DW- 0493 ML051390179 690

Mark Reback DW- 0200 ML051390174 207

Mark Reback DW- 1103 ML051390190 1919

Mark Reback DW- 0109 ML051390174 109

Michaela Redden DW- 1164 ML051390190 2028

Sherley Redding DW- 0428 ML051390179 502

Sherley Redding DW- 1104 ML051390190 1920

Audrey J. Reed DW- 1216 ML051390190 2087

Ben Reed DW- 0340 ML051390174 347

Ben Reed DW- 0058 ML051390174 58

Billie Reed DW- 1266 ML051390190 2139

Mark Reif DW- 0513 ML051390179 722

Joshua Rellick DW- 0615 ML051390179 896

Kenneth Remmers, Waterside Property Owners of Lake

Anna

DW- 0806 ML051390185 1206

Kenneth Remmers, Waterside Property Owners of Lake

Anna

DW- 0400 ML051390174 411

Charles Rettinger DW- 0720 ML051390185 1117

Helen R. Reutlinger DW- 0834 ML051390185 1256

Robert Rexroat DW- 0430 ML051390179 504

Robert Rexroat DW- 0412 ML051390174 443

Kirk Rhoads DW- 0250 ML051390174 257

Kirk Rhoads DW- 0075 ML051390174 75

Carlon Ribbins DW- 0332 ML051390174 339

Jim Riccio DT- 0033 ML051390190 2313

Ron Richards DW- 0229 ML051390174 236

Ron Richards DW- 0007 ML051390174 7

William Richards DW- 0448 ML051390179 617

Carmen Rico DW- 0286 ML051390174 293

Emily Rieber DW- 0391 ML051390174 399

Kelly Riley DW- 0240 ML051390174 247

Kelly Riley DW- 0011 ML051390174 11

Margaret Roach DW- 0591 ML051390179 852

Keegan Roberson DW- 0324 ML051390174 331

John Mark Roberton DW- 0263 ML051390174 270
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-26

Jon Roberts DW- 0248 ML051390174 255

Phillip Rockey DW- 0062 ML051390174 62

Ann Rogers DW- 1029 ML051390190 1729

Marliss Rogers DW- 0383 ML051390174 391

Ruthann Roka DW- 1142 ML051390190 1989

Darthula Romine DT- 0054 ML051390190 2459

Heidi Rood DW- 0029 ML051390174 29

Carol Rose DW- 0496 ML051390179 693

Cheryl Rosenfeld DW- 0338 ML051390174 345

Stewart Rosenkrantz DW- 0230 ML051390174 237

Stewart Rosenkrantz DW- 0024 ML051390174 24

Jerry Rosenthal DT- 0015 ML051390190 2250

Guy Ross DW- 1094 ML051390190 1897

David Roth DW- 0870 ML051390185 1334

Gregory Rouse DW- 1161 ML051390190 2021

Kira Routh DW- 0840 ML051390185 1272

Virginia Rovnyak DT- 0022 ML051390190 2278

Virginia Rovnyak DW- 0410 ML051390174 430

Ronald Russillo DW- 1210 ML051390190 2079

Robert Rutkowski DW- 0006 ML051390174 6

Robert Rutkowski DW- 0919 ML051390185 1429

Linda Safley DW- 0177 ML051390174 178

Joanna Salidis DW- 0792 ML051390185 1191

Michelle Salisbury DW- 0854 ML051390185 1306

Sherry Salomon DW- 0329 ML051390174 336

Anthony Sanchez DW- 0085 ML051390174 85

Helen Sanders DW- 0684 ML051390185 1057

Richard Sanders DW- 1202 ML051390190 2071

Maritza Santana DW- 0342 ML051390174 349

Roger P. Santerre DW- 0927 ML051390185 1448

Leonardo Sarli DW- 0635 ML051390179 936

Leonardo Sarli DW- 0964 ML051390190 1545

Chris Saunders DW- 1199 ML051390190 2068

Thomas Savage DW- 1108 ML051390190 1932

Rosemarie Sawdon DW- 0506 ML051390179 709

Rosemarie Sawdon DW- 0801 ML051390185 1200

Rosemarie Sawdon DW- 0652 ML051390185 989

Rosemarie Sawdon DW- 0641 ML051390179 948

Noah Scalin DW- 0843 ML051390185 1281

William and Nedra Scarrow DW- 1009 ML051390190 1673

Sarah Schaefer DW- 1165 ML051390190 2029

Rebecca Schild DW- 0319 ML051390174 326

Kerry Schindl DW- 0692 ML051390185 1089

Keith Schlesinger DW- 0194 ML051390174 197

Arthur Schmidt DW- 0447 ML051390179 616
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-27

Tavis Schmidt DW- 0133 ML051390174 133

Tavis Schmidt DW- 0722 ML051390185 1119

Kelly Schneider DW- 0357 ML051390174 364

Paul Schneller DW- 0341 ML051390174 348

Mark Schnider DW- 1220 ML051390190 2091

Kurt Schroeder DW- 0837 ML051390185 1263

Linda Schweppe DW- 0223 ML051390174 230

Robert Seltzer DW- 0220 ML051390174 227

Diana Sette DW- 0144 ML051390174 144

Diana Sette DW- 0742 ML051390185 1141

John Sexson DW- 0553 ML051390179 778

Charles Seyffer DW- 1018 ML051390190 1698

Erika Shamo DW- 0148 ML051390174 148

Erika Shamo DW- 0295 ML051390174 302

Andrea Shandor DW- 0905 ML051390185 1409

Tim Shank DW- 0607 ML051390179 880

David Shantz DW- 0993 ML051390190 1629

Michael Shapiro DW- 1040 ML051390190 1752

Kimberley Sharp DW- 0769 ML051390185 1168

Elaine Shaw DW- 0402 ML051390174 416

Janis Shaw DW- 1193 ML051390190 2062

Jason Shawn DW- 0523 ML051390179 734

John Shea DW- 0597 ML051390179 862

Lisa Shell DT- 0020 ML051390190 2267

Lisa Shell DW- 0863 ML051390185 1320

Judith Shematek DW- 0501 ML051390179 702

Judith Shematek DW- 0302 ML051390174 309

Judith Shematek DW- 0613 ML051390179 890

Sarah Sherwood Litchfield DW- 0188 ML051390174 189

Jone Shilliday DW- 0846 ML051390185 1290

Mandy Shipler DW- 0189 ML051390174 190

Charlotte Shnaider DW- 0789 ML051390185 1188

Denise Shreeve DW- 0631 ML051390179 926

Elizabeth Shuey DW- 1223 ML051390190 2094

Jean Sideris DW- 0001 ML051390174 1

Suzanne Sievers-Bartlett DW- 0726 ML051390185 1123

Chandra Sigmund DW- 0003 ML051390174 3

Mr. and Mrs. John Silver DW- 0682 ML051390185 1053

Seth Silverman DW- 0139 ML051390174 139

Seth Silverman DW- 0346 ML051390174 353

Jamie Simo DW- 0670 ML051390185 1022

Jane Simpson DW- 0924 ML051390185 1442

Sally Simpson DW- 0043 ML051390174 43

Sally Simpson DW- 0267 ML051390174 274

Stephanie Sims DW- 0281 ML051390174 288
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-28

Stephanie Sims DW- 0022 ML051390174 22

Barbara Singer DW- 0728 ML051390185 1125

Barbara Singer DW- 0068 ML051390174 68

Robert Singleterry DW- 0360 ML051390174 367

Robert Singleterry DT- 0043 ML051390190 2341

Silja Sistok-Katz DW- 0451 ML051390179 620

Silja Sistok-Katz DW- 0839 ML051390185 1269

Shelly and Sid Sitzer DW- 0413 ML051390174 444

Shelly and Sid Sitzer DW- 0816 ML051390185 1223

Shelly Sitzer DW- 0433 ML051390179 507

Sue Sjolin DW- 0030 ML051390174 30

Hannah Sk DW- 0941 ML051390185 1480

Kate Skolnick DW- 0176 ML051390174 177

Maya Skopal DW- 0996 ML051390190 1637

Richard Sloan DW- 0555 ML051390179 782

Ben Sloane DT- 0014 ML051390190 2246

Shaun Smakal DW- 0315 ML051390174 322

William Small DT- 0063 ML051390190 2463

Gene Smith DW- 0583 ML051390179 833

Jennifer Smith DW- 1087 ML051390190 1885

John Patrick Smith DW- 0828 ML051390185 1250

Kevin Smith DW- 0592 ML051390179 853

Saron Smith DW- 0310 ML051390174 317

Sharon Smith DW- 0118 ML051390174 118

Chelsea Snelgrove DW- 0110 ML051390174 110

Chelsea Snelgrove DW- 0270 ML051390174 277

Pamelynn Snell DW- 1079 ML051390190 1861

Amanda Snyder DW- 0002 ML051390174 2

Kelly Snyder DW- 1098 ML051390190 1908

Kelly Snyder DW- 0525 ML051390179 736

Ron Sokol DW- 0484 ML051390179 677

Dina Sorensen DW- 0733 ML051390185 1131

Patricia Soriano DW- 1070 ML051390190 1834

Yvonne Sorovacu DW- 1131 ML051390190 1974

Lucy Sotar DW- 1042 ML051390190 1758

Southern Environmental Law Center, Morgan Butler and

Richard A. Parrish

DW- 1122 ML051390190 1958

Valerie Soza DW- 0276 ML051390174 283

Valerie Soza DW- 0016 ML051390174 16

Chris Spahn DW- 0723 ML051390185 1120

Nancy Spears DW- 0715 ML051390185 1112

Nancy Spears DW- 0157 ML051390174 157

Nancy Spears DW- 0023 ML051390174 23

Nancy Spears DW- 0287 ML051390174 294

Karen Spencer DW- 1117 ML051390190 1953
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-29

Marina Spitkovskaya DW- 0336 ML051390174 343

Marina Spitkovskaya DW- 0056 ML051390174 56

Richard Spotts DW- 0243 ML051390174 250

Richard Spotts DW- 0050 ML051390174 50

Richard Spotts DW- 1114 ML051390190 1948

Chris Stafford DW- 1033 ML051390190 1737

Edgar Stahl DW- 0710 ML051390185 1107

Marlene Stanley DW- 0236 ML051390174 243

Michaela Starrett DW- 1246 ML051390190 2119

Shauna Steigerwald DW- 1213 ML051390190 2082

Paul Stenbjorn DW- 0446 ML051390179 615

Mary Steponkus DW- 0962 ML051390190 1539

Rachael Sterlin DW- 0698 ML051390185 1095

Catherine Stevens DW- 1190 ML051390190 2059

Douglas Stewart DW- 0593 ML051390179 854

Katie Stif DW- 0957 ML051390185 1524

Paula Stober DW- 0251 ML051390174 258

Mia Stollenwerk DW- 0709 ML051390185 1106

Jem Stone DW- 0621 ML051390179 909

Gary Stoner DW- 0550 ML051390179 775

Karen Stout DW- 1205 ML051390190 2074

Heather Strachan DW- 0646 ML051390179 959

Adrienne Strandberg DW- 1068 ML051390190 1828

Agnes Stringfellow DW- 0987 ML051390190 1611

Melissa Strobel DW- 0995 ML051390190 1634

Michael Stuart DW- 0820 ML051390185 1238

Judy Stufflebeam DW- 1125 ML051390190 1968

Robert Stumm DW- 0406 ML051390174 426

Katie Stump DW- 0872 ML051390185 1336

John Sukovich DW- 1099 ML051390190 1911

Alice Sullivan DW- 1126 ML051390190 1969

Barbara Sullivan DW- 1232 ML051390190 2103

Steve Summers DW- 0042 ML051390174 42

Steve Summers DW- 0231 ML051390174 238

Daniel Sumrall DW- 1065 ML051390190 1819

Nida Sun DW- 0376 ML051390174 384

Christian Sund DW- 0468 ML051390179 655

M. Sundy DW- 1016 ML051390190 1692

Dawn Surowski DW- 0708 ML051390185 1105

Emanuel Suter DW- 0939 ML051390185 1474

Josh Swartzbaugh DW- 0809 ML051390185 1215

Shannon Sweeney DW- 1146 ML051390190 1993

Judy Szeman DW- 0968 ML051390190 1557

Cynthia Tapley DW- 1225 ML051390190 2096

Heather Taplin DW- 0687 ML051390185 1084
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-30

Lynn Tarek DW- 0137 ML051390174 137

Suzanne Tarr DW- 0936 ML051390185 1465

Kristin Taverna DW- 0401 ML051390174 415

Leslie Tawnamaia DW- 0773 ML051390185 1172

Kelly L. Taylor DW- 0826 ML051390185 1248

Bill R. Teer DW- 1248 ML051390190 2121

Joe Terry DW- 1109 ML051390190 1935

Pat Therrien DW- 0918 ML051390185 1426

Abayha Thiel DT- 0007 ML051390190 2226

Abhaya Thiele DW- 0182 ML051390174 183

Abhaya Thiele DW- 0183 ML051390174 184

Abhaya Thiele DW- 1176 ML051390190 2044

Joanne M. Thiele DW- 0874 ML051390185 1340

Pablo Thomason DW- 0676 ML051390185 1035

Virginia M. Thull DW- 0431 ML051390179 505

Matthew Tiffault DW- 0325 ML051390174 332

Don Timmerman, Roberta Thurstin DW- 1100 ML051390190 1912

Hollis Toal DW- 0145 ML051390174 145

Julio Torres DW- 0101 ML051390174 101

Nicole Totino DW- 0348 ML051390174 355

Andrew Town DW- 0595 ML051390179 858

William G. Tresky DW- 0429 ML051390179 503

Jason Trew DW- 0539 ML051390179 760

Jason Trew DW- 0244 ML051390174 251

Gail Troy DW- 0195 ML051390174 199

Chip Tucker DW- 0825 ML051390185 1246

Ingrid Turner DW- 0440 ML051390179 601

Willis Turner DW- 0961 ML051390190 1536

Norman B. Tweed, Jr. DW- 1007 ML051390190 1668

Anne Tyrrell DW- 1077 ML051390190 1855

Joseph Tyrrell DW- 0892 ML051390185 1386

Kris Unger DW- 0373 ML051390174 381

Kris Unger DW- 0871 ML051390185 1335

Howard Urbach DW- 1027 ML051390190 1723

U.S. Environmental Protection Agency, William Arguto DW- 0422 ML051390174 472

Betty J. Van Wicklen DW- 0748 ML051390185 1147

Sara Van Buren DW- 0381 ML051390174 389

Felicia VanderBranden DW- 1268 ML051390190 2141

Kevin Vaught DW- 0041 ML051390174 41

Kevin Vaught DW- 0239 ML051390174 246

Yvonne Vecchia DW- 1240 ML051390190 2113

Asa Vegodski DT- 0008 ML051390190 2228

Eve Venema DW- 0721 ML051390185 1118

Eve Venema DW- 0147 ML051390174 147

Joetta Venneman DW- 0932 ML051390185 1459
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-31

Jan Vinegar DW- 0849 ML051390185 1299

Ann Volk DW- 1253 ML051390190 2126

Anna Von Gehr DW- 0775 ML051390185 1174

Katrina Von Briesen DW- 0456 ML051390179 629

John Votta DW- 0757 ML051390185 1156

Sandra Wagner DW- 0081 ML051390174 81

Bryan L. Wagoner DW- 0623 ML051390179 913

Laura Walters DW- 0247 ML051390174 254

Martha Waltman DW- 0045 ML051390174 45

Martha Waltman DW- 0237 ML051390174 244

Timothy D. Wampler DW- 0935 ML051390185 1464

Claire Ward DW- 1081 ML051390190 1867

Erin Ward DW- 0988 ML051390190 1614

Sheila Ward DW- 0090 ML051390174 90

Sheila Ward DW- 0322 ML051390174 329

Sheila Ward DW- 1230 ML051390190 2101

Cassandra Warren DW- 1236 ML051390190 2109

Waterside Property Owners of Lake Anna, Kenneth

Remmers

DW- 0806 ML051390185 1206

Waterside Property Owners of Lake Anna, Kenneth

Remmers

DW- 0400 ML051390174 411

Randal and Donna Watkins DW- 0181 ML051390174 182

Robin Watkins DW- 0629 ML051390179 921

Claire Watson DW- 0747 ML051390185 1146

Claire Watson DW- 0146 ML051390174 146

Claire Watson DW- 0065 ML051390174 65

Claire Watson DW- 0268 ML051390174 275

Cheryl Weber DW- 0469 ML051390179 656

Adam Weesner DW- 1185 ML051390190 2054

Michaela Wehner DW- 0862 ML051390185 1319

J. Weikert DW- 0951 ML051390185 1508

Tom Weis DW- 0947 ML051390185 1498

Joanna F. Welch DW- 0228 ML051390174 235

Joanna F. Welch DW- 0092 ML051390174 92

Kristina Weller DW- 0334 ML051390174 341

Donna Wellman DW- 0499 ML051390179 698

Catherine Welsh DW- 0925 ML051390185 1445

Jane Wentworth DW- 1090 ML051390190 1891

Westinghouse Savannah River Co., Robert A. Pedde

and Lawrence A. Salomone

DW- 0818 ML051390185 1225

President, Westinghouse Savannah River Co., Robert

Pedde

DW- 0416 ML051390174 447

Jared Wetherington DW- 0543 ML051390179 766

Alice Whealin DW- 1021 ML051390190 1707

Joe Whetstone DW- 0873 ML051390185 1339
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

NUREG-1811, Volume II December 2006 6-32

Eric White DW- 1107 ML051390190 1929

Lily Whitesell DW- 0942 ML051390185 1483

Doris Whitfield DW- 0642 ML051390179 950

Vernon and Carol Whitney DW- 1172 ML051390190 2038

Betty.Van Wicklen DW- 0025 ML051390174 25

David Wilcox DW- 0275 ML051390174 282

James Wilcox DW- 0515 ML051390179 724

Brenda Wiley DW- 0610 ML051390179 885

Craig Williams DW- 0254 ML051390174 261

David Williams DW- 0173 ML051390174 174

Marilyn Williams DW- 0012 ML051390174 12

Martha Williams DW- 0860 ML051390185 1317

Paul Williams DW- 0211 ML051390174 218

Paul Williams DW- 0121 ML051390174 121

Richard H. Williams DW- 0242 ML051390174 249

Barbara Williamson DW- 1050 ML051390190 1778

Ryan Williamson DW- 1028 ML051390190 1726

Sandra Williamson DW- 0166 ML051390174 167

Craig Willimas DW- 0155 ML051390174 155

Ken Willis DW- 0608 ML051390179 881

Alisha Wilson DW- 1175 ML051390190 2043

Amy Wilson DW- 0330 ML051390174 337

Beka Wilson DW- 0020 ML051390174 20

Bill Wilson DW- 0370 ML051390174 378

Brian Wilson DW- 0954 ML051390185 1517

Susan Wilson DW- 0917 ML051390185 1423

Dawn Winalski DW- 0732 ML051390185 1130

Dawn Winalski DW- 0018 ML051390174 18

Sean Winkel DW- 1200 ML051390190 2069

Sarah Wise DW- 0869 ML051390185 1333

Sarah Wise DW- 1072 ML051390190 1840

Marsha Withers DW- 0890 ML051390185 1382

Katie Wolf DW- 0149 ML051390174 149

Adel Wood DT- 0012 ML051390190 2244

Adele Wood DW- 0669 ML051390185 1021

Barbara L. Wood DW- 0225 ML051390174 232

Barbara L. Wood DW- 0040 ML051390174 40

Susannah Wood DW- 0779 ML051390185 1178

Michael Woodbridge DW- 1084 ML051390190 1876

Ann Woodlief DW- 0978 ML051390190 1587

Judy Woods DW- 1159 ML051390190 2019

Mary H. Woodward DW- 0301 ML051390174 308

Frank Worshek DW- 0796 ML051390185 1195

Sharon Wright DW- 1153 ML051390190 2004

Warren Wright DW- 0271 ML051390174 278
Commenter Name, Organization where specified

Comment

Number

Accession

Number

Page

Number

December 2006 NUREG-1811, Volume II 6-33

Warren Wright DW- 0063 ML051390174 63

Zaahira Wyne DW- 0497 ML051390179 694

Jowita Wysocka DW- 0992 ML051390190 1626

Suzanne Yeaman DW- 0856 ML051390185 1308

Ana Yong Soler DW- 0737 ML051390185 1135

Linda York DW- 0112 ML051390174 112

Linda York DW- 0735 ML051390185 1133

Stasi York DW- 0565 ML051390179 799

Stasi York DW- 1046 ML051390190 1766

Coleen Zahnke DW- 0786 ML051390185 1185

K. Zalewski DW- 0160 ML051390174 160

Sara Zaza DW- 1073 ML051390190 1843

Lou Zeller, Blue Ridge Environmental Defense League DT- 0034 ML051390190 2316

Louis Zeller, Blue Ridge Environmental Defense League DW- 1163 ML051390190 2025

James Zinck DW- 1036 ML051390190 1744

James Zizzo DW- 1128 ML051390190 1971

Alison Zyla DW- 1194 ML051390190 2063

North American Youth Generation in Nuclear Petition

Signers

DT- 0052 ML051390190 2360

International Organization Petition Signers DT- 0053 ML051390190 2476

Table 6-2. Draft EIS Index Arranged Numerically, Sorted by Comment Letter Number

Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

DT-1 Arjun Makhijani Public Meeting (2/17/05) ML050750309 --

DT-2 Donald Day Public Meeting (2/17/05) ML050750309 --

DT-3 Ray Dribble Public Meeting (2/17/05) ML050750309 --

DT-4 Gene Grecheck, Dominion

Nuclear North Anna, LLC 

Public Meeting (2/17/05) ML050750309 --

DT-5 Paxus Calta Public Meeting (2/17/05) ML050750309 --

DT-6 Sam Forrest Public Meeting (2/17/05) ML050750309 --

DT-7 Abayha Thiel Public Meeting (2/17/05) ML050750309 --

DT-8 Asa Vegodski Public Meeting (2/17/05) ML050750309 --

DT-9 Sue Chase Public Meeting (2/17/05) ML050750309 --

DT-10 Jim Bryan Public Meeting (2/17/05) ML050750309 --

DT-11 Bill Bourdin Public Meeting (2/17/05) ML050750309 --

DT-12 Adel Wood Public Meeting (2/17/05) ML050750309 --

DT-13 Richard Diamond Public Meeting (2/17/05) ML050750309 --

DT-14 Ben Sloane Public Meeting (2/17/05) ML050750309 --

DT-15 Jerry Rosenthal Public Meeting (2/17/05) ML050750309 --

DT-16 Brendan Hoffman Public Meeting (2/17/05) ML050750309 --

DT-17 Rena Martin-Errick Public Meeting (2/17/05) ML050750309 --

DT-18 Rebecca Faris Public Meeting (2/17/05) ML050750309 --

DT-19 Michele Boyd Public Meeting (2/17/05) ML050750309 --
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-34

DT-20 Lisa Shell Public Meeting (2/17/05) ML050750309 --

DT-21 Richard Ball Public Meeting (2/17/05) ML050750309 --

DT-22 Virginia Robnyak Public Meeting (2/17/05) ML050750309 --

DT-23 Jennifer Conner Public Meeting (2/17/05) ML050750309 --

DT-24 Jay Bolan Public Meeting (2/17/05) ML050750309 --

DT-25 Sama Bilbao y Leon Public Meeting (2/17/05) ML050750309 --

DT-26 Brian Buckley Public Meeting (2/17/05) ML050750309 --

DT-27 Scott Peterson Public Meeting (2/17/05) ML050750309 --

DT-28 Bill Murphy Public Meeting (2/17/05) ML050750309 --

DT-29 Dick Clark Public Meeting (2/17/05) ML050750309 --

DT-30 Unidentified speaker Public Meeting (2/17/05) ML050750309 --

DT-31 Delbert Horn Public Meeting (2/17/05) ML050750309 --

DT-32 John McCoy Public Meeting (2/17/05) ML050750309 --

DT-33 Jim Riccio Public Meeting (2/17/05) ML050750309 --

DT-34 Lou Zeller, Blue Ridge

Environmental Defense

League

Public Meeting (2/17/05) ML050750309 --

DT-35 Brianne Boylan Public Meeting (2/17/05) ML050750309 --

DT-36 Seamus Allman Public Meeting (2/17/05) ML050750309 --

DT-37 Sue Frandel-Streit Public Meeting (2/17/05) ML050750309 --

DT-38 Tyla Matteson Public Meeting (2/17/05) ML050750309 --

DT-39 Bill Casino Public Meeting (2/17/05) ML050750309 --

DT-40 Paul Gunter, Nuclear

Information Resource Service

Public Meeting (2/17/05) ML050750309 --

DT-41 Jana Cutler Public Meeting (2/17/05) ML050750309 --

DT-42 Elena Day Public Meeting (2/17/05) ML050750309 --

DT-43 Robert Singleterry Public Meeting (2/17/05) ML050750309 --

DT-44 Terry Lilley Public Meeting (2/17/05) ML050750309 --

DT-45 Joe Montague Public Meeting (2/17/05) ML050750309 --

DT-46 Todd Flowers Public Meeting (2/17/05) ML050750309 --

DT-47 John Cruickshank Public Meeting (2/17/05) ML050750309 --

DT-48 Fred Gruber Public Meeting (2/17/05) ML050750309 --

DT-49 Kurt Flage Public Meeting (2/17/05) ML050750309 --

DT-50 Jim Adams Public Meeting (2/17/05) ML050750309 --

DT-51 Julie Curry Public Meeting (2/17/05) ML050750309 --

DT-52 NA-YGN Petition Public Meeting (2/17/05) ML050750309 --

DT-53 International Organization

petition signers

Public Meeting (2/17/05) ML050750309 --

DT-54 Darthula Romine Public Meeting (2/17/05) ML050750309 --

DT-55 Jean Bordwin Public Meeting (2/17/05) ML050750309 --

DT-56 Joanne Fisher Public Meeting (2/17/05) ML050750309 --

DT-57 Joanne Fisher Public Meeting (2/17/05) ML050750309 --

DT-58 Jeph Herrin Public Meeting (2/17/05) ML050750309 --

DT-59 Bill McLaughlin Public Meeting (2/17/05) ML050750309 --

DT-60 Roy Butler Public Meeting (2/17/05) ML050750309 --

DT-61 Jacob Hosen Public Meeting (2/17/05) ML050750309 --

DT-62 Mecca Burns Public Meeting (2/17/05) ML050750309 --

DT-63 William Small Public Meeting (2/17/05) ML050750309 --
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-35

