Safety

Evaluation

Report for an

Early Site

Permit (ESP)

at the North

Anna ESP Site

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Washington, DC 20555-0001

September 2005
! .- - 1

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I I
-11.- -

NUREG-1835

Safety Evaluation Report

for an Early Site Permit (ESP)

at the North Anna ESP Site

Manuscript Completed: September2005

Date Published: September 2005

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 205$5-0001
ABSTRACT

This safety evaluation report (SER) documents the U.S. Nuclear Regulatory Commission (NRC)

staff's technical review of the site safety analysis report and emergency planning information

included in the early site permit (ESP) application submitted by Dominion Nuclear North Anna,

LLC (Dominion or the applicant), for the North Anna ESP site. By letter dated September 25,

2003, Dominion submitted the ESP application for the North Anna ESP site in accordance with

Subpart A, "Early Site Permits," of Title 10, Part 52, "Early Site Permits; Standard Design

Certifications