DW-1 Jean Sideris Written comment (12/08/04) ML051390174 1

DW-2 Amanda Snyder Written comment (12/08/04) ML051390174 2

DW-3 Chandra Sigmund Written comment (12/08/04) ML051390174 3

DW-4 Dale Richard Felker Written comment (12/08/04) ML051390174 4

DW-5 Alex Balboa Written comment (12/08/04) ML051390174 5

DW-6 Robert Rutkowski Written comment (12/08/04) ML051390174 6

DW-7 Ron Richards Written comment (12/08/04) ML051390174 7

DW-8 Ryan Davis Written comment (12/08/04) ML051390174 8

DW-9 Peter Buck Written comment (12/08/04) ML051390174 9

DW-10 Stephen Dunne Written comment (12/08/04) ML051390174 10

DW-11 Kelly Riley Written comment (12/08/04) ML051390174 11

DW-12 Marilyn Williams Written comment (12/08/04) ML051390174 12

DW-13 Meaghan Patrick Written comment (12/08/04) ML051390174 13

DW-14 Ana Najera Mendoza Written comment (12/08/04) ML051390174 14

DW-15 Andrew Leonard Written comment (12/08/04) ML051390174 15

DW-16 Valerie Soza Written comment (12/08/04) ML051390174 16

DW-17 Andrew Janicki Written comment (12/08/04) ML051390174 17

DW-18 Dawn Winalski Written comment (12/08/04) ML051390174 18

DW-19 Elizabeth Field Written comment (12/08/04) ML051390174 19

DW-20 Beka Wilson Written comment (12/08/04) ML051390174 20

DW-21 Kim Burgess Written comment (12/08/04) ML051390174 21

DW-22 Stephanie Sims Written comment (12/08/04) ML051390174 22

DW-23 Nancy Spears Written comment (12/08/04) ML051390174 23

DW-24 Stewart Rosenkrantz Written comment (12/08/04) ML051390174 24

DW-25 Betty.Van Wicklen Written comment (12/08/04) ML051390174 25

DW-26 Thomas Kay Written comment (12/08/04) ML051390174 26

DW-27 Stacey Lighfoot Written comment (12/08/04) ML051390174 27

DW-28 Ed Dewitt Written comment (12/08/04) ML051390174 28

DW-29 Heidi Rood Written comment (12/08/04) ML051390174 29

DW-30 Sue Sjolin Written comment (12/08/04) ML051390174 30

DW-31 Michael Bennett Written comment (12/08/04) ML051390174 31

DW-32 KL Matlock Written comment (12/08/04) ML051390174 32

DW-33 Merrill Cole Written comment (12/08/04) ML051390174 33

DW-34 Kevin Laffey Written comment (12/08/04) ML051390174 34

DW-35 Clancey Kilcoyne Written comment (12/08/04) ML051390174 35

DW-36 Mark Johnson Written comment (12/08/04) ML051390174 36

DW-37 Lesey Bensinger Written comment (12/08/04) ML051390174 37

DW-38 Nate Beuttenmueller Written comment (12/08/04) ML051390174 38

DW-39 Kris McCradic Written comment (12/08/04) ML051390174 39

DW-40 Barbara L. Wood Written comment (12/08/04) ML051390174 40

DW-41 Kevin Vaught Written comment (12/08/04) ML051390174 41

DW-42 Steve Summers Written comment (12/08/04) ML051390174 42

DW-43 Sally Simpson Written comment (12/08/04) ML051390174 43

DW-44 Martha Leahy Written comment (12/08/04) ML051390174 44

DW-45 Martha Waltman Written comment (12/08/04) ML051390174 45

DW-46 Corina Anderson Written comment (12/08/04) ML051390174 46

DW-47 Mitchell Maness Written comment (12/08/04) ML051390174 47

DW-48 Charles Alvarez Written comment (12/08/04) ML051390174 48

DW-49 Shyla Raghav Written comment (12/08/04) ML051390174 49
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-36

DW-50 Richard Spotts Written comment (12/08/04) ML051390174 50

DW-51 Dorothea Fransson Written comment (12/08/04) ML051390174 51

DW-52 Rachel Atwood Written comment (12/08/04) ML051390174 52

DW-53 BettyJean Herner Written comment (12/08/04) ML051390174 53

DW-54 Kerry Burkhardt Written comment (12/08/04) ML051390174 54

DW-55 Beth Goldstone Written comment (12/08/04) ML051390174 55

DW-56 Marina Spitkovskaya Written comment (12/08/04) ML051390174 56

DW-57 Candace Johnson Written comment (12/08/04) ML051390174 57

DW-58 Ben Reed Written comment (12/08/04) ML051390174 58

DW-59 Kathleen Mikulski Written comment (12/08/04) ML051390174 59

DW-60 Thomas Matsuda Written comment (12/08/04) ML051390174 60

DW-61 Wanda S. Ballentine Written comment (12/08/04) ML051390174 61

DW-62 Phillip Rockey Written comment (12/08/04) ML051390174 62

DW-63 Warren Wright Written comment (12/08/04) ML051390174 63

DW-64 Neil Asselin Written comment (12/08/04) ML051390174 64

DW-65 Claire Watson Written comment (12/08/04) ML051390174 65

DW-66 Michael Mihok Written comment (12/08/04) ML051390174 66

DW-67 Sarah Kendall Written comment (12/09/04) ML051390174 67

DW-68 Barbara Singer Written comment (12/09/04) ML051390174 68

DW-69 Khaalen East Written comment (12/09/04) ML051390174 69

DW-70 Michael Evans Written comment (12/09/04) ML051390174 70

DW-71 Jane Kimbrough Written comment (12/09/04) ML051390174 71

DW-72 Ann Hardy Written comment (12/09/04) ML051390174 72

DW-73 Sandy Eichert Written comment (12/09/04) ML051390174 73

DW-74 Adrienne Moumin Written comment (12/09/04) ML051390174 74

DW-75 Kirk Rhoads Written comment (12/09/04) ML051390174 75

DW-76 Scott Phillips Written comment (12/09/04) ML051390174 76

DW-77 Roger Kempton Written comment (12/09/04) ML051390174 77

DW-78 Debbie Burack Written comment (12/09/04) ML051390174 78

DW-79 Christopher Hargrove Written comment (12/09/04) ML051390174 79

DW-80 Jamie Bown Written comment (12/09/04) ML051390174 80

DW-81 Sandra Wagner Written comment (12/09/04) ML051390174 81

DW-82 Janice Foss Written comment (12/09/04) ML051390174 82

DW-83 Judith Carlson Written comment (12/09/04) ML051390174 83

DW-84 Jerry Dalton Written comment (12/09/04) ML051390174 84

DW-85 Anthony Sanchez Written comment (12/09/04) ML051390174 85

DW-86 Michelle Palladine Written comment (12/09/04) ML051390174 86

DW-87 Dough Finkelnburg Written comment (12/09/04) ML051390174 87

DW-88 Brendan Hoffman Written comment (12/09/04) ML051390174 88

DW-89 Heidi Holeman Written comment (12/09/04) ML051390174 89

DW-90 Sheila Ward Written comment (12/09/04) ML051390174 90

DW-91 Chell D. Pfeffer Written comment (12/09/04) ML051390174 91

DW-92 Joanna F. Welch Written comment (12/09/04) ML051390174 92

DW-93 Patricia Larch Written comment (12/09/04) ML051390174 93

DW-94 Andrea Cimino Written comment (12/09/04) ML051390174 94

DW-95 Rebecca Golden Written comment (12/09/04) ML051390174 95

DW-96 Audrey Blumeenau Written comment (12/09/04) ML051390174 96

DW-97 Nina Keefer Written comment (12/09/04) ML051390174 97

DW-98 Sara Lemmon Written comment (12/09/04) ML051390174 98
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-37

DW-99 Virginia Cassidy Written comment (12/09/04) ML051390174 99

DW-100 Steve Jerbi Written comment (12/09/04) ML051390174 100

DW-101 Julio Torres Written comment (12/09/04) ML051390174 101

DW-102 Felix Aguilar Written comment (12/09/04) ML051390174 102

DW-103 Linda Harrell Written comment (12/09/04) ML051390174 103

DW-104 Ken Irwin Written comment (12/09/04) ML051390174 104

DW-105 Gregory Esteve Written comment (12/09/04) ML051390174 105

DW-106 Katarzyna Written comment (12/09/04) ML051390174 106

DW-107 Brett Feldman Written comment (12/09/04) ML051390174 107

DW-108 Jennifer Heavilin Written comment (12/09/04) ML051390174 108

DW-109 Mark Reback Written comment (12/09/04) ML051390174 109

DW-110 Chelsea Snelgrove Written comment (12/09/04) ML051390174 110

DW-111 Jeffri Frontz Written comment (12/09/04) ML051390174 111

DW-112 Linda York Written comment (12/09/04) ML051390174 112

DW-113 Linda Prostko Written comment (12/09/04) ML051390174 113

DW-114 Paxus Calta Written comment (12/10/04) ML051390174 114

DW-115 Victoria Campbell Written comment (12/10/04) ML051390174 115

DW-116 Lindsey McConnell Written comment (12/10/04) ML051390174 116

DW-117 Mary Hirose Written comment (12/10/04) ML051390174 117

DW-118 Sharon Smith Written comment (12/10/04) ML051390174 118

DW-119 Jim Head Written comment (12/10/04) ML051390174 119

DW-120 Ariel Graham Written comment (12/10/04) ML051390174 120

DW-121 Paul Williams Written comment (12/10/04) ML051390174 121

DW-122 Sarah Harris Written comment (12/10/04) ML051390174 122

DW-123 Mary Bejer Written comment (12/11/04) ML051390174 123

DW-124 Paula Jaramillo Written comment (12/10/04) ML051390174 124

DW-125 Matt Moore Written comment (12/10/04) ML051390174 125

DW-126 M. Mathewson Written comment (12/10/04) ML051390174 126

DW-127 Tom Jackson Written comment (12/10/04) ML051390174 127

DW-128 Monica Allen Written comment (12/10/04) ML051390174 128

DW-129 Bobbie Dee Flowers Written comment (12/11/04) ML051390174 129

DW-130 Mitchell Maness Written comment (12/11/04) ML051390174 130

DW-131 Sherry Barnes Written comment (12/11/04) ML051390174 131

DW-132 Colleen McGlone Written comment (12/11/04) ML051390174 132

DW-133 Tavis Schmidt Written comment (12/11/04) ML051390174 133

DW-134 Jennifer Doob Written comment (12/11/04) ML051390174 134

DW-135 Carol DeAntoni Written comment (12/11/04) ML051390174 135

DW-136 Gail McGlone Written comment (12/11/04) ML051390174 136

DW-137 Lynn Tarek Written comment (12/12/04) ML051390174 137

DW-138 Kimberley Graham Written comment (12/12/04) ML051390174 138

DW-139 Seth Silverman Written comment (12/12/04) ML051390174 139

DW-140 Wayne Kelly Written comment (12/12/04) ML051390174 140

DW-141 Michael Neil Written comment (12/12/04) ML051390174 141

DW-142 David Randall Written comment (12/12/04) ML051390174 142

DW-143 A. Patrick Written comment (12/12/04) ML051390174 143

DW-144 Diana Sette Written comment (12/12/04) ML051390174 144

DW-145 Hollis Toal Written comment (12/12/04) ML051390174 145

DW-146 Claire Watson Written comment (12/13/04) ML051390174 146

DW-147 Eve Venema Written comment (12/13/04) ML051390174 147
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-38

DW-148 Erika Shamo Written comment (12/13/04) ML051390174 148

DW-149 Katie Wolf Written comment (12/13/04) ML051390174 149

DW-150 Simone Gourguechon Written comment (12/14/04) ML051390174 150

DW-151 Sandra Carrubba Written comment (12/14/04) ML051390174 151

DW-152 Rebecca Golden Written comment (12/09/04) ML051390174 152

DW-153 Kirk Clayton Written comment (12/15/04) ML051390174 153

DW-154 Caryn Corriere Written comment (12/15/04) ML051390174 154

DW-155 Craig Willimas Written comment (12/15/04) ML051390174 155

DW-156 L. Carter Written comment (12/15/04) ML051390174 156

DW-157 Nancy Spears Written comment (12/15/04) ML051390174 157

DW-158 Michael Fish Written comment (12/15/04) ML051390174 158

DW-159 Timothy Johnston Written comment (12/16/04) ML051390174 159

DW-160 K. Zalewski Written comment (12/16/04) ML051390174 160

DW-161 Douglas Krueger Written comment (12/16/04) ML051390174 161

DW-162 Brian Hebeisen Written comment (12/19/04) ML051390174 162

DW-163 Brian Butcher Written comment (12/18/04) ML051390174 163

DW-164 Elena Day Written comment (12/28/04) ML051390174 164

DW-165 Brianne Boylan Written comment (12/22/04) ML051390174 165

DW-166 Sandra Williamson Written comment (12/26/04) ML051390174 167

DW-167 Dee Hoke Written comment (12/26/04) ML051390174 168

DW-168 Sue Franket-Streit Written comment (12/26/04) ML051390174 169

DW-169 Kerry Johnson Written comment (12/24/04) ML051390174 170

DW-170 Lauren Bouyea Written comment (12/22/04) ML051390174 171

DW-171 Jana Cutlip Written comment (12/22/04) ML051390174 172

DW-172 Bill Johnson Written comment (12/21/04) ML051390174 173

DW-173 David Williams Written comment (12/21/04) ML051390174 174

DW-174 Caryn Corriere Written comment (12/28/04) ML051390174 175

DW-175 Pete Lafoillette Written comment (12/29/04) ML051390174 176

DW-176 Kate Skolnick Written comment (12/30/04) ML051390174 177

DW-177 Linda Safley Written comment (12/30/04) ML051390174 178

DW-178 Carolyn Doswell Written comment (12/30/04) ML051390174 179

DW-179 Cheryl Costigan Written comment (01/01/05) ML051390174 180

DW-180 Cary Brief Written comment (01/04/05) ML051390174 181

DW-181 Randal and Donna Watkins Written comment (01/04/05) ML051390174 182

DW-182 Abhaya Thiele Written comment (01/05/05) ML051390174 183

DW-183 Abhaya Thiele Written comment (01/05/05) ML051390174 184

DW-184 Wendy McFadden Written comment (01/05/05) ML051390174 185

DW-185 Todd Flowers Written comment (01/06/05) ML051390174 186

DW-186 Jennifer Meyer Written comment (01/08/05) ML051390174 187

DW-187 Nazen Merjian Written comment (01/07/05) ML051390174 188

DW-188 Sarah Sherwood Litchfield Written comment (01/08/05) ML051390174 189

DW-189 Mandy Shipler Written comment (01/13/05) ML051390174 190

DW-190 Jay R. Bolon Written comment (01/11/05) ML051390174 191

DW-191 Deborah Fahrner Written comment (01/10/05) ML051390174 192

DW-192 Elena Ellis Written comment (01/11/05) ML051390174 195

DW-193 Deborah L. Bors Written comment (01/20/05) ML051390174 196

DW-194 Keith Schlesinger Written comment (01/20/05) ML051390174 197

DW-195 Gail Troy Written comment (01/18/05) ML051390174 199

DW-196 Marione M. Cobb Written comment (01/21/05) ML051390174 202
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-39

DW-197 Evelyne Noel Written comment (02/01/05) ML051390174 203

DW-198 Wanda S. Ballentine Written comment (01/14/05) ML051390174 204

DW-199 Thomas Matsuda Written comment (01/14/05) ML051390174 206

DW-200 Mark Reback Written comment (01/14/05) ML051390174 207

DW-201 Evan Albright Written comment (01/14/05) ML051390174 208

DW-202 Neil Asselin Written comment (01/14/05) ML051390174 209

DW-203 Kerry Burkhardt Written comment (01/14/05) ML051390174 210

DW-204 Kim Burgess Written comment (01/14/05) ML051390174 211

DW-205 Corina Anderson Written comment (01/14/05) ML051390174 212

DW-206 Terrace Hutchinson Written comment (01/14/05) ML051390174 213

DW-207 Sandy Eichert Written comment (01/14/05) ML051390174 214

DW-208 Michael Bennett Written comment (01/14/05) ML051390174 215

DW-209 Debbie Burack Written comment (01/14/05) ML051390174 216

DW-210 Rdolfo Holz Written comment (01/14/05) ML051390174 217

DW-211 Paul Williams Written comment (01/14/05) ML051390174 218

DW-212 Elaine Matthew Written comment (01/14/05) ML051390174 219

DW-213 Liz Fuerst Written comment (01/14/05) ML051390174 220

DW-214 Rebecca Louis Written comment (01/14/05) ML051390174 221

DW-215 Meaghan Patrick Written comment (01/14/05) ML051390174 222

DW-216 Victoria Campbell Written comment (01/14/05) ML051390174 223

DW-217 Renee Duprey Written comment (01/14/05) ML051390174 224

DW-218 David Cook, Jr. Written comment (01/14/05) ML051390174 225

DW-219 Francisco Maya Written comment (01/14/05) ML051390174 226

DW-220 Robert Seltzer Written comment (01/14/05) ML051390174 227

DW-221 Sarah Kendall Written comment (01/14/05) ML051390174 228

DW-222 Sarah Pope Written comment (01/14/05) ML051390174 229

DW-223 Linda Schweppe Written comment (01/14/05) ML051390174 230

DW-224 Kim Brooks Written comment (01/14/05) ML051390174 231

DW-225 Barbara L. Wood Written comment (01/14/05) ML051390174 232

DW-226 Jason J. Green Written comment (01/14/05) ML051390174 233

DW-227 Audrey Blumeenau Written comment (01/14/05) ML051390174 234

DW-228 Joanna F. Welch Written comment (01/14/05) ML051390174 235

DW-229 Ron Richards Written comment (01/14/05) ML051390174 236

DW-230 Stewart Rosenkrantz Written comment (01/14/05) ML051390174 237

DW-231 Steve Summers Written comment (01/14/05) ML051390174 238

DW-232 Michael Mihok Written comment (01/14/05) ML051390174 239

DW-233 Nancy Gathing Written comment (01/14/05) ML051390174 240

DW-234 Felix Aguilar Written comment (01/14/05) ML051390174 241

DW-235 Charles Alvarez Written comment (01/14/05) ML051390174 242

DW-236 Marlene Stanley Written comment (01/14/05) ML051390174 243

DW-237 Martha Waltman Written comment (01/14/05) ML051390174 244

DW-238 Tom Jackson Written comment (01/14/05) ML051390174 245

DW-239 Kevin Vaught Written comment (01/14/05) ML051390174 246

DW-240 Kelly Riley Written comment (01/14/05) ML051390174 247

DW-241 Michael Evans Written comment (01/14/05) ML051390174 248

DW-242 Richard H. Williams Written comment (01/14/05) ML051390174 249

DW-243 Richard Spotts Written comment (01/14/05) ML051390174 250

DW-244 Jason Trew Written comment (01/14/05) ML051390174 251

DW-245 Amber Crooks Written comment (01/14/05) ML051390174 252
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-40

DW-246 Christopher Meder Written comment (01/14/05) ML051390174 253

DW-247 Laura Walters Written comment (01/14/05) ML051390174 254

DW-248 Jon Roberts Written comment (01/14/05) ML051390174 255

DW-249 Jesse Gore Written comment (01/14/05) ML051390174 256

DW-250 Kirk Rhoads Written comment (01/14/05) ML051390174 257

DW-251 Paula Stober Written comment (01/14/05) ML051390174 258

DW-252 Alex Balboa Written comment (01/14/05) ML051390174 259

DW-253 Bill LaFleur Written comment (01/14/05) ML051390174 260

DW-254 Craig Williams Written comment (01/14/05) ML051390174 26

DW-255 Timothy Johnston Written comment (01/18/05) ML051390174 262

DW-256 Ferris Kawar Written comment (01/18/05) ML051390174 263

DW-257 John Golembieski Written comment (01/18/05) ML051390174 264

DW-258 Roger Kempton Written comment (01/18/05) ML051390174 265

DW-259 Scot Phillips Written comment (01/18/05) ML051390174 266

DW-260 Vicki Johnson Written comment (01/18/05) ML051390174 267

DW-261 Adrienne Moumin Written comment (01/18/05) ML051390174 268

DW-262 Peggy Conroy Written comment (01/18/05) ML051390174 269

DW-263 John Mark Roberton Written comment (01/18/05) ML051390174 270

DW-264 Michelle Palladine Written comment (01/18/05) ML051390174 271

DW-265 Caroline Pott Written comment (01/18/05) ML051390174 272

DW-266 Merrill Cole Written comment (01/18/05) ML051390174 273

DW-267 Sally Simpson Written comment (01/18/05) ML051390174 274

DW-268 Claire Watson Written comment (01/18/05) ML051390174 275

DW-269 Dale Krewson Written comment (01/18/05) ML051390174 276

DW-270 Chelsea Snelgrove Written comment (01/18/05) ML051390174 277

DW-271 Warren Wright Written comment (01/18/05) ML051390174 278

DW-272 Shyla Raghav Written comment (01/18/05) ML051390174 279

DW-273 Jane Kimbrough Written comment (01/18/05) ML051390174 280

DW-274 Dan Brook Written comment (01/18/05) ML051390174 281

DW-275 David Wilcox Written comment (01/18/05) ML051390174 282

DW-276 Valerie Soza Written comment (01/18/05) ML051390174 283

DW-277 Adrienne Hohenberg Written comment (01/18/05) ML051390174 284

DW-278 Brenda Barnhart Written comment (01/14/05) ML051390174 285

DW-279 Dinda Evans Written comment (01/14/05) ML051390174 286

DW-280 Monica Allen Written comment (01/14/05) ML051390174 287

DW-281 Stephanie Sims Written comment (01/14/05) ML051390174 288

DW-282 Chad Derosier Written comment (01/14/05) ML051390174 289

DW-283 Martha Leahy Written comment (01/14/05) ML051390174 290

DW-284 Stacey Lightfoot Written comment (01/14/05) ML051390174 291

DW-285 Barbara Arcure Written comment (01/14/05) ML051390174 292

DW-286 Carmen Rico Written comment (01/14/05) ML051390174 293

DW-287 Nancy Spears Written comment (01/14/05) ML051390174 294

DW-288 Diba Khan-Bureau Written comment (01/14/05) ML051390174 295

DW-289 David Burkhart Written comment (01/14/05) ML051390174 296

DW-290 Ryan Davis Written comment (01/14/05) ML051390174 297

DW-291 Brett Feldman Written comment (01/14/05) ML051390174 298

DW-292 Elizabeth McAnally Written comment (01/14/05) ML051390174 299

DW-293 Brandi Gartland Written comment (01/14/05) ML051390174 300

DW-294 Sarah Harris Written comment (01/14/05) ML051390174 301
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-41

DW-295 Erika Shamo Written comment (01/14/05) ML051390174 302

DW-296 Laura Herndon Written comment (01/14/05) ML051390174 303

DW-297 Douglas Krueger Written comment (01/14/05) ML051390174 304

DW-298 Gerald Dalton Written comment (01/14/05) ML051390174 305

DW-299 Katarzyna Written comment (01/14/05) ML051390174 306

DW-300 Peggy Phan, Written comment (01/14/05) ML051390174 307

DW-301 Mary H. Woodward Written comment (01/14/05) ML051390174 308

DW-302 Judith Shematek Written comment (01/14/05) ML051390174 309

DW-303 Antje Adams Written comment (01/14/05) ML051390174 310

DW-304 Janice Foss Written comment (01/14/05) ML051390174 311

DW-305 Barney McComas Written comment (01/18/05) ML051390174 312

DW-306 Helen Kopp Written comment (01/18/05) ML051390174 313

DW-307 Colleen McGlone Written comment (01/18/05) ML051390174 314

DW-308 Jennifer Heavilin Written comment (01/18/05) ML051390174 315

DW-309 Robert Fener Written comment (02/02/05) ML051390174 316

DW-310 Saron Smith Written comment (01/18/05) ML051390174 317

DW-311 Janet Fotos Written comment (01/18/05) ML051390174 318

DW-312 Gree Bessette Written comment (01/18/05) ML051390174 319

DW-313 John Ingle Written comment (01/18/05) ML051390174 320

DW-314 Gina Boltz Written comment (01/18/05) ML051390174 321

DW-315 Shaun Smakal Written comment (01/18/05) ML051390174 322

DW-316 A. Patrick Written comment (01/18/05) ML051390174 323

DW-317 Susanna Blunt Written comment (01/18/05) ML051390174 324

DW-318 Domelza Costa Written comment (01/18/05) ML051390174 325

DW-319 Rebecca Schild Written comment (01/18/05) ML051390174 326

DW-320 David Fairman Written comment (01/18/05) ML051390174 327

DW-321 Ray Bell Written comment (01/18/05) ML051390174 328

DW-322 Sheila Ward Written comment (01/18/05) ML051390174 329

DW-323 Candace Johnson Written comment (01/18/05) ML051390174 330

DW-324 Keegan Roberson Written comment (01/18/05) ML051390174 331

DW-325 Matthew Tiffault Written comment (01/18/05) ML051390174 332

DW-326 James Facette Written comment (01/18/05) ML051390174 333

DW-327 Adrienne Moumin Written comment (01/18/05) ML051390174 334

DW-328 Kevin Laffey Written comment (01/18/05) ML051390174 335

DW-329 Sherry Salomon Written comment (01/18/05) ML051390174 336

DW-330 Amy Wilson Written comment (01/18/05) ML051390174 337

DW-331 Connor Petren Written comment (01/18/05) ML051390174 338

DW-332 Carlon Ribbins Written comment (01/18/05) ML051390174 339

DW-333 Donna Cassano Written comment (01/18/05) ML051390174 340

DW-334 Kristina Weller Written comment (01/18/05) ML051390174 341

DW-335 Matt Moore Written comment (01/18/05) ML051390174 342

DW-336 Marina Spitkovskaya Written comment (01/18/05) ML051390174 343

DW-337 Dorothea Fransson Written comment (01/18/05) ML051390174 344

DW-338 Cheryl Rosenfeld Written comment (01/18/05) ML051390174 345

DW-339 Stephen Calkins Written comment (01/18/05) ML051390174 346

DW-340 Ben Reed Written comment (01/18/05) ML051390174 347

DW-341 Paul Schneller Written comment (01/18/05) ML051390174 348

DW-342 Maritza Santana Written comment (01/18/05) ML051390174 349

DW-343 Bobbie Dee Flowers Written comment (01/18/05) ML051390174 350
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-42

DW-344 Ken Irwin Written comment (01/18/05) ML051390174 351

DW-345 Lisa Butch Written comment (01/18/05) ML051390174 352

DW-346 Seth Silverman Written comment (01/18/05) ML051390174 353

DW-347 Alma Evans Written comment (01/18/05) ML051390174 354

DW-348 Nicole Totino Written comment (01/18/05) ML051390174 355

DW-349 Kathy Mikulski Written comment (01/18/05) ML051390174 356

DW-350 Ned Fongemie Written comment (01/18/05) ML051390174 357

DW-351 Gregory Esteve Written comment (01/18/05) ML051390174 358

DW-352 Eric Mens Written comment (01/18/05) ML051390174 359

DW-353 M. Esseltine Written comment (01/18/05) ML051390174 360

DW-354 Virginia Cassidy Written comment (01/18/05) ML051390174 361

DW-355 Khaalen East Written comment (01/18/05) ML051390174 362

DW-356 Sharon Pederslie Written comment (01/18/05) ML051390174 363

DW-357 Kelly Schneider Written comment (01/18/05) ML051390174 364

DW-358 Charlotte Lundemo Written comment (01/18/05) ML051390174 365

DW-359 Andrew Janicki Written comment (01/18/05) ML051390174 366

DW-360 Robert Singleterry Written comment (01/18/05) ML051390174 367

DW-361 Rene Horst Written comment (01/18/05) ML051390174 369

DW-362 Ariela Friedman Written comment (01/18/05) ML051390174 370

DW-363 Nina Keefer Written comment (01/18/05) ML051390174 371

DW-364 Alva Pick Written comment (01/18/05) ML051390174 372

DW-365 Mitchell Hunt Written comment (01/18/05) ML051390174 373

DW-366 Gail McGlone Written comment (01/18/05) ML051390174 374

DW-367 RaVani Flood Written comment (01/18/05) ML051390174 375

DW-368 Richard Pasichnyk Written comment (01/18/05) ML051390174 376

DW-369 Victoria Bonsignore Written comment (01/18/05) ML051390174 377

DW-370 Bill Wilson Written comment (01/18/05) ML051390174 378

DW-371 Eric Indermuehle Written comment (01/18/05) ML051390174 379

DW-372 Mike Garnet Written comment (01/18/05) ML051390174 380

DW-373 Kris Unger Written comment (01/18/05) ML051390174 381

DW-374 Thomas Kay Written comment (01/18/05) ML051390174 382

DW-375 Wayne Kelly Written comment (01/19/05) ML051390174 383

DW-376 Nida Sun Written comment (01/19/05) ML051390174 384

DW-377 Patrick Costello Written comment (01/19/05) ML051390174 385

DW-378 Claire Kaplan Written comment (01/19/05) ML051390174 386

DW-379 Carl Brackett Written comment (01/19/05) ML051390174 387

DW-380 Rachana Bhatia Written comment (01/18/05) ML051390174 388

DW-381 Sara Van Buren Written comment (01/18/05) ML051390174 389

DW-382 Dale Richard Felker Written comment (01/18/05) ML051390174 390

DW-383 Marliss Rogers Written comment (01/18/05) ML051390174 391

DW-384 Sandra Carrubba Written comment (01/18/05) ML051390174 392

DW-385 Cheryl Costigan Written comment (01/18/05) ML051390174 393

DW-386 Mary E. McGilligan Written comment (01/18/05) ML051390174 394

DW-387 Andrea Cimino Written comment (01/18/05) ML051390174 395

DW-388 Mary Hirose Written comment (01/18/05) ML051390174 396

DW-389 Rebecca Hamil Written comment (01/18/05) ML051390174 397

DW-390 Kelly Korenak Written comment (01/18/05) ML051390174 398

DW-391 Emily Rieber Written comment (01/18/05) ML051390174 399

DW-392 Brian Butcher Written comment (01/18/05) ML051390174 400
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-43

DW-393 Nicole Allard Written comment (01/18/05) ML051390174 401

DW-394 Ariel Graham Written comment (01/18/05) ML051390174 402

DW-395 Mitchell Maness Written comment (01/18/05) ML051390174 403

DW-396 Steven Heinitz Written comment (01/18/05) ML051390174 404

DW-397 Lauren J. Agreela Written comment (02/09/05) ML051390174 405

DW-398 Nancy Campbell Written comment (02/06/05) ML051390174 406

DW-399 Richard L. Geddes Written comment (02/07/05) ML051390174 407

DW-400 Kenneth Remmers,

Waterside Property Owners

of Lake Anna

Written comment (01/19/05) ML051390174 411

DW-401 Kristin Taverna Written comment (02/17/05) ML051390174 415

DW-402 Elaine Shaw Written comment (02/09/05) ML051390174 416

DW-403 David R. Herring Written comment (02/10/05) ML051390174 418

DW-404 Maggie Written comment (02/16/05) ML051390174 420

DW-405 Evelyne Noel Written comment (02/01/05) ML051390174 425

DW-406 Robert Stumm Written comment (02/14/05) ML051390174 426

DW-407 Cathy Douthit Written comment (02/13/05) ML051390174 427

DW-408 Thomas Alex Davis Written comment (02/25/05) ML051390174 428

DW-409 Ken Bezilla Written comment (02/17/05) ML051390174 429

DW-410 Virginia Rovnyak Written comment (02/18/05) ML051390174 430

DW-411 Marion McDonald Written comment (02/17/05) ML051390174 441

DW-412 Robert Rexroat Written comment (02/20/05) ML051390174 443

DW-413 Shelly and Sid Sitzer Written comment (02/17/05) ML051390174 444

DW-414 Eleanor Amidon Written comment (02/22/05) ML051390174 445

DW-415 Priya Curtis Written comment (02/22/05) ML051390174 446

DW-416 Robert Pedde, President,

Westinghouse Savannah

River Co.

Written comment (02/15/05) ML051390174 447

DW-417 Sama Bilbao y Leon Written comment (02/24/05) ML051390174 458

DW-418 Joseph Pipik Written comment (02/23/05) ML051390174 465

DW-419 Darren Pace and Aaron

Eichorst

Written comment (02/23/05) ML051390174 467

DW-420 Mary Jane Gore Written comment (02/15/05) ML051390174 469

DW-421 Virginia B. Jordan Written comment (02/24/05) ML051390174 471

DW-422 William Arguto, U.S.

Environmental Protection

Agency

Written comment (03/01/05) ML051390174 472

DW-423 Eugene S. Grecheck,

Dominion Nuclear North

Anna, LLC 

Written comment (03/01/05) ML051390174 476

DW-424 Pete Marshall, Leah

Marshall, and Miriam Picus

Written comment (02/26/05) ML051390179 496

DW-425 Anne McGurk Written comment (02/24/05) ML051390179 498

DW-426 Lena Lewis Written comment (02/24/05) ML051390179 499

DW-427 H. Paul Bigler Written comment (02/26/05) ML051390179 501

DW-428 Sherley Redding Written comment (02/25/05) ML051390179 502

DW-429 William G. Tresky Written comment (02/19/05) ML051390179 503

DW-430 Robert Rexroat Written comment (02/20/05) ML051390179 504

DW-431 Virginia M. Thull Written comment (02/26/05) ML051390179 505
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-44

DW-432 Donna Pienkowski Written comment (02/21/05) ML051390179 506

DW-433 Shelly Sitzer Written comment (02/21/05) ML051390179 507

DW-434 Anna Fitzgerald Written comment (03/01/05) ML051390179 509

DW-435 Adrian P. Heymer, Nuclear

Energy Institute (NEI)

Written comment (03/01/05) ML051390179 511

DW-436 David Lenehan Written comment (023/02/05) ML051390179 522

DW-437 Michele Boyd, Public Citizen Written comment (03/01/05) ML051390179 523

DW-438 Aviv Goldsmith Written comment (02/25/05) ML051390179 537

DW-439 Ellie L. Irons, Commonwealth

of Virginia, Office of

Environmental Impact

Review

Written comment (03/03/05) ML051390179 555

DW-440 Ingrid Turner Written comment (02/22/05) ML051390179 601

DW-441 Richard L. Geddes Written comment (02/23/05) ML051390179 602

DW-442 Leo Fanning Written comment (02/25/05) ML051390179 606

DW-443 Richard L. Geddes Written comment (02/26/05) ML051390179 607

DW-444 Lawrence Gross, Battlefields

Sierra 

Written comment (02/28/05) ML051390179 611

DW-445 J. R. Feagin Written comment (02/28/05) ML051390179 614

DW-446 Paul Stenbjorn Written comment (02/25/05) ML051390179 615

DW-447 Arthur Schmidt Written comment (02/26/05) ML051390179 616

DW-448 William Richards Written comment (02/26/05) ML051390179 617

DW-449 Patricia Eichenberger Written comment (02/26/05) ML051390179 618

DW-450 Kevin Chaney Written comment (02/26/05) ML051390179 619

DW-451 Silja Sistok-Katz Written comment (02/26/05) ML051390179 620

DW-452 Loralee Clark Written comment (02/26/05) ML051390179 621

DW-453 Anne Bloomburg Written comment (02/26/05) ML051390179 624

DW-454 Diana Parker Written comment (02/26/05) ML051390179 627

DW-455 Dorothy Laverdiere Written comment (02/26/05) ML051390179 628

DW-456 Katrina Von Briesen Written comment (02/26/05) ML051390179 629

DW-457 Sarah Hepler Written comment (02/26/05) ML051390179 632

DW-458 Lawrence Pierce Written comment (02/26/05) ML051390179 633

DW-459 Anne McGurk Written comment (02/26/05) ML051390179 634

DW-460 Pamela Kim Written comment (02/26/05) ML051390179 637

DW-461 Rhea Baldino Written comment (02/26/05) ML051390179 638

DW-462 Rachel Bobbitt Written comment (02/26/05) ML051390179 639

DW-463 Audrey Clement Written comment (02/26/05) ML051390179 642

DW-464 Tom Dennison Written comment (02/26/05) ML051390179 645

DW-465 James Masters Written comment (02/26/05) ML051390179 648

DW-466 Liz Palmer Written comment (02/26/05) ML051390179 649

DW-467 Margaret Gilges Written comment (02/26/05) ML051390179 652

DW-468 Christian Sund Written comment (02/26/05) ML051390179 655

DW-469 Cheryl Weber Written comment (02/26/05) ML051390179 656

DW-470 Joseph Anthony Written comment (02/26/05) ML051390179 659

DW-471 Carl Avers Written comment (02/26/05) ML051390179 660

DW-472 Kimberly Moreno Written comment (02/26/05) ML051390179 661

DW-473 Stephen Mills Written comment (02/26/05) ML051390179 664

DW-474 Michelle Acton Written comment (02/26/05) ML051390179 665
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-45

DW-475 David Campbell Written comment (02/26/05) ML051390179 666

DW-476 Judith Ostrowski Written comment (02/26/05) ML051390179 667

DW-477 Susan Davis Written comment (02/26/05) ML051390179 670

DW-478 Lori C Written comment (02/26/05) ML050770019 671

DW-479 Jonathan Lotz Written comment (02/26/05) ML051390179 672

DW-480 Anne Jameson Written comment (02/26/05) ML051390179 673

DW-481 Stephen Anderson Written comment (02/26/05) ML051390179 674

DW-482 Louise Mann Written comment (02/26/05) ML051390179 675

DW-483 Kathy Joseph Written comment (02/26/05) ML051390179 676

DW-484 Ron Sokol Written comment (02/26/05) ML051390179 677

DW-485 Lisa Marshall Written comment (02/26/05) ML051390179 680

DW-486 Margaret Meister Written comment (02/26/05) ML051390179 681

DW-487 Barbara Martin Written comment (02/26/05) ML051390179 682

DW-488 Cornelia Lewis Written comment (02/26/05) ML051390179 683

DW-489 Linda Hanson Written comment (02/26/05) ML051390179 684

DW-490 Fletcher Collins Written comment (02/26/05) ML051390179 685

DW-491 Nicole Mettler Written comment (02/26/05) ML051390179 686

DW-492 Jacqueline Bowman Written comment (02/26/05) ML051390179 689

DW-493 Nancy Re Written comment (02/26/05) ML051390179 690

DW-494 Lilli Hoffman Written comment (02/26/05) ML051390179 691

DW-495 Martha Desrosiers Written comment (02/26/05) ML051390179 692

DW-496 Carol Rose Written comment (02/25/05) ML051390179 693

DW-497 Zaahira Wyne Written comment (02/25/05) ML051390179 694

DW-498 Darlene Coleman Written comment (02/25/05) ML051390179 697

DW-499 Donna Wellman Written comment (02/25/05) ML051390179 698

DW-500 Judy Popelas Written comment (02/25/05) ML051390179 699

DW-501 Judith Shematek Written comment (02/25/05) ML051390179 702

DW-502 Ross Feitlinger Written comment (02/25/05) ML051390179 703

DW-503 Chris Nicholas Written comment (02/25/05) ML051390179 704

DW-504 Keith Croghan Written comment (02/25/05) ML051390179 705

DW-505 Matthew Campbell Written comment (02/25/05) ML051390179 708

DW-506 Rosemarie Sawdon Written comment (02/25/05) ML051390179 709

DW-507 Aislynn Raymond Written comment (02/25/05) ML051390179 712

DW-508 Katherine Morgan Written comment (02/25/05) ML051390179 715

DW-509 Fred Lavy Written comment (02/25/05) ML051390179 716

DW-510 Tyla Matteson Written comment (02/25/05) ML051390179 717

DW-511 Martin Albert Written comment (02/25/05) ML051390179 720

DW-512 Ariele Foster Written comment (02/25/05) ML051390179 721

DW-513 Mark Reif Written comment (02/26/05) ML051390179 722

DW-514 Pat Dietch Written comment (02/26/05) ML051390179 723

DW-515 James Wilcox Written comment (02/26/05) ML051390179 724

DW-516 Robbin Knapp Written comment (02/26/05) ML051390179 725

DW-517 Joe Cecil Written comment (02/26/05) ML051390179 726

DW-518 Disamodha Amarasinghe Written comment (02/26/05) ML051390179 727

DW-519 Robert Rapice Written comment (02/26/05) ML051390179 730

DW-520 Mary Hodge Written comment (02/26/05) ML051390179 731

DW-521 Karla Alfano Written comment (02/26/05) ML051390179 732

DW-522 Carrie Bell Written comment (02/26/05) ML051390179 733

DW-523 Jason Shawn Written comment (02/26/05) ML051390179 734
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-46

DW-524 Janet Collins Written comment (02/26/05) ML051390179 735

DW-525 Kelly Snyder Written comment (02/26/05) ML051390179 736

DW-526 Karin Doggett Written comment (02/26/05) ML051390179 737

DW-527 Kenneth Campbell Written comment (02/26/05) ML051390179 738

DW-528 Bob Pechman Written comment (02/26/05) ML051390179 739

DW-529 Kenneth Campbell Written comment (02/26/05) ML051390179 742

DW-530 Jamsin Merida Written comment (02/26/05) ML051390179 745

DW-531 Kevin Blythe Written comment (02/26/05) ML051390179 748

DW-532 Yvonne Garcia Written comment (02/26/05) ML051390179 751

DW-533 Christina Copeland Written comment (02/26/05) ML051390179 752

DW-534 Constantina Economou Written comment (02/26/05) ML051390179 755

DW-535 Andrea B. Krochalis Written comment (02/26/05) ML051390179 756

DW-536 Thuy-Vy Bui Written comment (02/26/05) ML051390179 757

DW-537 Nancy Adamson Written comment (02/26/05) ML051390179 758

DW-538 David Mitchell Written comment (02/26/05) ML051390179 759

DW-539 Jason Trew Written comment (02/26/05) ML051390179 760

DW-540 David Bokel Written comment (02/26/05) ML051390179 761

DW-541 Gina Hayes Written comment (02/26/05) ML051390179 764

DW-542 Lynn Adams Written comment (02/26/05) ML051390179 765

DW-543 Jared Wetherington Written comment (02/26/05) ML051390179 766

DW-544 Gregory Doggett Written comment (02/26/05) ML051390179 767

DW-545 Ricky Grubb Written comment (02/27/05) ML051390179 768

DW-546 Elizabeth Harshaw Written comment (02/27/05) ML051390179 769

DW-547 Misha Fredericks Written comment (02/27/05) ML051390179 770

DW-548 Laura Poisson Written comment (02/27/05) ML051390179 771

DW-549 Joe McCloskey Written comment (02/27/05) ML051390179 772

DW-550 Gary Stoner Written comment (02/27/05) ML051390179 775

DW-551 Roberto Perez Written comment (02/27/05) ML051390179 776

DW-552 Sarah Knorr Written comment (02/27/05) ML051390179 777

DW-553 John Sexson Written comment (02/27/05) ML051390179 778

DW-554 Heather Martin Written comment (02/27/05) ML051390179 779

DW-555 Richard Sloan Written comment (02/27/05) ML051390179 782

DW-556 Elizabeth Barger Written comment (02/27/05) ML051390179 783

DW-557 Sarah Gillespie Written comment (02/27/05) ML051390179 784

DW-558 Shaun Mooney Written comment (02/27/05) ML051390179 785

DW-559 Shaun Mooney Written comment (02/27/05) ML051390179 788

DW-560 Dan Bodnaruk Written comment (02/27/05) ML051390179 789

DW-561 Lisa Fues Written comment (02/27/05) ML051390179 790

DW-562 Diane Clark Written comment (02/27/05) ML051390179 793

DW-563 Lorah East Written comment (02/27/05) ML051390179 796

DW-564 Donna Pienkowski Written comment (02/27/05) ML051390179 797

DW-565 Stasi York Written comment (02/27/05) ML051390179 799

DW-566 Joel Cox Written comment (02/27/05) ML051390179 800

DW-567 Susan Johnson Written comment (02/27/05) ML051390179 801

DW-568 Chrissie Lozano Written comment (02/27/05) ML051390179 802

DW-569 Jamie King Written comment (02/27/05) ML051390179 805

DW-570 Mary Gorka Written comment (02/27/05) ML051390179 808

DW-571 Charles Kern Written comment (02/27/05) ML051390179 809

DW-572 James Conroy Written comment (02/27/05) ML051390179 812
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-47

DW-573 Kirk Butler Written comment (02/27/05) ML051390179 813

DW-574 Probyn Gregory Written comment (02/27/05) ML051390179 814

DW-575 Nancy Carpenter Written comment (02/27/05) ML051390179 815

DW-576 Ivy Main Written comment (02/27/05) ML051390179 818

DW-577 Mark Lackey Written comment (02/27/05) ML051390179 819

DW-578 Lauren Jones Written comment (02/27/05) ML051390179 820

DW-579 Jay Howard Written comment (02/27/05) ML051390179 821

DW-580 Scott Blossom Written comment (02/27/05) ML051390179 824

DW-581 Holly Hendrickson Written comment (02/27/05) ML051390179 827

DW-582 Jennifer Davis Written comment (02/27/05) ML051390179 830

DW-583 Gene Smith Written comment (02/27/05) ML051390179 833

DW-584 Robert Cannon Written comment (02/27/05) ML051390179 834

DW-585 Devan Malore Written comment (02/27/05) ML051390179 837

DW-586 Kristie Hersey Written comment (02/27/05) ML051390179 838

DW-587 Ken Langslow Written comment (02/27/05) ML051390179 841

DW-588 Jennifer Bryant Written comment (02/27/05) ML051390179 842

DW-589 Richard H. Ball Written comment (02/28/05) ML051390179 845

DW-590 Andrew Presgraves Written comment (02/28/05) ML051390179 851

DW-591 Margaret Roach Written comment (02/28/05) ML051390179 852

DW-592 Kevin Smith Written comment (02/28/05) ML051390179 853

DW-593 Douglas Stewart Written comment (02/28/05) ML051390179 854

DW-594 Larry Gross Written comment (02/28/05) ML051390179 855

DW-595 Andrew Town Written comment (02/28/05) ML051390179 858

DW-596 Allison Morris Written comment (02/28/05) ML051390179 859

DW-597 John Shea Written comment (02/28/05) ML051390179 862

DW-598 Alicia Hans Written comment (02/28/05) ML051390179 863

DW-599 James Parker Written comment (02/28/05) ML051390179 864

DW-600 Kat Katsos Written comment (02/28/05) ML051390179 865

DW-601 Liz Ehrich Written comment (02/28/05) ML051390179 866

DW-602 Ruth Kaufman Written comment (02/28/05) ML051390179 869

DW-603 Anjali Athavale Written comment (02/28/05) ML051390179 872

DW-604 Mary Lawrence Written comment (02/28/05) ML051390179 873

DW-605 Teresa Dawson Written comment (02/28/05) ML051390179 876

DW-606 Annette May Written comment (02/28/05) ML051390179 879

DW-607 Tim Shank Written comment (02/28/05) ML051390179 880

DW-608 Ken Willis Written comment (02/28/05) ML051390179 881

DW-609 Robyn Erickson Written comment (02/28/05) ML051390179 884

DW-610 Brenda Wiley Written comment (02/28/05) ML051390179 885

DW-611 Kathy Day Written comment (02/28/05) ML051390179 886

DW-612 Margaret Breslau Written comment (02/28/05) ML051390179 887

DW-613 Judith Shematek Written comment (02/28/05) ML051390179 890

DW-614 Rena Martin-Errick Written comment (02/28/05) ML051390179 893

DW-615 Joshua Rellick Written comment (02/28/05) ML051390179 896

DW-616 Eric Borgersen Written comment (02/28/05) ML051390179 899

DW-617 Matthew Freeman Written comment (02/28/05) ML051390179 900

DW-618 Joseph Anthony Written comment (02/28/05) ML051390179 902

DW-619 Lee Archard Written comment (02/28/05) ML051390179 905

DW-620 Katherine Morgan Written comment (02/28/05) ML051390179 906

DW-621 Jem Stone Written comment (02/28/05) ML051390179 909
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-48

DW-622 Andrew Kalukin Written comment (02/28/05) ML051390179 912

DW-623 Bryan L. Wagoner Written comment (02/28/05) ML051390179 913

DW-624 Carlton Apperson Written comment (02/28/05) ML051390179 914

DW-625 Sarah Gillespie Written comment (02/28/05) ML051390179 915

DW-626 Sherelle Jackson Written comment (02/28/05) ML051390179 918

DW-627 Keith Baldwin Written comment (02/28/05) ML051390179 919

DW-628 Mark Elliott Written comment (02/28/05) ML051390179 920

DW-629 Robin Watkins Written comment (02/28/05) ML051390179 921

DW-630 Sarah Craig Freeman Written comment (02/28/05) ML051390179 922

DW-631 Denise Shreeve Written comment (02/28/05) ML051390179 926

DW-632 Conway Moy Written comment (02/28/05) ML051390179 929

DW-633 Anne Mickel Written comment (02/28/05) ML051390179 932

DW-634 Letitia Johnson Written comment (02/28/05) ML051390179 935

DW-635 Leonardo Sarli Written comment (02/28/05) ML051390179 936

DW-636 Don Jeffries Written comment (02/28/05) ML051390179 937

DW-637 Robert MacDowell Written comment (02/28/05) ML051390179 938

DW-638 Phil Hearne Written comment (02/28/05) ML051390179 941

DW-639 Beth Craig Written comment (02/28/05) ML051390179 944

DW-640 Brian Deasy Written comment (02/28/05) ML051390179 947

DW-641 Rosemarie Sawdon Written comment (02/28/05) ML051390179 948

DW-642 Doris Whitfield Written comment (02/28/05) ML051390179 950

DW-643 Gretchen Biernot Written comment (02/28/05) ML051390179 953

DW-644 Rachel Page Written comment (02/28/05) ML051390179 954

DW-645 Dwight Baker Written comment (02/28/05) ML051390179 957

DW-646 Heather Strachan Written comment (02/28/05) ML051390179 959

DW-647 Sarah Byrne Written comment (02/28/05) ML051390179 962

DW-648 C. R. Farley Written comment (02/28/05) ML051390179 963

DW-649 Aviv Goldsmith Written comment (02/28/05) ML051390179 965

DW-650 Ellen Anderson Written comment (02/28/05) ML051390185 985

DW-651 Nancy Asman Written comment (02/28/05) ML051390185 988

DW-652 Rosemarie Sawdon Written comment (02/28/05) ML051390185 989

DW-653 Jean E. Hiatt Written comment (02/28/05) ML051390185 990

DW-654 Christine Gyovia Written comment (02/28/05) ML051390185 991

DW-655 Stephen Dell’Aria Written comment (02/28/05) ML051390185 992

DW-656 Reed Muehlman Written comment (02/28/05) ML051390185 995

DW-657 Donna Phillips Written comment (02/28/05) ML051390185 996

DW-658 Cassie Jurasits Written comment (02/28/05) ML051390185 999

DW-659 Katrina Cox Written comment (02/28/05) ML051390185 1000

DW-660 Jay Kardan Written comment (03/01/05) ML051390185 1001

DW-661 Jean Jearman Written comment (03/01/05) ML051390185 1002

DW-662 Mary Ann McFarland Written comment (03/01/05) ML051390185 1005

DW-663 Brian Gallagher Written comment (03/01/05) ML051390185 1006

DW-664 Lauren Leake Written comment (03/01/05) ML051390185 1007

DW-665 Lisa Osborn Written comment (03/01/05) ML051390185 1010

DW-666 Tisha McMillan Written comment (03/01/05) ML051390185 1013

DW-667 Laura East Written comment (03/01/05) ML051390185 1014

DW-668 Scott Peterson, NEI Written comment (03/01/05) ML051390185 1017

DW-669 Adele Wood Written comment (03/01/05) ML051390185 1021

DW-670 Jamie Simo Written comment (03/01/05) ML051390185 1022
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-49

DW-671 Michaelene Pederson Written comment (03/01/05) ML051390185 1024

DW-672 Della Cleve Written comment (03/01/05) ML051390185 1025

DW-673 Beth Clark Written comment (03/01/05) ML051390185 1028

DW-674 Scheherazade FolleyRegustersWritten comment (03/01/05) ML051390185 1029

DW-675 Marcia Fairman Written comment (03/01/05) ML051390185 1032

DW-676 Pablo Thomason Written comment (03/01/05) ML051390185 1035

DW-677 Vince Newton Written comment (03/01/05) ML051390185 1038

DW-678 Robyn Good Written comment (02/28/05) ML051390185 1041

DW-679 Lee Mitchell Written comment (02/28/05) ML051390185 1044

DW-680 Toni Jackson Written comment (02/28/05) ML051390185 1047

DW-681 Marcia Dickinson Written comment (02/28/05) ML051390185 1050

DW-682 Mr. and Mrs. John Silver Written comment (02/28/05) ML051390185 1053

DW-683 Kathy Dammarell Written comment (02/28/05) ML051390185 1056

DW-684 Helen Sanders Written comment (02/28/05) ML051390185 1057

DW-685 James A. Bryan Written comment (03/01/05) ML051390185 1060

DW-686 Michele Boyd and Joseph P.

Malherek, Public Citizen

Written comment (03/01/05) ML051390185 1069

DW-687 Heather Taplin Written comment (03/07/05) ML051390185 1084

DW-688 Jose Maria Olmos Written comment (03/07/05) ML051390185 1085

DW-689 Ruth Miller Written comment (03/06/05) ML051390185 1086

DW-690 Jim and Kim Ackerman Written comment (03/06/05) ML051390185 1087

DW-691 Roselind Heinekamp Written comment (03/06/05) ML051390185 1088

DW-692 Kerry Schindl Written comment (03/06/05) ML051390185 1089

DW-693 Lorna Doering Written comment (03/06/05) ML051390185 1090

DW-694 Marcia Hoodwin Written comment (03/06/05) ML051390185 1091

DW-695 Alicia Jaffe Written comment (03/06/05) ML051390185 1092

DW-696 Michael Appia Written comment (03/06/05) ML051390185 1093

DW-697 Joseph Calhoun Written comment (03/06/05) ML051390185 1094

DW-698 Rachael Sterlin Written comment (03/06/05) ML051390185 1095

DW-699 David Boone Written comment (03/06/05) ML051390185 1096

DW-700 Griff Miller Written comment (03/05/05) ML051390185 1097

DW-701 Carsten Hansen Written comment (03/05/05) ML051390185 1098

DW-702 Frank Hammond Written comment (03/05/05) ML051390185 1099

DW-703 Sean Brady Written comment (03/05/05) ML051390185 1100

DW-704 Devin Evert Written comment (03/05/05) ML051390185 1101

DW-705 Michael Allen Written comment (03/05/05) ML051390185 1102

DW-706 Julie Kissel Written comment (03/05/05) ML051390185 1103

DW-707 Charlotte Lundemo Written comment (03/05/05) ML051390185 1104

DW-708 Dawn Surowski Written comment (03/05/05) ML051390185 1105

DW-709 Mia Stollenwerk Written comment (03/05/05) ML051390185 1106

DW-710 Edgar Stahl Written comment (03/05/05) ML051390185 1107

DW-711 Glenn Miller Written comment (03/04/05) ML051390185 1108

DW-712 Roberta Froome Written comment (03/04/05) ML051390185 1109

DW-713 Matt Legler Written comment (03/04/05) ML051390185 1110

DW-714 Carla Osborne Written comment (03/04/05) ML051390185 1111

DW-715 Nancy Spears Written comment (03/04/05) ML051390185 1112

DW-716 Dee Randolph Written comment (03/04/05) ML051390185 1113

DW-717 Revathi Ananthakrishnan Written comment (03/04/05) ML051390185 1114
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-50

DW-718 Rachel Bernatz Written comment (03/04/05) ML051390185 1115

DW-719 Pete Lafoillette Written comment (03/04/05) ML051390185 1116

DW-720 Charles Rettinger Written comment (01/19/05) ML051390185 1117

DW-721 Eve Venema Written comment (01/19/05) ML051390185 1118

DW-722 Tavis Schmidt Written comment (01/19/05) ML051390185 1119

DW-723 Chris Spahn Written comment (01/19/05) ML051390185 1120

DW-724 Juliana Radloff Written comment (01/19/05) ML051390185 1121

DW-725 Julie Bond Written comment (01/19/05) ML051390185 1122

DW-726 Suzanne Sievers-Bartlett Written comment (01/19/05) ML051390185 1123

DW-727 Jennifer Doob Written comment (01/19/05) ML051390185 1124

DW-728 Barbara Singer Written comment (01/19/05) ML051390185 1125

DW-729 David Barish Written comment (01/20/05) ML051390185 1126

DW-730 Beverly Jennings Written comment (01/20/05) ML051390185 1128

DW-731 Shirley Napps Written comment (01/20/05) ML051390185 1129

DW-732 Dawn Winalski Written comment (01/20/05) ML051390185 1130

DW-733 Dina Sorensen Written comment (01/20/05) ML051390185 1131

DW-734 Angela Burnett Penn Written comment (01/20/05) ML051390185 1132

DW-735 Linda York Written comment (01/20/05) ML051390185 1133

DW-736 Anne Maziak Written comment (01/20/05) ML051390185 1134

DW-737 Ana Yong Soler Written comment (01/20/05) ML051390185 1135

DW-738 Mha Atma S. Khalsa Written comment (01/20/05) ML051390185 1136

DW-739 Kris McCradic Written comment (01/21/05) ML051390185 1137

DW-740 Kathleen Grant Written comment (01/21/05) ML051390185 1138

DW-741 Patricia Raynor Written comment (01/21/05) ML051390185 1139

DW-742 Diana Sette Written comment (01/21/05) ML051390185 1141

DW-743 Brian Hebeisen Written comment (01/21/05) ML051390185 1142

DW-744 Marione M. Cobb Written comment (01/21/05) ML051390185 1143

DW-745 Linda Prostko Written comment (01/22/05) ML051390185 1144

DW-746 Tom Boughan Written comment (01/23/05) ML051390185 1145

DW-747 Claire Watson Written comment (01/23/05) ML051390185 1146

DW-748 Betty J. Van Wicklen Written comment (01/23/05) ML051390185 1147

DW-749 Cynthia Patterson Written comment (01/23/05) ML051390185 1148

DW-750 Kalin Patterson Written comment (01/24/05) ML051390185 1149

DW-751 Erin Christiansen Written comment (01/24/05) ML051390185 1150

DW-752 John Covey Written comment (01/24/05) ML051390185 1151

DW-753 Ed Harris Written comment (01/25/05) ML051390185 1152

DW-754 Linda Alberda Written comment (01/25/05) ML051390185 1153

DW-755 Kirk Clayton Written comment (01/25/05) ML051390185 1154

DW-756 Jim Oxyer Written comment (01/26/05) ML051390185 1155

DW-757 John Votta Written comment (01/26/05) ML051390185 1156

DW-758 Sydney Funsinn Written comment (01/27/05) ML051390185 1157

DW-759 Kelle Peeplez Written comment (01/27/05) ML051390185 1158

DW-760 K. Kenneth Fujishiro Written comment (01/28/05) ML051390185 1159

DW-761 Julie Boswell Written comment (01/28/05) ML051390185 1160

DW-762 Carolynn Pakeltis Written comment (01/29/05) ML051390185 1161

DW-763 Dianne Miller Written comment (01/29/05) ML051390185 1162

DW-764 Brian Butcher Written comment (01/31/05) ML051390185 1163

DW-765 Michael Neil Written comment (01/31/05) ML051390185 1164

DW-766 Connie Boitano Written comment (02/01/05) ML051390185 1165
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-51

DW-767 Michael Aleman Written comment (02/02/05) ML051390185 1166

DW-768 Pete Lafoillette Written comment (02/03/05) ML051390185 1167

DW-769 Kimberley Sharp Written comment (02/04/05) ML051390185 1168

DW-770 Jeffri Frontz Written comment (02/05/05) ML051390185 1169

DW-771 Caryn Corriere Written comment (02/06/05) ML051390185 1170

DW-772 Wendy McFadden Written comment (02/06/05) ML051390185 1171

DW-773 Leslie Tawnamaia Written comment (02/07/05) ML051390185 1172

DW-774 Ben Malloy Written comment (02/08/05) ML051390185 1173

DW-775 Anna Von Gehr Written comment (02/09/05) ML051390185 1174

DW-776 Claudia Duffy Written comment (02/09/05) ML051390185 1175

DW-777 Zack Fields Written comment (02/09/05) ML051390185 1176

DW-778 Emily and Jeremy Peters Written comment (02/09/05) ML051390185 1177

DW-779 Susannah Wood Written comment (02/09/05) ML051390185 1178

DW-780 Bob Peckman Written comment (02/09/05) ML051390185 1179

DW-781 Linda Boswell Written comment (02/09/05) ML051390185 1180

DW-782 Jeffrey Grossman Written comment (02/09/05) ML051390185 1181

DW-783 Cynthia Lewis Written comment (02/09/05) ML051390185 1182

DW-784 Carol Curran Written comment (02/09/05) ML051390185 1183

DW-785 Dottie Hampton Written comment (02/09/05) ML051390185 1184

DW-786 Coleen Zahnke Written comment (02/10/05) ML051390185 1185

DW-787 Elizabeth Gilchrist Written comment (02/10/05) ML051390185 1186

DW-788 Anne Johnston Written comment (02/10/05) ML051390185 1187

DW-789 Charlotte Shnaider Written comment (02/10/05) ML051390185 1188

DW-790 Melanie Jackson Written comment (02/10/05) ML051390185 1189

DW-791 Dennis A. Bried Written comment (02/10/05) ML051390185 1190

DW-792 Joanna Salidis Written comment (02/10/05) ML051390185 1191

DW-793 Clare McBrien Written comment (02/10/05) ML051390185 1192

DW-794 Della Cleve Written comment (02/11/05) ML051390185 1193

DW-795 Julie Huff Written comment (02/11/05) ML051390185 1194

DW-796 Frank Worshek Written comment (02/11/05) ML051390185 1195

DW-797 David Johnston Written comment (02/11/05) ML051390185 1196

DW-798 Peggy Augustus Written comment (02/12/05) ML051390185 1197

DW-799 Sally Bastian Written comment (02/12/05) ML051390185 1198

DW-800 Paul Fleisher Written comment (02/12/05) ML051390185 1199

DW-801 Rosemarie Sawdon Written comment (02/12/05) ML051390185 1200

DW-802 Diana Bach Written comment (02/13/05) ML051390185 1201

DW-803 Todd Chenore Written comment (02/13/05) ML051390185 1202

DW-804 Julie Bond Written comment (02/13/05) ML051390185 1203

DW-805 Charles Hall and Adrienne

Bodie

Written comment (02/14/05) ML051390185 1204

DW-806 Kenneth Remmers,

Waterside Property Owners

of Lake Anna

Written comment (02/15/05) ML051390185 1206

DW-807 James Nelson Written comment (02/15/05) ML051390185 1213

DW-808 Samuel Kroiz Written comment (02/15/05) ML051390185 1214

DW-809 Josh Swartzbaugh Written comment (02/15/05) ML051390185 1215

DW-810 Beth Davies Written comment (02/16/05) ML051390185 1216

DW-811 Lenore Bassett Written comment (02/16/05) ML051390185 1217

DW-812 Ashok Bankley Written comment (02/16/05) ML051390185 1218
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-52

DW-813 Katie Boyle Written comment (02/17/05) ML051390185 1219

DW-814 Marion McDonald Written comment (02/17/05) ML051390185 1220

DW-815 Marion McDonald Written comment (02/17/05) ML051390185 1221

DW-816 Shelly and Sid Sitzer Written comment (02/17/05) ML051390185 1223

DW-817 Lindsay Hawks Written comment (02/17/05) ML051390185 1224

DW-818 Robert A. Pedde and

Lawrence A. Salomone,

Westinghouse, Savannah

River Co.

Written comment (02/17/05) ML051390185 1225

DW-819 Jenny Heberlein Written comment (02/18/05) ML051390185 1237

DW-820 Michael Stuart Written comment (02/18/05) ML051390185 1238

DW-821 Allison Crowell Written comment (02/18/05) ML051390185 1239

DW-822 Brenda Hyson Written comment (02/20/05) ML051390185 1240

DW-823 Jim Adams Written comment (02/20/05) ML051390185 1241

DW-824 John Kesich Written comment (02/20/05) ML051390185 1245

DW-825 Chip Tucker Written comment (02/21/05) ML051390185 1246

DW-826 Kelly L. Taylor Written comment (02/21/05) ML051390185 1248

DW-827 Lillian Mezey Written comment (02/21/05) ML051390185 1249

DW-828 John Patrick Smith Written comment (02/22/05) ML051390185 1250

DW-829 Benjamin T. Brown Written comment (02/22/05) ML051390185 1251

DW-830 Rob Pates Written comment (02/23/05) ML051390185 1252

DW-831 Jennifer Meyer Written comment (02/23/05) ML051390185 1253

DW-832 Robert Oldham Written comment (02/24/05) ML051390185 1254

DW-833 Beth McLeod Written comment (02/24/05) ML051390185 1255

DW-834 Helen R. Reutlinger Written comment (02/24/05) ML051390185 1256

DW-835 Caryl Burtner Written comment (02/24/05) ML051390185 1257

DW-836 Dinda Evana Written comment (02/24/05) ML051390185 1260

DW-837 Kurt Schroeder Written comment (02/24/05) ML051390185 1263

DW-838 Scott Clark Written comment (02/24/05) ML051390185 1266

DW-839 Silja Sistok-Katz Written comment (02/24/05) ML051390185 1269

DW-840 Kira Routh Written comment (02/24/05) ML051390185 1272

DW-841 Susie Callahan Written comment (02/24/05) ML051390185 1275

DW-842 Blake Puhak Written comment (02/24/05) ML051390185 1278

DW-843 Noah Scalin Written comment (02/24/05) ML051390185 1281

DW-844 Dana Cook Written comment (02/24/05) ML051390185 1284

DW-845 Tina Pence Written comment (02/24/05) ML051390185 1287

DW-846 Jone Shilliday Written comment (02/24/05) ML051390185 1290

DW-847 Glen Besa Written comment (02/24/05) ML051390185 1293

DW-848 Amoret Bruguiere Written comment (02/24/05) ML051390185 1296

DW-849 Jan Vinegar Written comment (02/24/05) ML051390185 1299

DW-850 Michael Goodman Written comment (03/01/05) ML051390185 1302

DW-851 Ravi Grover Written comment (03/01/05) ML051390185 1303

DW-852 Michael Bernier Written comment (03/01/05) ML051390185 1304

DW-853 Jason Pooler Written comment (03/01/05) ML051390185 1305

DW-854 Michelle Salisbury Written comment (03/01/05) ML051390185 1306

DW-855 Elaine Plamquist Written comment (03/01/05) ML051390185 1307

DW-856 Suzanne Yeaman Written comment (03/01/05) ML051390185 1308

DW-857 Diana C. Parker Written comment (03/01/05) ML051390185 1311

DW-858 Matthew Holland Written comment (03/01/05) ML051390185 1313
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-53

DW-859 Mariah Grant Written comment (03/01/05) ML051390185 1314

DW-860 Martha Williams Written comment (03/01/05) ML051390185 1317

DW-861 Rebecca Farris Written comment (03/01/05) ML051390185 1318

DW-862 Michaela Wehner Written comment (03/01/05) ML051390185 1319

DW-863 Lisa Shell Written comment (03/01/05) ML051390185 1320

DW-864 Thomas Olsen Written comment (03/01/05) ML051390185 1324

DW-865 Andy Barton Written comment (03/01/05) ML051390185 1327

DW-866 Fred Dove Written comment (03/01/05) ML051390185 1330

DW-867 Barry Kuhlik Written comment (03/01/05) ML051390185 1331

DW-868 John Dukovich Written comment (02/25/05) ML051390185 1332

DW-869 Sarah Wise Written comment (02/25/05) ML051390185 1333

DW-870 David Roth Written comment (02/25/05) ML051390185 1334

DW-871 Kris Unger Written comment (02/25/05) ML051390185 1335

DW-872 Katie Stump Written comment (02/25/05) ML051390185 1336

DW-873 Joe Whetstone Written comment (02/25/05) ML051390185 1339

DW-874 Joanne M. Thiele Written comment (02/24/05) ML051390185 1340

DW-875 Anjili Pal Written comment (02/25/05) ML051390185 1343

DW-876 Sherri Cook Written comment (02/25/05) ML051390185 1346

DW-877 D. D. Delaney Written comment (02/25/05) ML051390185 1349

DW-878 Ryan Cunningham Written comment (02/25/05) ML051390185 1352

DW-879 Andrew Dzikiewicz Written comment (02/25/05) ML051390185 1355

DW-880 Allen Muchnick Written comment (02/25/05) ML051390185 1356

DW-881 Dexter Payne Written comment (02/25/05) ML051390185 1359

DW-882 Lynne Carruth Written comment (02/25/05) ML051390185 1360

DW-883 Mike Craig Written comment (02/25/05) ML051390185 1363

DW-884 Garrett English Written comment (02/25/05) ML051390185 1366

DW-885 Alan Carlson Written comment (02/25/05) ML051390185 1369

DW-886 Jon Cruickshank Written comment (02/25/05) ML051390185 1370

DW-887 Jason Miller Written comment (02/25/05) ML051390185 1373

DW-888 Albert Fioretti Written comment (02/25/05) ML051390185 1376

DW-889 Lilli Hoffman Written comment (02/25/05) ML051390185 1379

DW-890 Marsha Withers Written comment (02/25/05) ML051390185 1382

DW-891 Sue Hayden Written comment (02/25/05) ML051390185 1385

DW-892 Joseph Tyrrell Written comment (02/25/05) ML051390185 1386

DW-893 Katherine Hollins Written comment (02/25/05) ML051390185 1389

DW-894 Robert Kurtz Written comment (02/25/05) ML051390185 1392

DW-895 David Campbell Written comment (02/25/05) ML051390185 1393

DW-896 Gregory Doggett Written comment (02/25/05) ML051390185 1396

DW-897 Eliza Beth Engle Written comment (02/25/05) ML051390185 1399

DW-898 Margaret Murphy Written comment (02/25/05) ML051390185 1400

DW-899 Karen Rakes Written comment (02/25/05) ML051390185 1401

DW-900 John Morgan Written comment (02/25/05) ML051390185 1402

DW-901 Talbott Hagood Written comment (02/25/05) ML051390185 1403

DW-902 Ted Hochstadt Written comment (02/25/05) ML051390185 1404

DW-903 Cindy Carper Written comment (02/25/05) ML051390185 1405

DW-904 Dewey Keeton III Written comment (02/25/05) ML051390185 1408

DW-905 Andrea Shandor Written comment (02/25/05) ML051390185 1409

DW-906 Katie Brazier Written comment (02/25/05) ML051390185 1412

DW-907 Catherine OBrion Written comment (02/25/05) ML051390185 1413
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-54

DW-908 Walter Hill Written comment (02/25/05) ML051390185 1414

DW-909 Rich Meier Written comment (02/25/05) ML051390185 1415

DW-910 Roger Adams Written comment (02/25/05) ML051390185 1416

DW-911 Cindy Carper Written comment (02/25/05) ML051390185 1417

DW-912 John Davis Written comment (02/25/05) ML051390185 1418

DW-913 Jason J. Green Written comment (02/25/05) ML051390185 1419

DW-914 Kristy Lutjen Written comment (02/25/05) ML051390185 1420

DW-915 Roy Mitchell Written comment (02/25/05) ML051390185 1421

DW-916 Abigail Quesinberry Written comment (02/25/05) ML051390185 1422

DW-917 Susan Wilson Written comment (02/25/05) ML051390185 1423

DW-918 Pat Therrien Written comment (02/25/05) ML051390185 1426

DW-919 Robert Rutkowski Written comment (02/25/05) ML051390185 1429

DW-920 Nell Carr-Young Written comment (02/25/05) ML051390185 1430

DW-921 Roger Adams Written comment (02/25/05) ML051390185 1433

DW-922 Janet Hunt Written comment (02/25/05) ML051390185 1436

DW-923 Ignacia Pessoa Written comment (02/25/05) ML051390185 1439

DW-924 Jane Simpson Written comment (02/25/05) ML051390185 1442

DW-925 Catherine Welsh Written comment (02/25/05) ML051390185 1445

DW-926 Eileen and Victor Chieco Written comment (02/25/05) ML051390185 1447

DW-927 Roger P. Santerre Written comment (02/25/05) ML051390185 1448

DW-928 Kirit Mehta Written comment (02/25/05) ML051390185 1449

DW-929 Peter Buck Written comment (02/25/05) ML051390185 1452

DW-930 Jim Eldon Written comment (02/25/05) ML051390185 1455

DW-931 Joseph Edwards Written comment (02/25/05) ML051390185 1456

DW-932 Joetta Venneman Written comment (02/25/05) ML051390185 1459

DW-933 Peter and Catherine

Marciniak

Written comment (02/25/05) ML051390185 1460

DW-934 Jon McMillan Written comment (02/25/05) ML051390185 1461

DW-935 Timothy D. Wampler Written comment (02/25/05) ML051390185 1464

DW-936 Suzanne Tarr Written comment (02/25/05) ML051390185 1465

DW-937 Pamela Irwin Written comment (02/25/05) ML051390185 1468

DW-938 Pamela Newton Written comment (02/25/05) ML051390185 1471

DW-939 Emanuel Suter Written comment (02/25/05) ML051390185 1474

DW-940 Brian Quam Written comment (02/25/05) ML051390185 1477

DW-941 Hannah Sk Written comment (02/25/05) ML051390185 1480

DW-942 Lily Whitesell Written comment (02/25/05) ML051390185 1483

DW-943 Ron Anderson Written comment (02/25/05) ML051390185 1486

DW-944 Jason McMillen Written comment (02/25/05) ML051390185 1489

DW-945 Douglas Jaslow Written comment (02/25/05) ML051390185 1492

DW-946 Mark J. Burwinkel Written comment (02/25/05) ML051390185 1495

DW-947 Tom Weis Written comment (02/25/05) ML051390185 1498

DW-948 Charlote Diedrich Written comment (02/25/05) ML051390185 1501

DW-949 Amee McDermott Written comment (02/25/05) ML051390185 1502

DW-950 Mary Dunbar Written comment (02/25/05) ML051390185 1505

DW-951 J. Weikert Written comment (02/25/05) ML051390185 1508

DW-952 Leah Quam Written comment (02/25/05) ML051390185 1511

DW-953 Jeanne O’Hara Written comment (02/25/05) ML051390185 1514

DW-954 Brian Wilson Written comment (02/25/05) ML051390185 1517

DW-955 Mark Atkinson Written comment (02/25/05) ML051390185 1520
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-55

DW-956 Carol Bock Written comment (02/25/05) ML051390185 1521

DW-957 Katie Stif Written comment (02/28/05) ML051390185 1524

DW-958 Pat Churchman Written comment (02/24/05) ML051390185 1527

DW-959 Mimi Elrod Written comment (02/24/05) ML051390185 1530

DW-960 Kelly Bryan Written comment (02/24/05) ML051390190 1533

DW-961 Willis Turner Written comment (02/24/05) ML051390190 1536

DW-962 Mary Steponkus Written comment (02/24/05) ML051390190 1539

DW-963 Joe Apple Written comment (02/24/05) ML051390190 1542

DW-964 Leonardo Sarli Written comment (02/24/05) ML051390190 1545

DW-965 Letitia Johnson Written comment (02/24/05) ML051390190 1548

DW-966 Teresa Nemeth Written comment (02/24/05) ML051390190 1551

DW-967 Burt Avery Written comment (02/24/05) ML051390190 1554

DW-968 Judy Szeman Written comment (02/24/05) ML051390190 1557

DW-969 Matt Duffy Written comment (02/24/05) ML051390190 1560

DW-970 Vicki Nichols Goldstein Written comment (02/24/05) ML051390190 1563

DW-971 Heath Johnso Written comment (02/24/05) ML051390190 1566

DW-972 Lauren McCabe Written comment (02/24/05) ML051390190 1569

DW-973 Catherine Fleischman Written comment (02/24/05) ML051390190 1572

DW-974 Lori C Written comment (02/24/05) ML051390190 1575

DW-975 Flemming Heegaard Written comment (02/24/05) ML051390190 1578

DW-976 Paul Friedman Written comment (02/24/05) ML051390190 1581

DW-977 Scott Burger Written comment (02/24/05) ML051390190 1584

DW-978 Ann Woodlief Written comment (02/24/05) ML051390190 1587

DW-979 Michelle Parker Written comment (02/24/05) ML051390190 1588

DW-980 Barbara Gardner Written comment (02/24/05) ML051390190 1591

DW-981 Linda Falkerson Written comment (02/24/05) ML051390190 1594

DW-982 Mark Parlette Written comment (02/24/05) ML051390190 1597

DW-983 Elizabeth Borkowski Written comment (02/24/05) ML051390190 1600

DW-984 Robert Mueller Written comment (02/24/05) ML051390190 1603

DW-985 Andrea B. Krochalis Written comment (02/24/05) ML051390190 1605

DW-986 Jaime Bennett Written comment (02/24/05) ML051390190 1608

DW-987 Agnes Stringfellow Written comment (02/24/05) ML051390190 1611

DW-988 Erin Ward Written comment (02/24/05) ML051390190 1614

DW-989 Heidi Bilardo Written comment (02/24/05) ML051390190 1617

DW-990 Barbara Beck Written comment (02/24/05) ML051390190 1620

DW-991 Thomas Ellis Written comment (02/24/05) ML051390190 1623

DW-992 Jowita Wysocka Written comment (02/24/05) ML051390190 1626

DW-993 David Shantz Written comment (02/24/05) ML051390190 1629

DW-994 Anne Donley Written comment (02/24/05) ML051390190 1631

DW-995 Melissa Strobel Written comment (02/24/05) ML051390190 1634

DW-996 Maya Skopal Written comment (02/24/05) ML051390190 1637

DW-997 Steve Brooks Written comment (02/24/05) ML051390190 1640

DW-998 Sue D’Onofrio Written comment (02/24/05) ML051390190 1643

DW-999 Floret Parker Written comment (02/24/05) ML051390190 1644

DW-1000 Nicole Germans Written comment (02/24/05) ML051390190 1647

DW-1001 Boswell Jacqueline Written comment (02/24/05) ML051390190 1650

DW-1002 Gloria Berg Written comment (02/24/05) ML051390190 1653

DW-1003 Susie Crate Written comment (02/24/05) ML051390190 1656

DW-1004 John Howard Written comment (02/24/05) ML051390190 1659
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-56

DW-1005 Elijah Morrison Written comment (02/24/05) ML051390190 1662

DW-1006 Ron Edwards Written comment (02/24/05) ML051390190 1665

DW-1007 Norman B. Tweed, Jr. Written comment (02/24/05) ML051390190 1668

DW-1008 Audrey Moeller Written comment (02/24/05) ML051390190 1670

DW-1009 William and Nedra Scarrow Written comment (02/24/05) ML051390190 1673

DW-1010 Charles Pool Written comment (02/24/05) ML051390190 1676

DW-1011 Laura Davimes Written comment (02/24/05) ML051390190 1679

DW-1012 Julie Pitre Written comment (02/24/05) ML051390190 1682

DW-1013 Roy Mitchell Written comment (02/24/05) ML051390190 1683

DW-1014 Richard Churray Written comment (02/24/05) ML051390190 1686

DW-1015 Alice Catlin Written comment (02/24/05) ML051390190 1689

DW-1016 M. Sundy Written comment (02/24/05) ML051390190 1692

DW-1017 Melody Jeffrey Written comment (02/24/05) ML051390190 1695

DW-1018 Charles Seyffer Written comment (02/24/05) ML051390190 1698

DW-1019 Alan Gold Written comment (02/24/05) ML051390190 1701

DW-1020 Michael Loew Written comment (02/24/05) ML051390190 1704

DW-1021 Alice Whealin Written comment (02/24/05) ML051390190 1707

DW-1022 Mary Lou Bolas Written comment (02/24/05) ML051390190 1710

DW-1023 Laura Celestine Written comment (02/24/05) ML051390190 1713

DW-1024 Christoph Hogger Written comment (02/24/05) ML051390190 1716

DW-1025 D. Prusik Written comment (02/24/05) ML051390190 1719

DW-1026 Brigit Campana Written comment (02/24/05) ML051390190 1720

DW-1027 Howard Urbach Written comment (02/24/05) ML051390190 1723

DW-1028 Ryan Williamson Written comment (02/24/05) ML051390190 1726

DW-1029 Ann Rogers Written comment (02/24/05) ML051390190 1729

DW-1030 Aurora E. Hunter Written comment (02/24/05) ML051390190 1732

DW-1031 Laura Ewen Written comment (02/24/05) ML051390190 1733

DW-1032 Christopher Austin Written comment (02/24/05) ML051390190 1736

DW-1033 Chris Stafford Written comment (02/24/05) ML051390190 1737

DW-1034 Cindy Pryor Written comment (02/24/05) ML051390190 1740

DW-1035 Rael Nidess Written comment (02/24/05) ML051390190 1743

DW-1036 James Zinck Written comment (02/24/05) ML051390190 1744

DW-1037 Jean and Bill Ackor Written comment (02/24/05) ML051390190 1747

DW-1038 Susan Emge Milliner Written comment (02/24/05) ML051390190 1748

DW-1039 Susan Chappell Written comment (02/24/05) ML051390190 1749

DW-1040 Michael Shapiro Written comment (02/24/05) ML051390190 1752

DW-1041 Jimmy Carrell Written comment (02/24/05) ML051390190 1755

DW-1042 Lucy Sotar Written comment (02/24/05) ML051390190 1758

DW-1043 Douglas Austin Written comment (02/24/05) ML051390190 1759

DW-1044 David Longacre Written comment (02/24/05) ML051390190 1762

DW-1045 Carolyn Bushey Written comment (02/24/05) ML051390190 1763

DW-1046 Stasi York Written comment (02/24/05) ML051390190 1766

DW-1047 Talbott Hagood Written comment (02/24/05) ML051390190 1769

DW-1048 Dewey Keeton, III Written comment (02/24/05) ML051390190 1772

DW-1049 Keith Bryan Written comment (02/24/05) ML051390190 1775

DW-1050 Barbara Williamson Written comment (02/24/05) ML051390190 1778

DW-1051 Lance Pedigo Written comment (02/24/05) ML051390190 1781

DW-1052 Juan Marchini Written comment (02/24/05) ML051390190 1784

DW-1053 Ron Peterson and Family Written comment (02/24/05) ML051390190 1785
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-57

DW-1054 Dean Amel Written comment (02/24/05) ML051390190 1786

DW-1055 Yvonne McGhee Written comment (02/24/05) ML051390190 1789

DW-1056 Stephen Proctor Written comment (02/24/05) ML051390190 1792

DW-1057 Robert Barnes Written comment (02/24/05) ML051390190 1795

DW-1058 Letitia Kashani Written comment (02/24/05) ML051390190 1798

DW-1059 Diane Dennette-Shaw Written comment (02/24/05) ML051390190 1801

DW-1060 Kyle Bunting Written comment (02/24/05) ML051390190 1804

DW-1061 Leah Rampy Written comment (02/24/05) ML051390190 1807

DW-1062 Anne Nielsen Written comment (02/24/05) ML051390190 1810

DW-1063 Lillian Henderson Written comment (02/24/05) ML051390190 1813

DW-1064 Megan Imbert Written comment (02/24/05) ML051390190 1816

DW-1065 Daniel Sumrall Written comment (02/24/05) ML051390190 1819

DW-1066 Daniel Homitz Written comment (02/24/05) ML051390190 1822

DW-1067 Charlotte McAdams Written comment (02/24/05) ML051390190 1825

DW-1068 Adrienne Strandberg Written comment (02/24/05) ML051390190 1828

DW-1069 Griff Miller Written comment (02/24/05) ML051390190 1831

DW-1070 Patricia Soriano Written comment (02/24/05) ML051390190 1834

DW-1071 Buddy East Written comment (02/24/05) ML051390190 1837

DW-1072 Sarah Wise Written comment (02/24/05) ML051390190 1840

DW-1073 Sara Zaza Written comment (02/24/05) ML051390190 1843

DW-1074 Sarah Lanzman Written comment (02/24/05) ML051390190 1846

DW-1075 Anje Cassel Written comment (02/24/05) ML051390190 1849

DW-1076 Victoria Mullins Written comment (02/24/05) ML051390190 1852

DW-1077 Anne Tyrrell Written comment (02/24/05) ML051390190 1855

DW-1078 M. L. Devore Written comment (02/24/05) ML051390190 1858

DW-1079 Pamelynn Snell Written comment (02/24/05) ML051390190 1861

DW-1080 Paul Mayhew Written comment (02/24/05) ML051390190 1864

DW-1081 Claire Ward Written comment (02/24/05) ML051390190 1867

DW-1082 Leslie Fellows Written comment (02/24/05) ML051390190 1870

DW-1083 Christopher Kunkel Written comment (02/24/05) ML051390190 1873

DW-1084 Michael Woodbridge Written comment (02/24/05) ML051390190 1876

DW-1085 Linda Braham Written comment (02/24/05) ML051390190 1879

DW-1086 Barbara Pryor Written comment (02/24/05) ML051390190 1882

DW-1087 Jennifer Smith Written comment (02/24/05) ML051390190 1885

DW-1088 Cliff Miller Written comment (02/24/05) ML051390190 1888

DW-1089 James Lowestern Written comment (02/24/05) ML051390190 1890

DW-1090 Jane Wentworth Written comment (02/24/05) ML051390190 1891

DW-1091 Karen Jones Squires Written comment (02/24/05) ML051390190 1892

DW-1092 Tracy Ann Costello Written comment (02/24/05) ML051390190 1893

DW-1093 Lyn Darnall Written comment (02/24/05) ML051390190 1896

DW-1094 Guy Ross Written comment (02/24/05) ML051390190 1897

DW-1095 James P. Lynch Written comment (02/24/05) ML051390190 1900

DW-1096 Samuel Parrucci Written comment (02/24/05) ML051390190 1902

DW-1097 Robert Egbert Written comment (02/24/05) ML051390190 1905

DW-1098 Kelly Snyder Written comment (02/24/05) ML051390190 1908

DW-1099 John Sukovich Written comment (02/24/05) ML051390190 1911

DW-1100 Don Timmerman,

Roberta Thurstin

Written comment (02/24/05) ML051390190 1912

DW-1101 Whitney Cali Written comment (02/24/05) ML051390190 1913
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-58

DW-1102 Patricia Eichenberger Written comment (02/24/05) ML051390190 1916

DW-1103 Mark Reback Written comment (02/24/05) ML051390190 1919

DW-1104 Sherley Redding Written comment (02/24/05) ML051390190 1920

DW-1105 Sharon Best Written comment (02/24/05) ML051390190 1923

DW-1106 Christina Martinez Written comment (02/24/05) ML051390190 1926

DW-1107 Eric White Written comment (02/24/05) ML051390190 1929

DW-1108 Thomas Savage Written comment (02/24/05) ML051390190 1932

DW-1109 Joe Terry Written comment (02/24/05) ML051390190 1935

DW-1110 Paul Greggs Written comment (02/24/05) ML051390190 1938

DW-1111 Phyllis Pownall Written comment (02/24/05) ML051390190 1941

DW-1112 Ellie Carter Written comment (03/01/05) ML051390190 1944

DW-1113 Erica Hulstrom Written comment (03/01/05) ML051390190 1947

DW-1114 Richard Spotts Written comment (03/01/05) ML051390190 1948

DW-1115 Maurene Gray Written comment (03/01/05) ML051390190 1949

DW-1116 Dana Leeper Written comment (03/01/05) ML051390190 1950

DW-1117 Karen Spencer Written comment (03/01/05) ML051390190 1953

DW-1118 Wendy Kupsaw Written comment (03/01/05) ML051390190 1954

DW-1119 Jill Quick Written comment (03/01/05) ML051390190 1955

DW-1120 Jerome Decker Written comment (03/01/05) ML051390190 1956

DW-1121 Terry Grant Written comment (03/01/05) ML051390190 1957

DW-1122 Morgan Butler, and Richard

A. Parrish, Southern

Environmental Law Center

Written comment (03/01/05) ML051390190 1958

DW-1123 Brock Johnson Written comment (03/01/05) ML051390190 1966

DW-1124 Ceri Hitchcock-Hodgson Written comment (03/01/05) ML051390190 1967

DW-1125 Judy Stufflebeam Written comment (03/01/05) ML051390190 1968

DW-1126 Alice Sullivan Written comment (03/01/05) ML051390190 1969

DW-1127 David Leavitt Written comment (03/01/05) ML051390190 1970

DW-1128 James Zizzo Written comment (03/01/05) ML051390190 1971

DW-1129 Chris Hartleben Written comment (03/01/05) ML051390190 1972

DW-1130 Ronald Holberg Written comment (03/01/05) ML051390190 1973

DW-1131 Yvonne Sorovacu Written comment (03/01/05) ML051390190 1974

DW-1132 Nancy Gathing, Written comment (03/01/05) ML051390190 1977

DW-1133 Victoria Plummer Written comment (03/01/05) ML051390190 1978

DW-1134 Joseph Ponisciak Written comment (03/01/05) ML051390190 1979

DW-1135 Matthew R. Courter Written comment (03/01/05) ML051390190 1980

DW-1136 Lori Burris Written comment (03/01/05) ML051390190 1981

DW-1137 Ann Brummer Written comment (03/01/05) ML051390190 1982

DW-1138 Mark Kennedy Written comment (03/01/05) ML051390190 1985

DW-1139 Deke Gliem Written comment (03/01/05) ML051390190 1986

DW-1140 Jean Balckwood Written comment (03/01/05) ML051390190 1987

DW-1141 Amber Herdez Written comment (03/01/05) ML051390190 1988

DW-1142 Ruthann Roka Written comment (03/01/05) ML051390190 1989

DW-1143 Gordon Early Written comment (03/01/05) ML051390190 1990

DW-1144 Miriam Kurland Written comment (03/01/05) ML051390190 1991

DW-1145 Krista Blackwood Written comment (03/01/05) ML051390190 1992

DW-1146 Shannon Sweeney Written comment (03/01/05) ML051390190 1993

DW-1147 Steven Culp Written comment (03/01/05) ML051390190 1994

DW-1148 Eric Gracyalny Written comment (03/01/05) ML051390190 1995
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-59

DW-1149 Delbert Horn Written comment (03/01/05) ML051390190 1999

DW-1150 James H. Jorgensen Written comment (03/01/05) ML051390190 2001

DW-1151 David E. Brown Written comment (03/01/05) ML051390190 2002

DW-1152 France Perlman Written comment (03/01/05) ML051390190 2003

DW-1153 Sharon Wright Written comment (03/01/05) ML051390190 2004

DW-1154 Paul Gunter, Nuclear

Information Resource Service

Written comment (03/01/05) ML051390190 2005

DW-1155 Margaret O’Keefe Written comment (03/01/05) ML051390190 2010

DW-1156 Laurie Beringer Written comment (03/01/05) ML051390190 2011

DW-1157 Daniel R. Holmes, Piedmont

Environmental Center

Written comment (03/01/05) ML051390190 2012

DW-1158 Robert T. May Written comment (03/01/05) ML051390190 2018

DW-1159 Judy Woods Written comment (03/01/05) ML051390190 2019

DW-1160 Kimberly Anne Halizak Written comment (03/01/05) ML051390190 2020

DW-1161 Gregory Rouse Written comment (03/01/05) ML051390190 2021

DW-1162 Dianne Hinch Written comment (03/01/05) ML051390190 2022

DW-1163 Louis Zeller, Blue Ridge

Environmental Defense

League

Written comment (03/01/05) ML051390190 2025

DW-1164 Michaela Redden Written comment (03/01/05) ML051390190 2028

DW-1165 Sarah Schaefer Written comment (03/01/05) ML051390190 2029

DW-1166 Kathleen Halliburton-Ross Written comment (03/01/05) ML051390190 2030

DW-1167 Joseph O. Erb Written comment (03/01/05) ML051390190 2033

DW-1168 Dianne Hinch Written comment (03/01/05) ML051390190 2034

DW-1169 R. Michael Harman Written comment (03/01/05) ML051390190 2035

DW-1170 Steve Liebowitz Written comment (03/01/05) ML051390190 2036

DW-1171 Bert Courson Written comment (03/01/05) ML051390190 2037

DW-1172 Vernon and Carol Whitney Written comment (03/01/05) ML051390190 2038

DW-1173 Susanna Houston Written comment (03/01/05) ML051390190 2039

DW-1174 Erin Foley Written comment (03/01/05) ML051390190 2040

DW-1175 Alisha Wilson Written comment (03/02/05) ML051390190 2043

DW-1176 Abhaya Thiele Written comment (03/02/05) ML051390190 2044

DW-1177 Marcia Fairman Written comment (03/02/05) ML051390190 2046

DW-1178 Joe Blaszcak Written comment (03/02/05) ML051390190 2047

DW-1179 Priya Hudson-DiTraglia Written comment (03/02/05) ML051390190 2048

DW-1180 Sally Berk Written comment (03/02/05) ML051390190 2049

DW-1181 Chad Freckmann Written comment (03/02/05) ML051390190 2050

DW-1182 Isaac Ludwing Written comment (03/02/05) ML051390190 2051

DW-1183 Rachael Daigle Written comment (03/02/05) ML051390190 2052

DW-1184 Rita Hodge Written comment (03/02/05) ML051390190 2053

DW-1185 Adam Weesner Written comment (03/02/05) ML051390190 2054

DW-1186 Lucy Bovasso Written comment (03/02/05) ML051390190 2055

DW-1187 Jami Porter Lara Written comment (03/02/05) ML051390190 2056

DW-1188 Jill Ramson Written comment (03/02/05) ML051390190 2057

DW-1189 Mark and Sandra Crossler Written comment (03/02/05) ML051390190 2058

DW-1190 Catherine Stevens Written comment (03/02/05) ML051390190 2059

DW-1191 Kathi Lindsay Written comment (03/02/05) ML051390190 2060

DW-1192 Matthew Allenbaugh Written comment (03/02/05) ML051390190 2061

DW-1193 Janis Shaw Written comment (03/02/05) ML051390190 2062
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

NUREG-1811, Volume II December 2006 6-60

DW-1194 Alison Zyla Written comment (03/02/05) ML051390190 2063

DW-1195 Karen M. Lehman Written comment (03/02/05) ML051390190 2064

DW-1196 Mary Burress Written comment (03/02/05) ML051390190 2065

DW-1197 Marilyn Meyer Written comment (03/02/05) ML051390190 2066

DW-1198 Margaret Benfield Written comment (03/02/05) ML051390190 2067

DW-1199 Chris Saunders Written comment (03/02/05) ML051390190 2068

DW-1200 Sean Winkel Written comment (03/02/05) ML051390190 2069

DW-1201 James Barrett Written comment (03/02/05) ML051390190 2070

DW-1202 Richard Sanders Written comment (03/02/05) ML051390190 2071

DW-1203 J. Kennedy Written comment (03/04/05) ML051390190 2072

DW-1204 Mark Bir Written comment (03/04/05) ML051390190 2073

DW-1205 Karen Stout Written comment (03/04/05) ML051390190 2074

DW-1206 Yvonne E. Carter Written comment (03/04/05) ML051390190 2075

DW-1207 Bob Osland Written comment (03/04/05) ML051390190 2076

DW-1208 Rebecca Hoeschler Written comment (03/04/05) ML051390190 2077

DW-1209 Shannon Adams Written comment (03/04/05) ML051390190 2078

DW-1210 Ronald Russillo Written comment (03/04/05) ML051390190 2079

DW-1211 Julie Betterley Written comment (03/04/05) ML051390190 2080

DW-1212 Mary Fisher Written comment (03/04/05) ML051390190 2081

DW-1213 Shauna Steigerwald Written comment (03/04/05) ML051390190 2082

DW-1214 Richard L. Geddes Written comment (03/04/05) ML051390190 2083

DW-1215 Julie Obermeyer Written comment (03/03/05) ML051390190 2086

DW-1216 Audrey J. Reed Written comment (03/03/05) ML051390190 2087

DW-1217 John Coltrinari Written comment (03/03/05) ML051390190 2088

DW-1218 Katy Duke Written comment (03/03/05) ML051390190 2089

DW-1219 Sigrid Hepp-Dax Written comment (03/03/05) ML051390190 2090

DW-1220 Mark Schnider Written comment (03/03/05) ML051390190 2091

DW-1221 James Mayes Written comment (03/03/05) ML051390190 2092

DW-1222 Kerry Girardin Written comment (03/03/05) ML051390190 2093

DW-1223 Elizabeth Shuey Written comment (03/03/05) ML051390190 2094

DW-1224 Andrew Davis Written comment (03/03/05) ML051390190 2095

DW-1225 Cynthia Tapley Written comment (03/03/05) ML051390190 2096

DW-1226 Tori Mitchell Written comment (03/03/05) ML051390190 2097

DW-1227 Kim McClamroch Written comment (03/03/05) ML051390190 2098

DW-1228 Kay Goss Written comment (03/03/05) ML051390190 2099

DW-1229 Julie Bruning Written comment (03/04/05) ML051390190 2100

DW-1230 Sheila Ward Written comment (03/04/05) ML051390190 2101

DW-1231 Angela Black Written comment (03/04/05) ML051390190 2102

DW-1232 Barbara Sullivan Written comment (03/08/05) ML051390190 2103

DW-1233 Dianne Bigler Written comment (03/07/05) ML051390190 2105

DW-1234 Tom Loper Written comment (02/28/05) ML051390190 2106

DW-1235 Joseph R. Lyle Written comment (04/01/05) ML051390190 2107

DW-1236 Cassandra Warren Written comment (03/31/05) ML051390190 2109

DW-1237 John Daily Written comment (04/20/05) ML051390190 2110

DW-1238 Robin Rabens Written comment (04/08/05) ML051390190 2111

DW-1239 Bryan Chauveau Written comment (04/08/05) ML051390190 2112

DW-1240 Yvonne Vecchia Written comment (03/28/05) ML051390190 2113

DW-1241 Virginia Brown Written comment (03/25/05) ML051390190 2114

DW-1242 Amber Ostheimer Written comment (03/25/05) ML051390190 2115
Comment

Number Commenter Name Source

Accession

Number

Page

Number

(for DWs

only)

December 2006 NUREG-1811, Volume II 6-61

DW-1243 Neah Monteiro Written comment (03/24/05) ML051390190 2116

DW-1244 Lindsay Broockman Written comment (03/23/05) ML051390190 2117

DW-1245 Bruce Flinchum Written comment (03/15/05) ML051390190 2118

DW-1246 Michaela Starrett Written comment (03/13/05) ML051390190 2119

DW-1247 Joe Porfert Written comment (03/13/05) ML051390190 2120

DW-1248 Bill R. Teer Written comment (03/09/05) ML051390190 2121

DW-1249 M. A. Jones Written comment (03/08/05) ML051390190 2122

DW-1250 Joanna Gras Written comment (03/08/05) ML051390190 2123

DW-1251 Joel Boggan Written comment (03/08/05) ML051390190 2124

DW-1252 Robin Dina Written comment (03/08/05) ML051390190 2125

DW-1253 Ann Volk Written comment (03/08/05) ML051390190 2126

DW-1254 Jimmy Brooks Written comment (03/07/05) ML051390190 2127

DW-1255 Jessica Mottley Written comment (03/07/05) ML051390190 2128

DW-1256 Michael Cavanaugh Written comment (03/07/05) ML051390190 2129

DW-1257 Jill Bender Written comment (03/07/05) ML051390190 2130

DW-1258 John Alge Written comment (03/07/05) ML051390190 2131

DW-1259 Joyce and Terry Fernandez Written comment (03/07/05) ML051390190 2132

DW-1260 Carla Mathews Written comment (03/07/05) ML051390190 2133

DW-1261 Britta Gustavson Written comment (03/07/05) ML051390190 2134

DW-1262 Susan Keith Written comment (03/07/05) ML051390190 2135

DW-1263 James Heater Written comment (03/07/05) ML051390190 2136

DW-1264 Holy Holily Holian Written comment (03/07/05) ML051390190 2137

DW-1265 James M. Nordlund Written comment (03/07/05) ML051390190 2138

DW-1266 Billie Reed Written comment (03/07/05) ML051390190 2139

DW-1267 David Dunkleberger Written comment (03/07/05) ML051390190 2140

DW-1268 Felicia VanderBranden Written comment (03/07/05) ML051390190 2141

DW-1269 Diana Martz Written comment (03/07/05) ML051390190 2142

DW-1270 Mary E. McGilligan Written comment (04/06/05) ML051390190 2143

DW-1271 Michelle Parker Written comment (03/14/05) ML051390190 2144

DW-1272 William Arguto, U.S.

Environmental Protection

Agency

Written comment (04/11/05) ML051390190 2145

DW-1273 Jeanne and John Evans Written comment (04/13/05) ML051390190 2148

Table 6-3. Draft EIS Mass Mailing Cross-Reference List

Comment Document ID Last Name First Name

DMM-1 DW-0029 Rood Heidi

DMM-1A DW-0007 Richards Ron

DMM-1A DW-0011 Riley Kelly

DMM-1A DW-0012 Williams Marilyn

DMM-1A DW-0015 Leonard Andrew

DMM-1A DW-0017 Janicki Andrew

DMM-1A DW-0020 Wilson Beka

DMM-1A DW-0021 Burgess Kim

DMM-1A DW-0024 Rosenkrantz Stewart

DMM-1A DW-0026 Kay Thomas
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-62

DMM-1A DW-0027 Lightfoot Stacey

DMM-1A DW-0033 Cole Merrill

DMM-1A DW-0034 Laffey Kevin

DMM-1A DW-0036 Johnson Mark

DMM-1A DW-0038 Beuttenmueller Nate

DMM-1A DW-0039 McCradic Kris

DMM-1A DW-0041 Vaught Kevin

DMM-1A DW-0045 Waltman Martha

DMM-1A DW-0048 Alvarez Charles

DMM-1A DW-0049 Raghav shyla

DMM-1A DW-0050 Spotts Richard

DMM-1A DW-0052 Atwood Rachel

DMM-1A DW-0053 Herner Betty Jean

DMM-1A DW-0058 Reed Ben

DMM-1A DW-0065 Watson Claire

DMM-1A DW-0073 Eichert Sandy

DMM-1A DW-0077 Kempton Roger

DMM-1A DW-0079 Hargrove Christopher

DMM-1A DW-0086 Palladine Michelle

DMM-1A DW-0087 Finkelnburg Doug

DMM-1A DW-0091 Pfeffer Chell D

DMM-1A DW-0094 Cimino Andrea

DMM-1A DW-0096 Blumeenau Audrey

DMM-1A DW-0098 Lemmon Sara

DMM-1A DW-0100 Jerbi Steve

DMM-1A DW-0102 Aguilar Felix

DMM-1A DW-0106 Jong Katarzyna

DMM-1A DW-0107 Feldman Brett

DMM-1A DW-0117 Hirose Mary

DMM-1A DW-0119 Head Jim

DMM-1A DW-0120 Graham Ariel

DMM-1A DW-0121 Williams Paul

DMM-1A DW-0128 Allen Monica

DMM-1A DW-0133 Schmidt Tavis

DMM-1A DW-0138 Graham Kimberley

DMM-1A DW-0139 Silverman Seth

DMM-1A DW-0141 Neil Michael

DMM-1A DW-0145 Toal Hollis

DMM-1A DW-0149 Wolff Katie

DMM-1A DW-0151 Carrubba Sandra

DMM-1A DW-0156 Carter L.

DMM-1A DW-0158 Fish Michael

DMM-1A DW-0161 Krueger Douglas

DMM-1A DW-0166 Williamson Sandra

DMM-1A DW-0168 Frankel-Streit Sue

DMM-1A DW-0174 Corriere Caryn

DMM-1A DW-0189 Shipler Mandy

DMM-1A DW-0202 Asselin Neil
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-63

DMM-1A DW-0207 Eichert Sandy

DMM-1A DW-0208 Bennett Michael

DMM-1A DW-0210 Holz Rdolfo

DMM-1A DW-0214 Louis Rebecca

DMM-1A DW-0217 Duprey Renee

DMM-1A DW-0221 Kendall Sarah

DMM-1A DW-0225 Wood Barbara

DMM-1A DW-0227 Blumeenau Audrey

DMM-1A DW-0230 Rosenkrantz Stewart

DMM-1A DW-0233 Gathing Nancy

DMM-1A DW-0234 Aguilar Felix

DMM-1A DW-0236 Stanley Marlene

DMM-1A DW-0240 Riley Kelly

DMM-1A DW-0243 Spotts Richard

DMM-1A DW-0245 Crooks Amber

DMM-1A DW-0247 Walters Laura

DMM-1A DW-0250 Rhoads Kirk

DMM-1A DW-0255 Johnston Timothy

DMM-1A DW-0260 Johnson Vicki

DMM-1A DW-0264 Palladine Michelle

DMM-1A DW-0267 Simpson Sally

DMM-1A DW-0268 Watson Claire

DMM-1A DW-0271 Wright Warren

DMM-1A DW-0275 Wilcox David

DMM-1A DW-0278 Barnhart Brenda

DMM-1A DW-0282 Derosier Chad

DMM-1A DW-0284 Lightfoot Stacey

DMM-1A DW-0287 Spears Nancy

DMM-1A DW-0288 Khan-Bureau Diba

DMM-1A DW-0289 Burkhart David

DMM-1A DW-0291 Feldman Brett

DMM-1A DW-0292 McAnally Elizabeth

DMM-1A DW-0294 Harris Sarah

DMM-1A DW-0298 Dalton Gerald

DMM-1A DW-0302 Shematek Judith

DMM-1A DW-0303 Adams Antje

DMM-1A DW-0306 Kopp Helen

DMM-1A DW-0311 Fotos Janet

DMM-1A DW-0312 Bessette Bree

DMM-1A DW-0315 Smakal Shaun

DMM-1A DW-0319 Schild Rebecca

DMM-1A DW-0320 Fairman David

DMM-1A DW-0322 Ward Sheila

DMM-1A DW-0328 Laffey Kevin

DMM-1A DW-0331 Petren Conor

DMM-1A DW-0332 Robbins Carlon

DMM-1A DW-0334 Weller Kristina

DMM-1A DW-0336 Spitkovskaya Marina
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-64

DMM-1A DW-0339 Calkins Stephen

DMM-1A DW-0340 Reed Ben

DMM-1A DW-0345 Butch Lisa

DMM-1A DW-0350 Fongemie Ned

DMM-1A DW-0354 Cassidy Virginia

DMM-1A DW-0358 Lundemo Charlotte

DMM-1A DW-0367 Flood RaVani

DMM-1A DW-0371 Indermuehle Eric

DMM-1A DW-0377 Costello Patirck

DMM-1A DW-0379 Brackett Carl

DMM-1A DW-0383 Rogers Marliss

DMM-1A DW-0389 Hamil Rebecca

DMM-1A DW-0393 Allard Nicole

DMM-1A DW-0394 Graham Ariel

DMM-1A DW-0396 Heinitz Steven

DMM-1A DW-0707 Lundemo Charlotte

DMM-1A DW-0723 Spahn Chris

DMM-1A DW-0724 Radloff Juliana

DMM-1A DW-0732 Winalski Dawn

DMM-1A DW-0733 Sorensen Dina

DMM-1A DW-0736 Maziak Anne

DMM-1A DW-0737 Yong Soler Ana

DMM-1A DW-0740 Grant Kathleen

DMM-1A DW-0742 Sette Diana

DMM-1A DW-0746 Boughan Tom

DMM-1A DW-0755 Clayton Kirk

DMM-1A DW-0756 Oxyer Jim

DMM-1A DW-0763 Miller Dianne

DMM-1A DW-0764 Butcher Brian

DMM-1A DW-0768 Lafoillette Pete

DMM-1A DW-0771 Corriere Caryn

DMM-1A DW-0778 Peters Emily and Jeremy

DMM-1A DW-0785 Hampton Dottie

DMM-1A DW-0788 Johnston Anne

DMM-1A DW-0796 Worshek Frank

DMM-1A DW-0803 Chenore Todd

DMM-1A DW-0804 Bond Julie

DMM-1A DW-0819 Heberlein Jenny

DMM-1A DW-1240 Vecchia Yvonne

DMM-1A DW-1246 Starrett Michaela

DMM-1B DW-0002 Snyder Amanda

DMM-1B DW-0006 Rutkowski Robert

DMM-1B DW-0014 Mendoza Ana Najera

DMM-1B DW-0018 Winalski Dawn

DMM-1B DW-0022 Sims Stephanie

DMM-1B DW-0030 Sjolin Sue

DMM-1B DW-0032 Matlock KL

DMM-1B DW-0037 Bensinger Lesley

DMM-1B DW-0040 Wood Barbara L
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-65

DMM-1B DW-0056 Spitkovskaya Marina

DMM-1B DW-0060 Matsuda Thomas

DMM-1B DW-0062 Rockey Phillip

DMM-1B DW-0067 Kendall Sarah

DMM-1B DW-0068 Singer Barbara

DMM-1B DW-0078 Burack Debbie

DMM-1B DW-0080 Brown Jamie

DMM-1B DW-0081 Wagner Sandra

DMM-1B DW-0082 Foss Janice

DMM-1B DW-0083 Carlson Judith

DMM-1B DW-0084 Dalton Jerry

DMM-1B DW-0085 Sanchez Anthony

DMM-1B DW-0089 Holeman Heidi

DMM-1B DW-0090 Ward Sheila

DMM-1B DW-0092 Welch Joanna F

DMM-1B DW-0095 Golden Rebecca

DMM-1B DW-0097 Keefer Nina

DMM-1B DW-0103 Harrell Linda

DMM-1B DW-0109 Reback Mark

DMM-1B DW-0112 York Linda

DMM-1B DW-0113 Prostko Linda

DMM-1B DW-0118 Smith Sharon

DMM-1B DW-0123 Beier Mary

DMM-1B DW-0126 Mathewson M.

DMM-1B DW-0127 Jackson Tom

DMM-1B DW-0130 Maness Mitchell

DMM-1B DW-0132 McGlone Colleen

DMM-1B DW-0135 DeAntoni Carol

DMM-1B DW-0137 Tarek Lynn

DMM-1B DW-0144 Sette Diana

DMM-1B DW-0146 Watson Claire

DMM-1B DW-0150 Gourguechon Simone

DMM-1B DW-0152 Golden Rebecca

DMM-1B DW-0153 Clayton Kirk

DMM-1B DW-0154 Corriere Caryn

DMM-1B DW-0159 Johnston Timothy

DMM-1B DW-0163 Butcher Brian

DMM-1B DW-0165 Boylan Brianne

DMM-1B DW-0167 Hoke Dee

DMM-1B DW-0169 Johnson Kerry

DMM-1B DW-0170 Bouyea Lauren

DMM-1B DW-0200 Reback Mark

DMM-1B DW-0201 Albright Evan

DMM-1B DW-0203 Burkhardt Kerry

DMM-1B DW-0204 Burgess Kim

DMM-1B DW-0211 Williams Paul

DMM-1B DW-0212 Matthew Elaine

DMM-1B DW-0213 Fuerst Liz
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-66

DMM-1B DW-0216 Campbell Victoria

DMM-1B DW-0218 Cook David

DMM-1B DW-0222 Pope Sarah

DMM-1B DW-0223 Schweppe Linda

DMM-1B DW-0224 Books Kim

DMM-1B DW-0226 Green Jason

DMM-1B DW-0229 Richards Ron

DMM-1B DW-0231 Summers Steve

DMM-1B DW-0232 Mihok Michael

DMM-1B DW-0238 Jackson Tom

DMM-1B DW-0239 Vaught Kevin

DMM-1B DW-0241 Evans Michael

DMM-1B DW-0242 Williams Richard

DMM-1B DW-0248 Roberts Jon

DMM-1B DW-0251 Stober Paula

DMM-1B DW-0254 Williams Craig

DMM-1B DW-0257 Golembieski John

DMM-1B DW-0258 Kempton Roger

DMM-1B DW-0259 Phillips Scot

DMM-1B DW-0262 Conroy Peggy

DMM-1B DW-0270 Snelgrove Chelsea

DMM-1B DW-0277 Hohenberg Adrienne

DMM-1B DW-0281 Sims Stephanie

DMM-1B DW-0283 Leahy Martha

DMM-1B DW-0285 Arcure Barbara

DMM-1B DW-0290 Davis Ryan

DMM-1B DW-0304 Foss Janice

DMM-1B DW-0307 McGlone Colleen

DMM-1B DW-0308 Heavilin Jennifer

DMM-1B DW-0310 Smith Sharon

DMM-1B DW-0317 Blunt Susanna

DMM-1B DW-0318 Costa Demelza

DMM-1B DW-0324 Roberson Keegan

DMM-1B DW-0326 Facette James

DMM-1B DW-0329 Salomon Sherry

DMM-1B DW-0335 Moore Matt

DMM-1B DW-0337 Fransson Dorothea

DMM-1B DW-0338 Rosenfeld Cheryl

DMM-1B DW-0341 Schneller Paul

DMM-1B DW-0348 Totino Nicole

DMM-1B DW-0351 Esteve Gregory

DMM-1B DW-0353 Esseltine M.

DMM-1B DW-0355 East Khaalen

DMM-1B DW-0356 Pederslie Sharon

DMM-1B DW-0357 Schneider Kelly

DMM-1B DW-0362 Friedman Ariela

DMM-1B DW-0363 Keefer Nina

DMM-1B DW-0364 Pick Alva
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-67

DMM-1B DW-0366 McGlone Gail

DMM-1B DW-0372 Garnett Mike

DMM-1B DW-0376 Sun Nida

DMM-1B DW-0380 Bhatia Rachana

DMM-1B DW-0382 Felker III Dale Richard

DMM-1B DW-0384 Carrubba Sandra

DMM-1B DW-0386 McGilligan Mary

DMM-1B DW-0390 Korenak Kelly

DMM-1B DW-0391 Rieber Emily

DMM-1B DW-0392 Butcher Brian

DMM-1B DW-0720 Rettiger Charles

DMM-1B DW-0721 Venema Eve

DMM-1B DW-0725 Bond Julie

DMM-1B DW-0727 Doob Jennifer

DMM-1B DW-0730 Jennings Beverly

DMM-1B DW-0731 Napps Shirley

DMM-1B DW-0734 Penn Angela

DMM-1B DW-0738 Khalsa Mha Atma

DMM-1B DW-0743 Hebeisen Brian

DMM-1B DW-0747 Watson Claire

DMM-1B DW-0748 Van Wicklen Betty

DMM-1B DW-0751 Christiansen Erin

DMM-1B DW-0753 Harris Ed

DMM-1B DW-0754 Alberda Linda

DMM-1B DW-0758 Funsinn Sydney

DMM-1B DW-0759 Peeplez Kelle

DMM-1B DW-0762 Pakeltis Carolynn

DMM-1B DW-0765 Neil Michael

DMM-1B DW-0767 Aleman Micheal

DMM-1B DW-0769 Sharp Kimberley

DMM-1B DW-0779 Wood Susannah

DMM-1B DW-0784 Curran Carol

DMM-1B DW-0787 Gilchrist Elizabeth

DMM-1B DW-0790 jackson Melanie

DMM-1B DW-0795 Huff Julie

DMM-1B DW-0799 Bastian Sally

DMM-1B DW-0809 Swartzbaugh Josh

DMM-1B DW-0810 Davies Beth

DMM-1B DW-1238 Rabens Robin

DMM-1B DW-1244 Broockman Lindsay

DMM-1B DW-1245 Flinchum Bruce

DMM-1B DW-1270 McGilligan Mary

DMM-1C DW-0001 Sideris Jean

DMM-1C DW-0003 Sigmond Chandra

DMM-1C DW-0004 Felker Dale Richard

DMM-1C DW-0005 Balboa Alex

DMM-1C DW-0008 Davis Ryan

DMM-1C DW-0009 Buck Peter
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-68

DMM-1C DW-0010 Dunne Stephen

DMM-1C DW-0013 Patrick Meaghan

DMM-1C DW-0016 Soza Valerie

DMM-1C DW-0019 Field Elizabeth

DMM-1C DW-0023 Spears Nancy

DMM-1C DW-0025 Van Wicklen Betty J.

DMM-1C DW-0028 Devitt Ed

DMM-1C DW-0031 Bennett Michael

DMM-1C DW-0035 Kilcoyne Clancey

DMM-1C DW-0042 Summers Steve

DMM-1C DW-0043 Simpson Sally

DMM-1C DW-0044 Leahy Martha

DMM-1C DW-0046 Anderson Corina

DMM-1C DW-0047 Maness Mitchell

DMM-1C DW-0051 Fransson Dorothea

DMM-1C DW-0054 Burkhardt Kerry

DMM-1C DW-0055 Goldstone Beth

DMM-1C DW-0059 Mikulski Kathleen

DMM-1C DW-0061 Ballentine Wanda S.

DMM-1C DW-0063 Wright Warren

DMM-1C DW-0064 Asselin Neil

DMM-1C DW-0066 Mihok Michael

DMM-1C DW-0069 East Khaalen

DMM-1C DW-0070 Evans Michael

DMM-1C DW-0071 Kimbrough Jane

DMM-1C DW-0072 Hardy Ann

DMM-1C DW-0074 Moumin Adrienne

DMM-1C DW-0075 Rhoads Kirk

DMM-1C DW-0076 Phillips Scot

DMM-1C DW-0093 Larch Patricia

DMM-1C DW-0099 Cassidy Virginia

DMM-1C DW-0101 Torres Julio

DMM-1C DW-0104 Irwin Ken

DMM-1C DW-0105 Esteve Gregory

DMM-1C DW-0108 Heavilin Jennifer

DMM-1C DW-0110 Snelgrove Chelsea

DMM-1C DW-0111 Frontz Jeffri

DMM-1C DW-0115 Campbell Victoria

DMM-1C DW-0116 McConnell Lindsey

DMM-1C DW-0122 Harris Sarah

DMM-1C DW-0124 Jaramillo Paula

DMM-1C DW-0125 Moore Matt

Extracted from 

DMM-1C

DW-0129 Flowers Babbie Dee

DDMM-1C DW-0131 Barnes Sherry

DMM-1C DW-0134 Doob Jennifer

DMM-1C DW-0136 McGlone Gail

DMM-1C DW-0140 Kelly Wayne
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-69

DMM-1C DW-0142 Randall David

DMM-1C DW-0143 Patrick A.

DMM-1C DW-0147 Venema Eve

DMM-1C DW-0148 Shamo Erika

DMM-1C DW-0155 Williams Craig

DMM-1C DW-0157 Spears Nancy

DMM-1C DW-0160 Zalewski K

DMM-1C DW-0162 Hebeisen Brian

DMM-1C DW-0164 Day Elena

DMM-1C DW-0171 Cutlip Jana

DMM-1C DW-0172 Johnson Bill

DMM-1C DW-0175 Lafoillette Pete

DMM-1C DW-0176 Skolnick Kate

DMM-1C DW-0178 Doswell Carolyn

DMM-1C DW-0179 Costigan Cheryl

DMM-1C DW-0184 McFadden Wendy

DMM-1C DW-0199 Matsuda Thomas

DMM-1C DW-0205 Anderson Corina

DMM-1C DW-0206 Hutchinson Terrance

DMM-1C DW-0209 Burack Debbie

DMM-1C DW-0215 Patrick Meaghan

DMM-1C DW-0219 Maya Francisco

DMM-1C DW-0220 Seltzer Robert

DMM-1C DW-0228 Welch Joanna

DMM-1C DW-0235 Alvarez Charles

DMM-1C DW-0237 Waltman Martha

DMM-1C DW-0244 Trew Jason

DMM-1C DW-0246 Meder Christopher

DMM-1C DW-0249 Gore Jesse

DMM-1C DW-0252 Balboa Alex

DMM-1C DW-0253 LaFleur Bill

DMM-1C DW-0256 Kawar Ferris

DMM-1C DW-0263 Robertson John

DMM-1C DW-0265 Pott Caronlin

DMM-1C DW-0269 Krewson Dale

DMM-1C DW-0272 Raghav Shyla

DMM-1C DW-0273 Kimbrough Jane

DMM-1C DW-0274 Brook Dan

DMM-1C DW-0276 Soza Valerie

DMM-1C DW-0279 Evans Dinda

DMM-1C DW-0280 Allen Monica

DMM-1C DW-0286 Rico Carmen

DMM-1C DW-0293 Gartland Brandi

DMM-1C DW-0295 Shamo Erika

DMM-1C DW-0296 Herndon Laura

DMM-1C DW-0297 Krueger Douglas

DMM-1C DW-0299 Jong Katarzyna

DMM-1C DW-0300 Phan Peggy
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-70

DMM-1C DW-0301 Woodward Mary

DMM-1C DW-0305 McComas Barney

DMM-1C DW-0313 Ingle John

DMM-1C DW-0314 Boltz Gina

DMM-1C DW-0316 Patrick A.

DMM-1C DW-0321 Bell Ray

DMM-1C DW-0323 Johnson Candace

DMM-1C DW-0325 Tiffault Matthew

DMM-1C DW-0327 Moumin Adrienne

DMM-1C DW-0330 Wilson Amy

DMM-1C DW-0342 Santana Maritza

DMM-1C DW-0343 Flowers Bobbie Dee

DMM-1C DW-0344 Irwin Ken

DMM-1C DW-0346 Silverman Seth

DMM-1C DW-0347 Evans Alma

DMM-1C DW-0349 Mikulski Kathy

DMM-1C DW-0352 Mens Eric

DMM-1C DW-0359 Janicki Andrew

DMM-1C DW-0361 Horst Rene

DMM-1C DW-0365 Hunt Mitchell

DMM-1C DW-0368 Pasichnyk Richard

DMM-1C DW-0369 Bonsignore Victoria

DMM-1C DW-0373 Unger Kris

DMM-1C DW-0374 Kay Thomas

DMM-1C DW-0375 Kelly Wayne

DMM-1C DW-0378 Kaplan Claire

DMM-1C DW-0381 Van Buren Sarah

DMM-1C DW-0385 Costigan Cheryl

DMM-1C DW-0387 Cimino Andrea

DMM-1C DW-0388 Hirose Mary

DMM-1C DW-0395 Maness Mitchell

DMM-1C DW-0689 Miller Ruth

DMM-1C DW-0696 Appia Michael

DMM-1C DW-0715 Spears Nancy

DMM-1C DW-0719 Lafoillette Pete

DMM-1C DW-0722 Schmidt Tavis

DMM-1C DW-0726 Sievers-Bartlett Suzanne

DMM-1C DW-0728 Singer Barbara

DMM-1C DW-0735 York Linda

DMM-1C DW-0739 McCradic Kris

DMM-1C DW-0745 Prostko Linda

DMM-1C DW-0752 Covey John

DMM-1C DW-0761 Boswell Julie

DMM-1C DW-0766 Boitano Connie

DMM-1C DW-0770 Frontz Jeffri

DMM-1C DW-0772 McFadden Wendy

DMM-1C DW-0773 Tawnamia Leslie

DMM-1C DW-0774 Malloy Ben
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-71

DMM-1C DW-0775 Von Gehr Anna

DMM-1C DW-0776 Duffy Claudia

DMM-1C DW-0780 Peckman Bob

DMM-1C DW-0781 Boswell Linda

DMM-1C DW-0782 Grossman Jeffery

DMM-1C DW-0786 Zahnke Coleen

DMM-1C DW-0792 Salidis Joanna

DMM-1C DW-0794 Cleve Della

DMM-1C DW-0801 Sawdon Rosemarie

DMM-1C DW-0813 Boyle Katie

DMM-1C DW-0814 McDonald Marion

DMM-1C DW-0824 Kesich John

DMM-1C DW-0828 Smith John Patrick

DMM-1C DW-1236 Warren Cassandra

DMM-1C DW-1242 Ostheimer Amber

DMM-1C DW-1243 Monteiro Neah

Extracted from DMM-2 DW-0397 Aguilar Lauren

Extracted from DMM-2 DW-0401 Taverna Kristin

DMM-2 DW-0402 Shaw Elaine

DMM-2 DW-0418 Pipik Joseph

DMM-2 DW-0419 Eichorst Aaron

DMM-2 DW-0420 Gore Mary Jand

DMM-2 DW-0433 Sitzer Shelly

DMM-2 DW-0434 Fitzgerald Anna

DMM-2 DW-0543 Wetherington Jared

DMM-2 DW-0547 Fredericks Misha

DMM-2 DW-0573 Butler Kirk

Extracted from DMM-2 DW-0617 Freeman Matthew

DMM-2 DW-0654 Gyovai Christine

DMM-2 DW-0656 Muehlman Reed

DMM-2 DW-0805 Hall Bodie Charles and

Adrienne

Extracted from DMM-2 DW-0808 Kroiz Samuel

DMM-2 DW-0881 Payne Dexter

DMM-2 DW-0885 Carlson Alan

DMM-2 DW-0919 Rutkowski Robert

DMM-2 DW-0926 Chieco Eileen and Victor

DMM-2 DW-0927 Santerre Roger

DMM-2 DW-0930 Eldon jim

DMM-2 DW-0932 Venneman Joetta

DMM-2 DW-0933 Marciniak Peter and

Catherine

DMM-2 DW-0935 Wampler Timothy

DMM-2 DW-0948 Diedrich Charltte

DMM-2 DW-1025 Prusik D

DMM-2 DW-1030 Hunter Aurora

DMM-2 DW-1032 Austin Christopher

DMM-2 DW-1035 Nidess Rael

DMM-2 DW-1038 Milliner Susan
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-72

DMM-2 DW-1044 Longacre David

DMM-2 DW-1052 Marchini Juan

DMM-2 DW-1053 Peterson Ron

DMM-2 DW-1093 Darnall Lyn

DMM-2 DW-1100 Roberta Thurstin Don Timmerman

DMM-2 DW-1103 Reback Mark

DMM-2 DW-1232 Sullivan Barbara

DMM-3 DW-0427 Bigler H. Paul

DMM-3 DW-0428 Redding Sherley

DMM-3 DW-0436 Lenehan David

DMM-3 DW-0446 Stenbjorn Paul

DMM-3 DW-0447 Schmidt Arthur

DMM-3 DW-0448 Richards William

DMM-3 DW-0449 Eichenberger Patricia

DMM-3 DW-0450 Chancey Kevin

DMM-3 DW-0451 Sistok-Katz Silja

DMM-3 DW-0452 Clark Loralee

DMM-3 DW-0454 Parker Diana

DMM-3 DW-0455 Laverdiere Dorothy

DMM-3 DW-0457 Hepler Sarah

DMM-3 DW-0458 Pierce Lawrence

DMM-3 DW-0460 Kim Pamela

DMM-3 DW-0461 Baldino Rhea

DMM-3 DW-0465 Masters James

DMM-3 DW-0468 Sund Christian

DMM-3 DW-0470 Anthony Joseph Patrick

DMM-3 DW-0473 Mills Stephen

DMM-3 DW-0475 Campbell David

DMM-3 DW-0477 Davis Susan

DMM-3 DW-0478 C Lori

DMM-3 DW-0479 Lotz Jonathan

DMM-3 DW-0480 Jameson Anne

DMM-3 DW-0481 Anderson Stephen

DMM-3 DW-0482 Mann Louise

DMM-3 DW-0483 Joseph Kathy

DMM-3 DW-0485 Marshall Lisa

DMM-3 DW-0486 Meister Margaret

DMM-3 DW-0487 Martin Barbara

DMM-3 DW-0488 Lewis Cornelia

DMM-3 DW-0489 Hanson Linda

DMM-3 DW-0490 Collins Fletcher

DMM-3 DW-0492 Bowman Jacqueline

DMM-3 DW-0493 Re Nancy

DMM-3 DW-0494 Hoffman Lilli

DMM-3 DW-0495 Desrosiers Martha

DMM-3 DW-0496 Rose Carol

DMM-3 DW-0498 Coleman Darlene

DMM-3 DW-0499 Wellman Donna
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-73

DMM-3 DW-0501 Shematek Judith

DMM-3 DW-0502 Feitlinger Ross

DMM-3 DW-0503 Nicholas Chris

DMM-3 DW-0505 Campbell Matthew

DMM-3 DW-0508 Morgan Katherine

DMM-3 DW-0509 Lavy Fred

DMM-3 DW-0511 Albert Martin

DMM-3 DW-0512 Foster Ariele

DMM-3 DW-0513 Reif Mark

DMM-3 DW-0514 Dietch Pat

DMM-3 DW-0515 Wilcox James

DMM-3 DW-0516 Knapp Robbin

DMM-3 DW-0517 Cecil Joe

DMM-3 DW-0519 Rapice Robert

DMM-3 DW-0520 Hodge Mary

DMM-3 DW-0521 Alfano Karla

DMM-3 DW-0522 Bell Carrie

DMM-3 DW-0523 Shawn Jason

DMM-3 DW-0524 Collins Janet

DMM-3 DW-0525 Snyder Kelly

DMM-3 DW-0526 Dogget Karin

DMM-3 DW-0527 Campbell Kenneth

DMM-3 DW-0532 Garcia Yvonne

DMM-3 DW-0534 Economou Constantina

DMM-3 DW-0535 Krochalis Andrea

DMM-3 DW-0536 Bui Thuy-Vy

DMM-3 DW-0537 Adamson Nancy

DMM-3 DW-0538 Mitchell David

DMM-3 DW-0539 Trew Jason

DMM-3 DW-0541 Hayes Gina

DMM-3 DW-0542 Adams Lynn

DMM-3 DW-0544 Doggett Gregory

DMM-3 DW-0545 Grubb Ricky

DMM-3 DW-0546 Harsahw Elizabeth

DMM-3 DW-0548 Poisson Laura

DMM-3 DW-0550 Stoner Gary

DMM-3 DW-0551 Prez Roberto

DMM-3 DW-0552 Knorr Sarah

DMM-3 DW-0553 Sexson John

DMM-3 DW-0555 Sloan Richard

DMM-3 DW-0556 Barger Elizabeth

DMM-3 DW-0557 Gillespie Sarah

DMM-3 DW-0559 Mooney Shaun

DMM-3 DW-0560 Bodnaruk Dan

DMM-3 DW-0563 East Lorah

DMM-3 DW-0565 York Stasi

DMM-3 DW-0566 Cox Joel

DMM-3 DW-0567 Johnson Susan
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-74

DMM-3 DW-0570 Gorka Mary

DMM-3 DW-0572 Conroy James

DMM-3 DW-0574 Gregory Probyn

DMM-3 DW-0576 Main Ivy

DMM-3 DW-0577 Lackey Mark

DMM-3 DW-0578 Jones Lauren

DMM-3 DW-0585 Malore Devan

DMM-3 DW-0587 Langslow Ken

DMM-3 DW-0590 Presgraves Andrew

DMM-3 DW-0591 Roach Margaret

DMM-3 DW-0592 Smith Kevin

DMM-3 DW-0595 Town Andrew

DMM-3 DW-0597 Shea John

DMM-3 DW-0598 Hans Alicia

DMM-3 DW-0599 Parker James

DMM-3 DW-0600 Katsos Kat

DMM-3 DW-0603 Athavale Anjali

DMM-3 DW-0606 May Annette

DMM-3 DW-0607 Shank Tim

DMM-3 DW-0609 Krickson Robyn

DMM-3 DW-0610 Wiley Brenda

DMM-3 DW-0611 Day Kathy

DMM-3 DW-0616 Borgersen Eric

DMM-3 DW-0619 Archard Lee

DMM-3 DW-0622 Kalukin Andrew

DMM-3 DW-0624 Apperson Carlton

DMM-3 DW-0627 Baldwin Keith

DMM-3 DW-0629 Watkins Robin

DMM-3 DW-0634 Johnson Letitia

DMM-3 DW-0635 Sarli Leonardo

DMM-3 DW-0636 Jeffries Don

DMM-3 DW-0643 Biernot Gretchen

DMM-3 DW-0647 Byrne Sarah

DMM-3 DW-0651 Asman Nancy

DMM-3 DW-0652 Sawdon Rosemarie

DMM-3 DW-0658 Jurasits Cassie

DMM-3 DW-0659 Cox Katrina

DMM-3 DW-0660 Kardan Jay

DMM-3 DW-0662 McFarland Mary Ann

DMM-3 DW-0663 Gallagher Brian

DMM-3 DW-0666 McMillan Tisha

DMM-3 DW-0670 Simo Jamie

DMM-3 DW-0671 Pederson Michaelene

DMM-3 DW-0673 Clark Beth

DMM-3 DW-0683 Dammarell Kathy

DMM-3 DW-0687 Taplin Heather

DMM-3 DW-0688 Ma OlmosC Jose

DMM-3 DW-0690 Ackerman John and Kim
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-75

DMM-3 DW-0691 Heinekamp Roselind

DMM-3 DW-0692 Schindl Kerry

DMM-3 DW-0693 Doering Lorna

DMM-3 DW-0694 Hoodwin Marcia

DMM-3 DW-0695 Jaffe Alicia

DMM-3 DW-0697 Calhoun Joseph

DMM-3 DW-0698 Sterlin Rachael

DMM-3 DW-0699 Boone David

DMM-3 DW-0700 Miller Griff

DMM-3 DW-0701 Hansen Carsten

DMM-3 DW-0702 Hammond Frank

DMM-3 DW-0703 Brady Sean

DMM-3 DW-0704 Evert Devin

DMM-3 DW-0705 Allen Michael

DMM-3 DW-0706 Kissel Julie

DMM-3 DW-0708 Surowski Dawn

DMM-3 DW-0709 Stollenwerk Mia

DMM-3 DW-0710 Stahl Edgar

DMM-3 DW-0711 Miller Glenn

DMM-3 DW-0712 Froome Roberta

DMM-3 DW-0713 Legler Matt

DMM-3 DW-0714 Osorne Carla

DMM-3 DW-0716 Randolph Dee

DMM-3 DW-0717 Annanthakrishnan Revathi

DMM-3 DW-0718 Bernatz Rachel

DMM-3 DW-0850 Goodman Michael

DMM-3 DW-0852 Bernier Michael

DMM-3 DW-0853 Pooler Jason

DMM-3 DW-0854 Salisbury Michelle

DMM-3 DW-0855 Palmquist Elaine

DMM-3 DW-0860 Williams Martha

DMM-3 DW-0862 Wehner Michaela

DMM-3 DW-0868 Dukovich John

DMM-3 DW-0869 Wise Sarah

DMM-3 DW-0870 Roth David

DMM-3 DW-0871 Unger Kris

DMM-3 DW-0873 Whetstone Joe

DMM-3 DW-0891 Hayden Sue

DMM-3 DW-0897 Engle Eliza Beth

DMM-3 DW-0898 Murphy Margaret

DMM-3 DW-0899 Rakes Karen

DMM-3 DW-0900 Morgan John

DMM-3 DW-0901 Hagood Talbott

DMM-3 DW-0902 Hochstadt Ted

DMM-3 DW-0904 Keeton III Dewey

DMM-3 DW-0906 Brazier Katie

DMM-3 DW-0907 Obrion Catherine

DMM-3 DW-0908 Hill Walter
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-76

DMM-3 DW-0909 Meier Rich

DMM-3 DW-0910 Adams Roger

DMM-3 DW-0911 Carper Cindy

DMM-3 DW-0912 Davis John

DMM-3 DW-0913 Green Jason

DMM-3 DW-0914 Lutjen Kristy

DMM-3 DW-0915 Mitchell Roy

DMM-3 DW-0916 Quesinberry Abigail

DMM-3 DW-1012 Pitre Julia

DMM-3 DW-1114 Spotts Richard

DMM-3 DW-1115 Gray Maurene

DMM-3 DW-1117 Spencer Karen

DMM-3 DW-1118 Kupsaw Wendy

DMM-3 DW-1119 Quick Jill

DMM-3 DW-1120 Decker Jerome

DMM-3 DW-1123 Johnson Brock

DMM-3 DW-1124 Hitchcock-Hodgson Ceri

DMM-3 DW-1125 Stufflebeam Judy

DMM-3 DW-1126 Sullivan Alice

DMM-3 DW-1127 Leavitt David

DMM-3 DW-1128 Zizzo James

DMM-3 DW-1129 Hartleben Chris

DMM-3 DW-1130 Holberg Ronald

DMM-3 DW-1132 Gathing Nancy

DMM-3 DW-1133 Plummber Vicotria

DMM-3 DW-1134 Ponisciak Joseph

DMM-3 DW-1135 Courter Matthew

DMM-3 DW-1136 Burris Lori

DMM-3 DW-1138 Kennedy Mark

DMM-3 DW-1139 Gliem Deke

DMM-3 DW-1140 Blackwood Jean

DMM-3 DW-1141 Herdez Amber

DMM-3 DW-1142 Roka Ruthann

DMM-3 DW-1143 Early Gordon

DMM-3 DW-1144 Kurland Miriam

DMM-3 DW-1145 Blackwood Krista

DMM-3 DW-1146 Sweeney Shannon

DMM-3 DW-1147 Culp Steven

DMM-3 DW-1150 Jorgensen James

DMM-3 DW-1152 Perlman France

DMM-3 DW-1153 Wright Sharon

DMM-3 DW-1155 O'Keefe Margaret

DMM-3 DW-1156 Beringer Laurie

DMM-3 DW-1159 Woods Judy

DMM-3 DW-1160 Halizak Kimberly Anne

DMM-3 DW-1161 Rouse Gregory

DMM-3 DW-1164 Redden Michaela

DMM-3 DW-1165 Schaefer Sarah
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-77

DMM-3 DW-1168 Hinch Dianne

DMM-3 DW-1169 Harman Michael

DMM-3 DW-1170 Liebowitz Steve

DMM-3 DW-1171 Courson Bert

DMM-3 DW-1172 Whitney Vernon and Carol

DMM-3 DW-1173 Houston Susanna

DMM-3 DW-1175 Wilson Alisha

DMM-3 DW-1177 Fairman Marcia

DMM-3 DW-1178 Blaszczak Joe

DMM-3 DW-1179 Hudson-DiTraglia Priya

DMM-3 DW-1180 Berk Sally

DMM-3 DW-1182 Ludwig Isaac

DMM-3 DW-1183 Daigle Rachael

DMM-3 DW-1184 Hodge Rita

DMM-3 DW-1185 Weesner Adam

DMM-3 DW-1186 Bovasso Lucy

DMM-3 DW-1187 Porter Lara Jami

DMM-3 DW-1188 Ransom Jill

DMM-3 DW-1189 Crossier Mark and Sandra

DMM-3 DW-1190 Stevens Catherine

DMM-3 DW-1191 Lindsay Kathi

DMM-3 DW-1192 Allenbaugh Matthew

DMM-3 DW-1193 Shaw Janis

DMM-3 DW-1194 Zyla Alison

DMM-3 DW-1195 Lehman Karen

DMM-3 DW-1196 Burress Mary

DMM-3 DW-1197 Meyer Marilyn

DMM-3 DW-1198 Benfield Margaret

DMM-3 DW-1199 Saunders Chris

DMM-3 DW-1200 Winkel Sean

DMM-3 DW-1201 Barrett James

DMM-3 DW-1202 Sanders Richard

DMM-3 DW-1203 Kennedy J

DMM-3 DW-1204 Bir Mark

DMM-3 DW-1205 Stout Karen

DMM-3 DW-1206 Carter Yvonne

DMM-3 DW-1207 Osland Bob

DMM-3 DW-1208 Hoeschler Rebecca

DMM-3 DW-1209 Adams Shannon

DMM-3 DW-1210 Russillo Ronald

DMM-3 DW-1211 Betterley Julie

DMM-3 DW-1212 Fisher Mary

DMM-3 DW-1213 Steigerwald Shauna

DMM-3 DW-1215 Obermeyer Julie

DMM-3 DW-1216 Reed Audrey

DMM-3 DW-1217 Coltrinari John

DMM-3 DW-1218 Duke Katy

DMM-3 DW-1219 Hepp-Dax Sigrid

DMM-3 DW-1220 Schneider Mark
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-78

DMM-3 DW-1221 Mayes James

DMM-3 DW-1222 Girardin Kerry

DMM-3 DW-1223 Shuey Elizabeth

DMM-3 DW-1224 Davis Andrew

DMM-3 DW-1225 Tapley Cynthia

DMM-3 DW-1226 Mitchell Tori

DMM-3 DW-1227 Mcclamroch Kim

DMM-3 DW-1228 Goss Kay

DMM-3 DW-1229 Bruning Julie

DMM-3 DW-1230 Ward Sheila

DMM-3 DW-1231 Black Angela

DMM-3 DW-1234 Loper Tom

DMM-3 DW-1239 Chauveau Bryan

DMM-3 DW-1241 Brown Virginia

DMM-3 DW-1247 Porfert Joe

DMM-3 DW-1250 Gras Joanna

DMM-3 DW-1251 Boggan Joel

DMM-3 DW-1252 Dina Robin

DMM-3 DW-1253 Volk Ann

DMM-3 DW-1254 Brooks Jimmy

DMM-3 DW-1255 Mottley Jessica

DMM-3 DW-1256 Cavanaugh Michael

DMM-3 DW-1257 Bender Jill

DMM-3 DW-1258 Alge John

DMM-3 DW-1259 Fernadez Joyce & Terry

DMM-3 DW-1260 Mathews Carla

DMM-3 DW-1261 Gustavson Britta

DMM-3 DW-1262 Keith Susan

DMM-3 DW-1263 Heater James

DMM-3 DW-1264 Holian Holy Holily

DMM-3 DW-1265 Nordlund James

DMM-3 DW-1266 Reed Billie

DMM-3 DW-1267 Dunkleberger David

DMM-3 DW-1268 VandenBranden Felicia

DMM-3 DW-1269 Martz Diana

DMM-3 DW-1271 Parker Michelle

DMM-4 DW-0425 McGurk Anne

DMM-4 DW-0453 Bloomsburg Anne

DMM-4 DW-0456 Van Briesen Katrina

DMM-4 DW-0459 McGurk Anne

DMM-4 DW-0462 Bobbitt Rachel

DMM-4 DW-0463 Clement Audrey

DMM-4 DW-0464 Dennison Tom

DMM-4 DW-0466 Palmer Liz

DMM-4 DW-0467 Gilges Margaret

DMM-4 DW-0469 Weber Cheryl

DMM-4 DW-0472 Moreno Kimberly

DMM-4 DW-0474 Acton Michelle
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-79

DMM-4 DW-0476 Ostrowski Judith

DMM-4 DW-0484 Sokol Ron

DMM-4 DW-0491 Mettler Nicole

DMM-4 DW-0497 Wyne Zaahira

DMM-4 DW-0500 Popelas Judy

DMM-4 DW-0504 Croghan Keith

DMM-4 DW-0506 Sawdon Rosemarie

DMM-4 DW-0507 Raymond Aislynn

DMM-4 DW-0510 Matteson Tyla

DMM-4 DW-0518 Amarasinghe Disamodha

DMM-4 DW-0528 Peckman Bob

DMM-4 DW-0529 Campbell Kenneth

DMM-4 DW-0530 Merida Jasmin

DMM-4 DW-0531 Blythe Kevin

DMM-4 DW-0533 Copeland Christina

DMM-4 DW-0540 Bokel David

DMM-4 DW-0549 McCloskey Joe

DMM-4 DW-0554 Martin Heather

DMM-4 DW-0558 Mooney Shaun

DMM-4 DW-0561 Fues Lisa

DMM-4 DW-0562 Clark Diane

DMM-4 DW-0568 Lozano Chrissie

DMM-4 DW-0569 King Jamie

DMM-4 DW-0571 Kern Charles

DMM-4 DW-0575 Carpenter Nancy

DMM-4 DW-0579 Howard Jay

DMM-4 DW-0580 Blossom Scott

DMM-4 DW-0581 Hendrickson Holly

DMM-4 DW-0582 Davis Jennifer

DMM-4 DW-0584 Cannon Robert

DMM-4 DW-0586 Hersey Kristie

DMM-4 DW-0588 Bryant Jennifer

DMM-4 DW-0596 Morris Allison

DMM-4 DW-0601 Ehrich Liz

DMM-4 DW-0602 Daufman Ruth

DMM-4 DW-0604 Lawrence Mary

DMM-4 DW-0605 Dawson Teresa

DMM-4 DW-0608 Willis Ken

DMM-4 DW-0612 Breslau Margaret

DMM-4 DW-0613 Shematek Judith

DMM-4 DW-0615 Rellick Joshua

DMM-4 DW-0618 Anthony Joseph

DMM-4 DW-0620 Morgan Katherine

DMM-4 DW-0621 Stone Jem

DMM-4 DW-0625 Gillespie Sarah

DMM-4 DW-0631 Shreeve Denise

DMM-4 DW-0632 Moy Conway

DMM-4 DW-0633 Mickel Anne
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-80

DMM-4 DW-0637 MacDowell Robert

DMM-4 DW-0638 Hearne Phil

DMM-4 DW-0639 Craig Beth

DMM-4 DW-0642 Whitfield Doris

DMM-4 DW-0644 Page Rachel

DMM-4 DW-0646 Strachan Heather

DMM-4 DW-0650 Anderson Ellen

DMM-4 DW-0655 Dell'Aria Stephen

DMM-4 DW-0657 Phillips Donna

DMM-4 DW-0661 Jearman Jean

DMM-4 DW-0664 Leake Lauren

DMM-4 DW-0665 Osborn Lisa

DMM-4 DW-0667 East Laura

DMM-4 DW-0670 Simo Jamie

DMM-4 DW-0672 Cleve Della

DMM-4 DW-0674 Folley-Regusters Scheherazade

DMM-4 DW-0675 Fairman Marcia

DMM-4 DW-0676 Thomason Pablo

DMM-4 DW-0677 Newton Vince

DMM-4 DW-0678 Good Robyn

DMM-4 DW-0679 Mitchell Lee

DMM-4 DW-0680 Jackson Toni

DMM-4 DW-0681 Dickinson Marcia

DMM-4 DW-0682 Silver John

DMM-4 DW-0684 Sanders Helen

DMM-4 DW-0835 Burtner Caryl

DMM-4 DW-0836 Evans Dinda

DMM-4 DW-0837 Schroeder Kurt

DMM-4 DW-0838 Clark Scott

DMM-4 DW-0839 Sistok-Katz Silja

DMM-4 DW-0840 Routh Kira

DMM-4 DW-0841 Callahan Susie

DMM-4 DW-0842 Puhak Blake

DMM-4 DW-0843 Scalin Noah

DMM-4 DW-0844 Cook Dana

DMM-4 DW-0845 Pence Tina

DMM-4 DW-0846 Shilliday Jone

DMM-4 DW-0847 Besa Glen

DMM-4 DW-0848 Bruguiere Amoret

DMM-4 DW-0849 Vinegar Jan

DMM-4 DW-0856 Yeaman Suzanne

DMM-4 DW-0859 Grant Mariah

DMM-4 DW-0864 Olsen Thomas

DMM-4 DW-0865 Barton Andy

DMM-4 DW-0872 Stump Katie

DMM-4 DW-0874 Thiele Joanne

DMM-4 DW-0875 Pal Anjili

DMM-4 DW-0876 Cook Sherri
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-81

DMM-4 DW-0877 Delaney D

DMM-4 DW-0878 Cunningham Ryan

DMM-4 DW-0880 Muchnick Allen

DMM-4 DW-0882 Carruth Lynne

DMM-4 DW-0883 Craig Mike

DMM-4 DW-0884 English Garrett

DMM-4 DW-0886 Cruickshank John

DMM-4 DW-0887 Miller Jason

DMM-4 DW-0888 Fioretti Albert

DMM-4 DW-0889 Hoffman Lilli

DMM-4 DW-0890 Withers Marsha

DMM-4 DW-0892 Tyrrell Joseph

DMM-4 DW-0893 Hollins Katherine

Extracted from DMM-4 DW-0894 Kurtz Robert

DMM-4 DW-0895 Campbell David

DMM-4 DW-0896 Doggett Gregory

DMM-4 DW-0903 Carper Cindy

DMM-4 DW-0905 Shandor Andrea

DMM-4 DW-0917 Wilson Susan

DMM-4 DW-0918 Therrien Pat

DMM-4 DW-0920 Carr-Young Nell

DMM-4 DW-0921 Adams Roger

DMM-4 DW-0922 Hunt Janet

DMM-4 DW-0923 Pessoa Ignacio

DMM-4 DW-0924 Simpson Jane

DMM-4 DW-0925 Welsh Catherine

DMM-4 DW-0928 Mehta Kirit

DMM-4 DW-0929 Buck Peter

DMM-4 DW-0931 Edwards Joseph

DMM-4 DW-0934 McMillan Jon

DMM-4 DW-0936 Tarr Suzanne

DMM-4 DW-0937 Irwin Pamela

DMM-4 DW-0938 Newton Pamela

DMM-4 DW-0939 Suter Emanuel

DMM-4 DW-0940 Quam Brian

DMM-4 DW-0941 Scialdone-Kimberley Hannah

DMM-4 DW-0942 Whitesell Lily

DMM-4 DW-0943 Anderson Ron

DMM-4 DW-0944 McMillen Jason

DMM-4 DW-0945 Jaslow Douglas

DMM-4 DW-0947 Weis Tom

DMM-4 DW-0949 McDermott Amee

DMM-4 DW-0950 Dunbar Mary

DMM-4 DW-0951 Weikert J

DMM-4 DW-0952 Quam Leah

DMM-4 DW-0953 O'Hara Jeanne

DMM-4 DW-0954 Wilson Brian

DMM-4 DW-0956 Bock Carol
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-82

DMM-4 DW-0957 Stiff Katie

DMM-4 DW-0958 Churchman Pat

DMM-4 DW-0959 Elrod Mimi

DMM-4 DW-0960 Bryan Kelly

DMM-4 DW-0961 Turner Willis

DMM-4 DW-0962 Steponkus Mary

DMM-4 DW-0963 Apple Joe

DMM-4 DW-0964 Sarli Leonardo

DMM-4 DW-0965 Johnson Letitia

DMM-4 DW-0966 Nemeth Teresa

DMM-4 DW-0967 Avery Burt

DMM-4 DW-0968 Szeman Judy

DMM-4 DW-0969 Duffy Matt

DMM-4 DW-0970 Goldstein Vicki

DMM-4 DW-0971 Johnson Heath

DMM-4 DW-0972 McCabe Lauren

DMM-4 DW-0973 Fleischman Catherine

DMM-4 DW-0974 C. Lori

DMM-4 DW-0975 Heegaard Flemming

DMM-4 DW-0976 Friedman Paul

DMM-4 DW-0977 Burger Scott

Extracted from DMM-4 DW-0978 Woodlief Ann

DMM-4 DW-0979 Parker Michelle

DMM-4 DW-0980 Gardner Barbara

DMM-4 DW-0981 Falkerson Linda

DMM-4 DW-0982 Parlette Mark

DMM-4 DW-0983 Borkowski Elizabeth

DMM-4 DW-0984 Mueller Robert

DMM-4 DW-0985 Krochalis Andrea

DMM-4 DW-0986 Bennett Jaime

DMM-4 DW-0987 Stringfellow Agnes

DMM-4 DW-0988 Ward Erin

DMM-4 DW-0989 Bilardo Heidi

DMM-4 DW-0990 Beck Barbara

DMM-4 DW-0991 Ellis Thomas

DMM-4 DW-0992 Wysocka Jowita

DMM-4 DW-0993 Shantz David

DMM-4 DW-0994 Donley Anne

DMM-4 DW-0995 Strobel Melissa

DMM-4 DW-0996 Skopal Maya

DMM-4 DW-0997 Brooks Steve

DMM-4 DW-0999 Parker Floret

DMM-4 DW-1000 Germans Nicole

DMM-4 DW-1001 Jacqueline Boswell

DMM-4 DW-1002 Berg Gloria

DMM-4 DW-1003 Crate Susie

DMM-4 DW-1004 Howard John

DMM-4 DW-1005 Morrison Elijah
Comment Document ID Last Name First Name

December 2006 NUREG-1811, Volume II 6-83

DMM-4 DW-1006 Edwards Ron

DMM-4 DW-1008 Moeller Audrey

DMM-4 DW-1009 Scarrow William and Nedra

DMM-4 DW-1010 Pool Charles

DMM-4 DW-1011 Davimes Laura

DMM-4 DW-1012 Pitre Julia

DMM-4 DW-1013 Mitchell Roy

DMM-4 DW-1014 Churray Richard

DMM-4 DW-1016 Sundy M

DMM-4 DW-1017 Jeffrey Melody

DMM-4 DW-1019 Gold Alan

DMM-4 DW-1020 Loew Michael

DMM-4 DW-1021 Whealin Alice

DMM-4 DW-1022 Bolas Mary Lou

DMM-4 DW-1023 Celestine Laura

DMM-4 DW-1024 Hogger Christoph

DMM-4 DW-1026 Campana Birgit

DMM-4 DW-1027 Urbach Howard

DMM-4 DW-1028 Williamson Ryan

DMM-4 DW-1029 Rogers Ann

DMM-4 DW-1031 Ewen Laura

DMM-4 DW-1033 Stafford Chris

DMM-4 DW-1034 Pryor Cindy

DMM-4 DW-1036 Zinck James

Extracted from DMM-4 DW-1037 Ackor Jean and Bill

DMM-4 DW-1039 Chappell Susan

DMM-4 DW-1040 Shapiro Michael

DMM-4 DW-1041 Carrell Jimmy

DMM-4 DW-1043 Austin Douglas

DMM-4 DW-1045 Bushey Carolyn

DMM-4 DW-1046 York Stasi

DMM-4 DW-1047 Hagood Talbott

DMM-4 DW-1048 Keeton III Dewey

DMM-4 DW-1049 Bryan Keith

DMM-4 DW-1050 Williamson Barbara

DMM-4 DW-1051 Pedigo Lance

DMM-4 DW-1054 Amel Dean

DMM-4 DW-1055 McGhee Yvonne

DMM-4 DW-1056 Kashani Letitia

DMM-4 DW-1057 Dennette-Shaw Diane

DMM-4 DW-1058 Bunting Kyle

DMM-4 DW-1059 Proctor Stephen

DMM-4 DW-1060 Barnes Robet

DMM-4 DW-1061 Rampy Leah

DMM-4 DW-1062 Nielsen Anne

DMM-4 DW-1063 Henderson Lillian

DMM-4 DW-1064 Imbert Megan

DMM-4 DW-1065 Sumrall Daniel
Comment Document ID Last Name First Name

NUREG-1811, Volume II December 2006 6-84

DMM-4 DW-1066 Homitz Daniel

DMM-4 DW-1067 McAdams Charlotte

DMM-4 DW-1068 Strandberg Adrienne

DMM-4 DW-1069 Miller Griff

DMM-4 DW-1070 Soriano Patricia

DMM-4 DW-1071 East Buddy

DMM-4 DW-1072 Wise Sarah

DMM-4 DW-1073 Zaza Sara

DMM-4 DW-1074 Lanzman Sarah

DMM-4 DW-1075 Cassel Anje

DMM-4 DW-1076 Mullins Victoria

DMM-4 DW-1077 Tyrrell Anne

DMM-4 DW-1078 Devore ML

DMM-4 DW-1079 Snell pamelynn

DMM-4 DW-1080 Mayhew Paul

DMM-4 DW-1081 Ward Claire

DMM-4 DW-1082 Fellows Leslie

DMM-4 DW-1083 Kunkel Christopher

DMM-4 DW-1084 Woodbridge Michael

DMM-4 DW-1085 Branham Linda

DMM-4 DW-1086 Pryor Barbara

DMM-4 DW-1087 Smith Jennifer

DMM-4 DW-1088 Miller Cliff

DMM-4 DW-1092 Costello TracyAnn

DMM-4 DW-1094 Ross Guy

Extracted from DMM-4 DW-1095 Lynch James

DMM-4 DW-1096 Parrucci Samuel

DMM-4 DW-1097 Egbert Robert

DMM-4 DW-1098 Snyder Kelly

Extracted from DMM-4 DW-1099 Dukovich John

DMM-4 DW-1101 Cali Whitney

DMM-4 DW-1102 Eichenberger Patricia

DMM-4 DW-1104 Redding Sherley

DMM-4 DW-1105 Best Sharon

DMM-4 DW-1106 Martinez Christina

DMM-4 DW-1107 White Eric

DMM-4 DW-1108 Savage Thomas

DMM-4 DW-1109 Terry Joe

DMM-4 DW-1110 Greggs Paul

DMM-4 DW-1111 Pownall Phyllis

DMM-4 DW-1112 Carter Ellie

Extracted from DMM-4 DW-1113 Hulstrom Erica

DMM-4 DW-1116 Leeper Dana

DMM-4 DW-1131 Sorovacu Yvonne

DMM-4 DW-1137 Brummer Ann

DMM-4 DW-1162 Hinch Dianne

DMM-4 DW-1166 Halliburton-Ross Kathleen

DMM-4 DW-1174 Foley Erin
December 2006 NUREG-1811, Volume II 6-85

Table 6-4. SDEIS Index Arranged Alphabetically

Commenter Name, Organization where Specified

Commenter

Number

Accession

Number

Comment

Date

Jim Adams ST-0038 ML062440240 8/15/2006

Lee Anthony ST-0034 ML062440240 8/15/2006

Richard Ball Virginia Chapter of Sierra Club ST-0030 ML062440240 8/15/2006

Dick Ball Virginia Chapter of Sierra Club SE-0038 ML062540017 9/8/2006

Vishwa Bhargava SE-0023 ML062330040 8/17/2006

Sama Bilbao SE-0025 ML062350119 8/16/2006

Sama Bilbao Y Leon North American Young Generation of Nuclear ST-0013 ML062440240 8/15/2006

Kirsten Breeded ST-0022 ML062440240 8/15/2006

Gary Breeden Aspen Homeowner's Association ST-0029 ML062440240 8/15/2006

Sandra Brockel SE-0008 ML062060627 7/25/2006

Bill Campbell ST-0023 ML062440240 8/15/2006

Eric Cantor Congressman SW-0002 ML062280472 8/7/2006

Bill Casino ST-0017 ML062440240 8/15/2006

Keith Cheatham Virginia Chamber of Commerce ST-0031 ML062440240 8/15/2006

Keith Cheatham V. P. Virginia Chamber of Commerce SW-0007 ML062350262 8/15/2006

Michael Chezik U.S. Department of the Interior SE-0024 ML062350118 8/21/2006

Robert Clarke Industrial Dev. Authority, Louisa Cty ST-0016 ML062440240 8/15/2006

Julie Curry SW-0014 ML062350337 8/16/2006

Scott Curtis SW-0001 ML062220274 7/30/2006

Elena Day People's Alliance for Clean Energy ST-0002 ML062440240 8/15/2006

Peter Dorn PK Dorn and Associates SE-0015 ML062210381 8/1/2006

R. Faris SE-0037 ML062500414 9/7/2006

Rebecca Farris ST-0006 ML062440240 8/15/2006

Todd Flowers SW-0006 ML062350260 8/15/2006

Wade Frazee SE-0019 ML062260020 8/11/2006

Sherman Frye SE-0011 ML062200091 8/6/2006

Paul Genoa ST-0033 ML062440240 8/15/2006

Gerry Giaccai ST-0007 ML062440240 8/15/2006

Aviv Goldsmith ST-0036 ML062440240 8/15/2006

Aviv Goldsmith (same as SW-0018) SE-0045 ML062550560 9/12/2006

Aviv Goldsmith (same as SE-0045) SW-0018 ML062650173 9/12/2006

Eugene Grecheck Dominion Nuclear North Anna ST-0009 ML062440240 8/15/2006

Eugene Grecheck Dominion Nuclear North Anna SE-0050 ML062990422 9/12/2006

Eugene Grecheck Dominion (same as SE-0050) SW-0022 ML062990422 9/12/2006

Patrick Hanley Louisa Cty Chamber of Commerce ST-0018 ML062440240 8/15/2006

Frank Harksen Hanover Cty Dept of Public Utilities SW-0019 ML062650174 9/12/2006

Frank Harksen Hanover Cty Dept of Public Utilities SE-0048 ML062550564 9/12/2006

Vicky Harte U.S. Women in Nuclear SE-0026 ML062400041 8/24/2006

Delbert Horn ST-0026 ML062440240 8/15/2006

Robin Horne Chair, Louisa Cty School Board ST-0011 ML062440240 8/15/2006

Robin Horne (and HA Shaffer) Louisa Cty School Board SW-0016 ML062610057 9/6/2006

Michael Ireland SE-0016 ML062220293 8/9/2006
Commenter Name, Organization where Specified

Commenter

Number

Accession

Number

Comment

Date

NUREG-1811, Volume II December 2006 6-86

Michael Ireland SE-0020 ML062260021 8/13/2006

Ellie Irons (VEDQ--forwarding SE-0008 to NRC) SE-0009 ML062060628 7/25/2006

Ellie Irons Virginia Department of Environmental Quality SE-0021 ML062260451 8/14/2006

Ellie Irons Virginia Department of Environmental Quality SE-0039 ML062540018 9/8/2006

Ellie Irons Virginia Department of Environmental Quality SW-0017 ML062100582 9/8/2006

Ellis James SW-0021 ML062860577 9/10/2006

Bill Janis Virginia House of Delegates SW-0012 ML062350335 8/14/2006

Ray Jurgel SW-0015 ML062350338 8/16/2006

Melissa Kemp Public Citizen ST-0005 ML062440240 8/15/2006

Allan Lassitor ST-0035 ML062440240 8/15/2006

Keely Levering SE-0014 ML062210380 8/9/2006

Lee Lintecum Louisa County Administrator ST-0010 ML062440240 8/15/2006

Lee Lintecum Louisa County Administrator SW-0005 ML062350259 8/15/2006

Chris Lloyd ST-0003 ML062440240 8/15/2006

Jackie Lombardo SE-0034 ML062500406 9/5/2006

Jackie Lombardo SE-0041 ML062540021 9/5/2006

Kouy Luangphinith SW-0013 ML062350336 8/16/2006

Theresa Lynch SE-0035 ML062500408 9/6/2006

Ron Mickens ST-0021 ML062440240 8/15/2006

Steve Montgomery ST-0037 ML062440240 8/15/2006

William Murphey Lake Anna Civic Association SW-0004 ML062350256 8/15/2006

Bill Murphy Lake Anna Civic Association ST-0004 ML062440240 8/15/2006

 NA-YGN Petition North American Young Generation of Nuclear SW-0009 ML062350445 8/15/2006

Christopher Paine National Resources Defense Council SE-0040 ML062540019 9/9/2006

Richard Parrish Southern Environmental Law Center SE-0046 ML062550561 9/12/2006

Donna Pienkowski SE-0049 ML062560017 9/12/2006

Henry Pollard Cristian Barton for Bear Island Paper Co. SE-0047 ML062550562 9/12/2006

Henry Pollard Atty, Bear Island Paper Co. SW-0020 ML062650177 9/12/2006

Ken Remmers Watersides Homeowner's Property

Association

ST-0028 ML062440240 8/15/2006

Kenneth Remmers Watersides Homeowner's Property

Association

SE-0027 ML062400043 8/24/2006

Kenneth Remmers (duplicate of SE-0027) SE-0028 ML062400045 8/24/2006

Kenneth Remmers Watersides Homeowner's Property

Association

SE-0029 ML062410057 8/28/2006

Helen Reutlinger SE-0032 ML062490034 9/5/2006

Helen Reutlinger (duplicate of SE-0032) SE-0042 ML062540022 9/5/2006

Robert Richards SE-0018 ML062260019 8/11/2006

Jerry Rosenthal ST-0024 ML062440240 8/15/2006

Harry Ruth Friends of Lake Anna ST-0014 ML062440240 8/15/2006

Harry Ruth Friends of Lake Anna SE-0002 ML062050345 7/24/2006

Harry Ruth Friends of Lake Anna SE-0003 ML062050346 7/24/2006

Harry Ruth Friends of Lake Anna SE-0004 ML062050635 7/24/2006

Harry Ruth (duplicate of SE-0003) SE-0005 ML062050638 7/24/2006

Harry Ruth (duplicate of SE-0003) SE-0006 ML062060625 7/25/2006
Commenter Name, Organization where Specified

Commenter

Number

Accession

Number

Comment

Date

December 2006 NUREG-1811, Volume II 6-87

Harry Ruth Friends of Lake Anna SE-0007 ML062060626 7/24/2006

Harry Ruth Friends of Lake Anna SE-0013 ML062200539 8/7/2006

Harry Ruth Friends of Lake Anna SE-0022 ML062330039 8/17/2006

Harry Ruth Friends of Lake Anna SE-0033 ML062490036 9/5/2006

Harry Ruth Friends of Lake Anna SE-0044 ML062550131 9/12/2006

Bill Salisbury SE-0017 ML062220294 8/10/2006

Harold Schaffer Louisa County School Board SE-0036 ML062550322 9/6/2006

Dennis Schaible ST-0032 ML062440240 8/15/2006

Dennis Schaible SE-0012 ML062200093 8/5/2006

David Schwartz SE-0010 ML062120115 7/29/2006

Ben Slone ST-0015 ML062440240 8/15/2006

Selena Smith ST-0027 ML062440240 8/15/2006

Margo Sorokin SE-0031 ML062490033 9/5/2006

Margo Sorokin (duplicate of SE-0031) SE-0043 ML062540025 9/5/2006

Lisa Stiles-Shell Int'l Youth Nuclear Congress, NA-YGN ST-0012 ML062440240 8/15/2006

Michael Stuart ST-0020 ML062440240 8/15/2006

Kelly Taylor ST-0025 ML062440240 8/15/2006

Norman Tweed Jr SE-0001 ML062050344 7/21/2006

Brad Wike Int'l Brotherhood of Electrical Workers SW-0003 ML062350252 8/15/2006

Arguto William US Environmental Protection Agency SE-0030 ML062550326 8/28/2006

Catherine Williams SW-0011 ML062350332 8/14/2006

Lee Wycoff ST-0001 ML062440240 8/15/2006

Patricia Wycoff ST-0019 ML062440240 8/15/2006

Lou Zeller Blue Ridge Env. Defense League ST-0008 ML062440240 8/15/2006

Louis Zeller Blue Ridge Env. Defense League SW-0008 ML062350263 8/15/2006

Table 6-5. SDEIS Index Arranged Numerically

Commenter

Number Commenter Name, Organization where Specified

Accession

Number

Comment

Date

Transcript Comments

ST-0001 Lee Wycoff ML062440240 8/15/2006

ST-0002 Elena Day People's Alliance for Clean Energy ML062440240 8/15/2006

ST-0003 Chris Lloyd ML062440240 8/15/2006

ST-0004 Bill Murphy Lake Anna Civic Association ML062440240 8/15/2006

ST-0005 Melissa Kemp Public Citizen ML062440240 8/15/2006

ST-0006 Rebecca Farris ML062440240 8/15/2006

ST-0007 Gerry Giaccai ML062440240 8/15/2006

ST-0008 Lou Zeller Blue Ridge Env. Defense League ML062440240 8/15/2006

ST-0009 Gene Grecheck Dominion Nuclear North Anna ML062440240 8/15/2006

ST-0010 Lee Lintecum Louisa Cty Administrator ML062440240 8/15/2006

ST-0011 Robin Horne Louisa County School Board ML062440240 8/15/2006

ST-0012 Lisa Stiles-Shell Int'l Youth Nuclear Congress, NA-YGN ML062440240 8/15/2006

ST-0013 Sama Bilbao Y Leon North American Young Generation of Nuclear ML062440240 8/15/2006
Commenter

Number Commenter Name, Organization where Specified

Accession

Number

Comment

Date

NUREG-1811, Volume II December 2006 6-88

ST-0014 Harry Ruth Friends of Lake Anna ML062440240 8/15/2006

ST-0015 Ben Slone ML062440240 8/15/2006

ST-0016 Robert Clarke Industrial Dev. Authority, Louisa Cty ML062440240 8/15/2006

ST-0017 Bill Casino ML062440240 8/15/2006

ST-0018 Patrick Hanley Louisa Cty Chamber of Commerce ML062440240 8/15/2006

ST-0019 Patricia Wycoff ML062440240 8/15/2006

ST-0020 Michael Stuart ML062440240 8/15/2006

ST-0021 Ron Mickens ML062440240 8/15/2006

ST-0022 Kirsten Breeded ML062440240 8/15/2006

ST-0023 Bill Campbell ML062440240 8/15/2006

ST-0024 Jerry Rosenthal ML062440240 8/15/2006

ST-0025 Kelly Taylor ML062440240 8/15/2006

ST-0026 Delbert Horn ML062440240 8/15/2006

ST-0027 Selena Smith ML062440240 8/15/2006

ST-0028 Ken Remmers Watersides Homeowner's Property Association ML062440240 8/15/2006

ST-0029 Gary Breeden Aspen Homeowner's Association ML062440240 8/15/2006

ST-0030 Richard Ball Virginia Chapter of Sierra Club ML062440240 8/15/2006

ST-0031 Keith Cheatham Virginia Chamber of Commerce ML062440240 8/15/2006

ST-0032 Dennis Schaible ML062440240 8/15/2006

ST-0033 Paul Genoa ML062440240 8/15/2006

ST-0034 Lee Anthony ML062440240 8/15/2006

ST-0035 Allan Lassitor ML062440240 8/15/2006

ST-0036 Aviv Goldsmith ML062440240 8/15/2006

ST-0037 Steve Montgomery ML062440240 8/15/2006

ST-0038 Jim Adams ML062440240 8/15/2006

E-mail comments

SE-0001 Norman Tweed Jr ML062050344 7/21/2006

SE-0002 Harry Ruth Friends of Lake Anna ML062050345 7/24/2006

SE-0003 Harry Ruth Friends of Lake Anna ML062050346 7/24/2006

SE-0004 Harry Ruth Friends of Lake Anna ML062050635 7/24/2006

SE-0005 Harry Ruth (duplicate of SE-0003) ML062050638 7/24/2006

SE-0006 Harry Ruth (duplicate of SE-0003) ML062060625 7/25/2006

SE-0007 Harry Ruth Friends of Lake Anna ML062060626 7/24/2006

SE-0008 Sandra Brockel ML062060627 7/25/2006

SE-0009 Ellie Irons (VEDQ--forwarding SE-0008 to NRC) ML062060628 7/25/2006

SE-0010 David Schwartz ML062120115 7/29/2006

SE-0011 Sherman Frye ML062200091 8/6/2006

SE-0012 Dennis Schaible ML062200093 8/5/2006

SE-0013 Harry Ruth Friends of Lake Anna ML062200539 8/7/2006

SE-0014 Keely Levering ML062210380 8/9/2006

SE-0015 Peter Dorn PK Dorn and Associates ML062210381 8/1/2006

SE-0016 Michael Ireland ML062220293 8/9/2006

SE-0017 Bill Salisbury ML062220294 8/10/2006

SE-0018 Robert Richards ML062260019 8/11/2006

SE-0019 Wade Frazee ML062260020 8/11/2006
Commenter

Number Commenter Name, Organization where Specified

Accession

Number

Comment

Date

December 2006 NUREG-1811, Volume II 6-89

SE-0020 Michael Ireland ML062260021 8/13/2006

SE-0021 Ellie Irons ML062260451 8/14/2006

SE-0022 Harry Ruth Friends of Lake Anna ML062330039 8/17/2006

SE-0023 Vishwa Bhargava ML062330040 8/17/2006

SE-0024 Michael Chezik U.S. Department of the Interior ML062350118 8/21/2006

SE-0025 Sama Bilbao ML062350119 8/16/2006

SE-0026 Vicky Harte U.S. Women in Nuclear ML062400041 8/24/2006

SE-0027 Kenneth Remmers Watersides Homeowner's Property Association ML062400043 8/24/2006

SE-0028 Kenneth Remmers (duplicate of SE-0027) ML062400045 8/24/2006

SE-0029 Kenneth Remmers Watersides Homeowner's Property Association ML062410057 8/28/2006

SE-0030 Arguto William US Environmental Protection Agency ML062550326 8/28/2006

SE-0031 Margo Sorokin ML062490033 9/5/2006

SE-0032 Helen Reutlinger ML062490034 9/5/2006

SE-0033 Harry Ruth Friends of Lake Anna ML062490036 9/5/2006

SE-0034 Jackie Lombardo ML062500406 9/5/2006

SE-0035 Theresa Lynch ML062500408 9/6/2006

SE-0036 Harold Schaffer Louisa County School Board ML062550322 9/6/2006

SE-0037 R. Faris ML062500414 9/7/2006

SE-0038 Dick Ball Virginia Chapter of Sierra Club ML062540017 9/8/2006

SE-0039 Irons Ellie Virginia Department of Environmental Quality ML062540018 9/8/2006

SE-0040 Christopher Paine National Resources Defense Council ML062540019 9/9/2006

SE-0041 Jackie Lombardo ML062540021 9/5/2006

SE-0042 Helen Reutlinger (duplicate of SE-0032) ML062540022 9/5/2006

SE-0043 Margo Sorokin (duplicate of SE-0031) ML062540025 9/5/2006

SE-0044 Harry Ruth Friends of Lake Anna ML062550131 9/12/2006

SE-0045 Aviv Goldsmith (same as SW-0018) ML062550560 9/12/2006

SE-0046 Richard Parrish Southern Environmental Law Center ML062550561 9/12/2006

SE-0047 Henry Pollard Cristian Barton for Bear Island Paper Co. ML062550562 9/12/2006

SE-0048 Harksen Frank Hanover Cty Dept of Public Utilities ML062550564 9/12/2006

SE-0049 Donna Pienkowski ML062560017 9/12/2006

SE-0050 Eugene Grecheck Dominion Nuclear North Anna ML062990422 9/12/2006

Written comments

SW-0001 Scott Curtis ML062220274 7/30/2006

SW-0002 Eric Cantor Congressman ML062280472 8/7/2006

SW-0003 Brad Wike Int'l Brotherhood of Electrical Workers ML062350252 8/15/2006

SW-0004 William Murphey Lake Anna Civic Association ML062350256 8/15/2006

SW-0005 Lee Lintecum Louisa County Administrator ML062350259 8/15/2006

SW-0006 Todd Flowers ML062350260 8/15/2006

SW-0007 Keith Cheatham V. P. Virginia Chamber of Commerce ML062350262 8/15/2006

SW-0008 Louis Zeller Blue Ridge Env. Defense League ML062350263 8/15/2006

SW-0009 NA-YGN Petition North American Young Generation of Nuclear ML062350445 8/15/2006

SW-0010 Notes erroneously entered as a comment ML062350266 8/15/2006

SW-0011 Catherine Williams ML062350332 8/14/2006

SW-0012 Bill Janis Virginia House of Delegates ML062350335 8/14/2006

SW-0013 Kouy Luangphinith ML062350336 8/16/2006
Commenter

Number Commenter Name, Organization where Specified

Accession

Number

Comment

Date

NUREG-1811, Volume II December 2006 6-90

SW-0014 Julie Curry ML062350337 8/16/2006

SW-0015 Ray Jurgel ML062350338 8/16/2006

SW-0016 Robin Horne (and HA Shaffer) Louisa Cty School Board ML062610057 9/6/2006

SW-0017 Ellie Irons Virginia Department of Environmental Quality ML062100582 9/8/2006

SW-0018 Aviv Goldsmith (same as SW-0045) ML062650173 9/12/2006

SW-0019 Frank Harksen Hanover Cty Dept of Public Utilities ML062650174 9/12/2006

SW-0020 Henry Pollard Atty, Bear Island Paper Co. ML062650177 9/12/2006

SW-0021 Ellis James ML062860577 9/10/2006

SW-0022 Eugene Grecheck Dominion (same as SE-0050) ML062990422 9/12/2006
Appendix F

Key Correspondence
December 2006 F-1 NUREG-1811, Volume II

Appendix F

Dominion Nuclear North Anna LLC’s

Key Early Site Permit Consultation Correspondence

Correspondence received during the evaluation process of the early site permit (ESP)

application for Dominion Nuclear North Anna LLC (Dominion) for the proposed North Anna site

is identified in Table F-1. Copies of the correspondence are included at the end of this table.

Source Recipient Date of Letter/E-mail

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

Virginia Department of Historic

Resources

(Ethel Eaton)

November 21, 2003

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

Virginia Council on Indians

(Deanna Beacham)

December 3, 2003

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

Tuscarora Environmental

Program

(Neil Patterson)

December 3, 2003

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

Chief Arnold Hewitt December 3, 2003

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

Chief Leo Henry December 3, 2003

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

NOAA Fisheries

(Mary Colligan)

December 21, 2003

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

U.S. Fish and Wildlife Service

(John Wolflin)

December 21, 2003

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

U.S. Fish and Wildlife Service

(Roger Banks)

December 21, 2003

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

U.S. Fish and Wildlife Service

(Mary Knapp)

December 21, 2003
Appendix F

Source Recipient Date of Letter/E-mail

NUREG-1811, Volume II F-2 December 2006

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

Advisory Council on Historic

Preservation

(Don Klima)

January 5, 2004

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

NOAA Fisheries

(Georgia Cranmore)

January 5, 2004

NOAA Fisheries

(Mary Colligan)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

January 6, 2004

U.S. Fish and Wildlife Service

(Timothy Hall)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

January 15, 2004

U.S. Fish and Wildlife Service

(Mary Knapp)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

February 3, 2004

NOAA

(David Bernhart)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

May 19, 2004

U.S. Fish and Wildlife Service

(Karen Mayne)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

October 25, 2004

Virginia Department of Historic

Resources

(Ethel Eaton)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

January 5, 2005

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

U.S. Fish and Wildlife Service

(David Sutherland)

January 31, 2005

Dominion Virginia Power

Company

(Pamela Faggert)

Virginia Department of

Environmental Quality

(Ellie Irons)

March 21, 2005

U.S. Fish and Wildlife Service

(John Wolflin)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

May 20, 2005

Virginia Department of

Environmental Quality

(Ellie Irons)

Dominion Virginia Power

Company

(Pamela Faggert)

June 17, 2005
Appendix F

Source Recipient Date of Letter/E-mail

December 2006 F-3 NUREG-1811, Volume II

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

U.S. Army Corps of Engineers

(Mr. Regena Bronson)

June 30, 2005

Department of the Army

Corps of Engineers

(Bruce F. Williams)

U.S. Nuclear Regulatory

Commission

(Jack Cushing)

July 15, 2005

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

Virginia Department of Historic

Resources (Ethel Eaton)

September 27, 2005

U.S. Department of the Interior,

National Park Service

(Skip Brooks)

U.S. Nuclear Regulatory

Commission

(Jack Cushing)

October 25, 2005

Virginia Department of Historic

Resources

(Roger W. Kirchen)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

November 3, 2005

Virginia Department of

Environmental Quality

(Jeffery A. Steers)

U.S. Nuclear Regulatory

Commission

(Jack Cushing)

June 16, 2006

Virginia Department of

Historic Resources

(Roger W. Kirchen)

U.S. Nuclear Regulatory

Commission

(Jack Cushing)

October 20, 2006 |

|

|

U.S. Nuclear Regulatory |

Commission (Brent Clayton) |

Virginia Department of Historic

Resources (Ethel Eaton)

November 3, 2006 |

U.S. Nuclear Regulatory |

Commission (Brent Clayton) |

U.S. Fish and Wildlife Service

(Michael Chezik)

November 3, 2006 |

Dominion Nuclear North Anna,

LLC (Eugene Grecheck)

U.S. Nuclear Regulatory

Commission

(Pao-Tsin Kuo)

November 22, 2006 |

|

|
Appendix F

NUREG-1811, Volume II F-4 December 2006
Appendix F

December 2006 F-5 NUREG-1811, Volume II
Appendix F

NUREG-1811, Volume II F-6 December 2006
Appendix F

December 2006 F-7 NUREG-1811, Volume II
Appendix F

NUREG-1811, Volume II F-8 December 2006
Appendix F

December 2006 F-9 NUREG-1811, Volume II
Appendix F

NUREG-1811, Volume II F-10 December 2006
Appendix F

December 2006 F-11 NUREG-1811, Volume II
Appendix F

NUREG-1811, Volume II F-12 December 2006
Appendix F

December 2006 F-13 NUREG-1811, Volume II
Appendix F

NUREG-1811, Volume II F-14 December 2006
Appendix F

December 2006 F-15 NUREG-1811, Volume II
Appendix F

NUREG-1811, Volume II F-16 December 2006
Appendix F

December 2006 F-17 NUREG-1811, Volume II
Appendix F

NUREG-1811, Volume II F-18 December 2006
Appendix F

December 2006 F-19 NUREG-1811, Volume II
Appendix F

NUREG-1811, Volume II F-20 December 2006
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June 30, 2005

Ms. Regena Bronson

U.S. Army Corps of Engineers

Potomac Virginia Field Office

P.O. Box 1704

Leonardtown, MD 20650

SUBJECT: NORTH ANNA EARLY SITE PERMIT REVIEW (TAC NO. MC1128)

Dear Ms. Bronson:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing an application submitted by

Dominion Nuclear North Anna, LLC (Dominion) for an early site permit (ESP). The proposed

action requested in Dominion’s application is for the NRC to: (1) approve a site within the

existing North Anna Power Station (NAPS) boundaries as suitable for the construction and

operation of one or more new nuclear power generating facilities; and (2) issue an ESP for the

proposed site located at NAPS. An ESP does not authorize construction or operation of a

nuclear power plant. Rather, the ESP application and review process makes it possible to

evaluate and resolve certain safety and environmental issues related to siting before the

applicant makes large commitments of resources. If the ESP is approved, the applicant can

?bank” the site for up to 20 years for future reactor siting. To construct or operate a nuclear

power plant, an ESP holder must obtain a construction permit and an operating license, or a

combined license.

As part of its environmental review of Dominion’s ESP application, the NRC prepared a draft

environmental impact statement (DEIS) in accordance with 10 CFR 52.18. The DEIS includes

the NRC staff’s analysis of the environmental impacts of constructing and operating two nuclear

units at the North Anna ESP site, or at alternative sites. It also includes the staff’s preliminary

recommendation to the Commission regarding the proposed action. In addition, as described in

the DEIS, if the ESP includes a site redress plan, the ESP holder can conduct certain site

preparation and preliminary construction activities allowed by Title 10 of the Code of Federal

Regulations Section 50.10(e)(1) (10 CFR 50.10 (e)(1)), provided the final EIS concludes that

such activities will not result in any significant environmental impact that cannot redressed. 

Dominion has included a site redress plan in its application. If the ESP is approved, Dominion

would be allowed to conduct site preparation and preliminary construction activities pursuant to

10 CFR 52.25 and 10 CFR 50.10(e)(1), subject to receipt of any other necessary Federal,

State, and/or local approvals. Dominion has stated that it does not plan to conduct such

activities at this time. However, these activities, if performed, could include dredging and other

activities potentially subject to Clean Water Act requirements. The environmental impacts of

these activities are discussed in the DEIS.

Appendix F

NUREG-1811, Volume II F-102 December 2006
R. Bronson -2-

Pursuant to the “Memorandum of Understanding Between the Corps of Engineers, United

States Army, and the United States Nuclear Regulatory Commission for Regulation of Nuclear

Power Plants” (40 FR 37110 (dated August 25, 1975)), we request that the Army Corps of

Engineers review and provide to the NRC any comments on the DEIS.

Enclosed is a copy of NUREG-1811 “The Draft Environmental Impact Statement for an Early

Site Permit (ESP) at the North Anna ESP Site.” We request your comments no later than

August 12, 2005. Enclosed to aid in your review is a CD containing Dominion’s application for

an ESP. If you have any questions concerning the ESP application or other aspects of this

project, please contact Mr. Jack Cushing, Senior Environmental Project Manager, at 301-415-

1424 or by e-mail at JXC9@nrc.gov.

Sincerely,

/RA/

Pao-Tsin Kuo, Program Director

License Renewal and Environmental Impacts Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket No.: 52-008

Enclosure: As stated

cc wo/encl.: See next page

Appendix F

December 2006 F-103 NUREG-1811, Volume II
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NUREG-1811, Volume II F-104 December 2006
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December 2006 F-105 NUREG-1811, Volume II
September 27, 2005

Dr. Ethel Eaton, Manager

Office of Review and Compliance

Virginia Department of Historic Resources

2801 Kensington Avenue

Richmond, VA 23221

SUBJECT: NORTH ANNA EARLY SITE PERMIT REVIEW (TAC NO. MC1128)

Dear Dr. Eaton:

This letter responds to your request for a programmatic agreement with the U.S. Nuclear

Regulatory Commission (NRC) under the National Historic Preservation Act (NHPA) raised

during our teleconference conducted on May 23, 2005, with members of your staff and

Dominion Nuclear North Anna, LLC (Dominion). The Virginia Department of Historic Resources

(VDHR) request for a programmatic agreement (PA) relates to Dominion’s application for an

early site permit (ESP) at the North Anna site in Louisa County, Virginia. 

The NRC stated the actions that it expected Dominion to take based on representations made

in Dominion’s environmental report (ER), which is reflected in the NRC’s draft environmental

impact statement (DEIS). Specifically, Dominion stated in its ER:

“Prior to any activities that would disturb existing ground conditions, Dominion

would assess the need, in coordination with VDHR, to undertake subsurface

investigations for the identification of potentially significant historic or cultural

resources in the area(s) to be disturbed. The investigations would be conducted

in accordance with professional archeological practices and recommendations

as developed in coordination with VDHR. Additionally, Dominion would

implement the necessary administrative steps to make proper notifications in the

event of any unanticipated discovery (including human remains). These steps

would include stop-work, assessment, and notification protocol.” [ER Revision 5

Section 4.1.3, Page 3-4-6].

The above statement regarding coordination by Dominion with VDHR before ground disturbing

activities was relied on and is reflected in DEIS Section 4.6. 

As set forth in our November 21, 2003, letter to you, the NRC staff is using the National

Environmental Policy Act (NEPA) process to comply with the obligations imposed under

§ 106 of the NHPA in accordance with the provisions in 36 CFR 800.8. Consistent with our

November 21 letter, the NRC has described in the EIS analyses of potential impacts to

historical and cultural resources and measures in place at the ESP site that would be expected

to avoid, minimize or mitigate any adverse effects on historic properties. The NRC staff also

forwarded the draft EIS to you for your review and comment. Accordingly, the NRC staff does

not believe a PA is warranted.

Appendix F

NUREG-1811, Volume II F-106 December 2006
E. Eaton -2-

If you have any questions concerning the ESP application or other aspects of this project,

please contact Mr. Jack Cushing, Senior Environmental Project Manager, at 301-415-1424 or 

by e-mail at JXC9@nrc.gov.

Sincerely,

/RA Jacob Zimmerman For/

Pao-Tsin Kuo, Program Director

License Renewal and Environmental Impacts Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Docket No.: 52-008

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NUREG-1811, Volume II F-116 December 2006
November 3, 2006

Mr. Michael T. Chezik

Regional Environmental Officer

United States Department of the Interior

Office of the Secretary

Office of Environmental Policy and Compliance

Custom House, Room 244

200 Chestnut Street

Philadelphia, PA 19106-2904

SUBJECT: REQUEST BY THE U.S. FISH AND WILDLIFE SERVICE FOR A MEMORANDUM

OF AGREEMENT REGARDING EAGLE MANAGEMENT AT LAKE ANNA

Dear Mr. Chezik:

On August 21, 2006, you provided us with the Department of Interior’s comments on the

U.S. Nuclear Regulatory Commission’s (NRC) NUREG-1811, Supplement to the Draft

Environmental Statement for an Early Site Permit (ESP) at the North Anna ESP Site. You

stated that “with the exception of the issue discussed in the paragraph below, the Draft

Environmental Impact Statement adequately addresses issues of concern to the Department,

including those regarding fish and wildlife resources, as well as species protected by the

Endangered Species Act.” In the subsequent paragraph you recommended that the NRC

develop an eagle management plan to protect eagle habitat along sections of the lake shore

while allowing development in others. Further, you expressed interest in pursuing a

Memorandum of Agreement with the NRC, Virginia Dominion Power, and the Virginia

Department of Game and Inland Fisheries (VDGIF) to address eagle management at Lake

Anna. As suggested in your letter, we contacted Eric Davis of the U.S. Fish and Wildlife

Service’s (FWS’s) Virginia Field Office and held a conference call with the above parties on

September 26, 2006. 

The purpose of the call was to discuss the request for a Memorandum of Agreement between

FWS and other parties regarding development of an eagle management plan. The participants

in the call were: Jack Cushing, NRC, Mike Sackchewsky, Pacific Northwest National

Laboratory, Eric Davis, FWS, Tony Banks, Dominion Nuclear North Anna, LLC, and

Andrew Zdanik and Jeff Cooper from VDGIF. 

FWS confirmed that consultation was completed and that this request was not being made as

part of the consultation process. The concern FWS expressed was that with the potential

de-listing of the bald eagle, it would no longer be protected under the Endangered Species Act,

but would be protected under the Bald and Golden Eagle Protection Act. Mr. Davis, thought

that protection of the bald eagle may be more difficult under the Bald and Golden Eagle

Protection Act than under the Endangered Species Act, therefore, an eagle management plan

at Lake Anna would make protection easier.

Appendix F

December 2006 F-117 NUREG-1811, Volume II
M. Chezik -2-

Dominion suggested that FWS may want to consider working with Louisa County on its

shoreline management guidelines as a possible means to address eagle management around

the lake. VDGIF express concern that there may not be funding for VDGIF to work on eagle

management once the eagle is delisted, because VDGIF is funded for the protection of

endangered species.

The NRC stated that it does consult with the FWS on the eagle under the Endangered Species

Act; however, the NRC does not have the regulatory authority to develop or enforce an eagle

management plan. Therefore, there is no reason for the NRC to develop such a plan or enter

into a memorandum of agreement regarding one. 

If you have any further questions regarding the request for a memorandum of agreement,

please contact the NRC Environmental Project Manager, Jack Cushing, at 301-415-1424, or

JXC9@nrc.gov.

Sincerely,

/RA/

Brent Clayton, Acting Chief

Environmental Projects Branch A

Division of Site and Environmental Reviews

Office of New Reactors

Docket No. 52-008

cc: See next page

Appendix F

NUREG-1811, Volume II F-118 December 2006
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-1811 Vol. 2

3. DATE REPORT PUBLISHED

MONTH

December

YEAR

2006

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

NUREG-1811: Final Environmental Impact Statement (FEIS) Regarding Early Site Permit (ESP)

for North Anna ESP Site

Final Report

5. AUTHOR(S)

See Appendix A of report

6. TYPE OF REPORT

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 Reviews

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, 

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

Docket Nos. 52-008

11. ABSTRACT (200 words or less)

This environmental impact statement (EIS) has been prepared in response to an application submitted to the U.S. Nuclear

Regulatory Commission (NRC) by Dominion Nuclear North Anna, LLC (Dominion), for an early site permit (ESP). The proposed

action requested in Dominion's application is for the NRC to (1) approve a site within the existing North Anna Power Station

(NAPS) boundaries as suitable for the construction and operation of one or more new nuclear power generating facilities and (2)

issue an ESP for the proposed site located at NAPS. The proposed action does not include any decision or approval to

construct or operate one or more units; these are matters that would be considered only upon the filing of applications for a

construction permit and an operating license, or an application for a combined license.

The staff's recommendation to the Commission related to its environmental review of the proposed action is that the ESP should

be issued. This recommendation is based on (1)the Environmental Report (ER) submitted by Dominion; (2) consultation with

Federal, State, Tribal, and local agencies; (3) the staff's independent review; (4) the staff's consideration of public comments on

both the Draft EIS and the SDEIS; and (5) the assessments summarized in this Final EIS, including the potential mitigation

measures identified in the ER and in the EIS. In addition, in making its recommendation, the staff has concluded that the

alternative sites considered are not obviously superior to the proposed site. Finally, the staff concludes that the site preparation

and preliminary construction activities enumerated in 10 CFR 50.10(e)(1) would not result in any significant adverse

environmental impact that cannot be redressed.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

North Anna ESP Site

National Environmental Policy Act

NEPA

Environmental Impact Statement

EIS

Early Site Permits

ESP

New Reactors

North Anna

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, DC 20555-0001

Same as 8. above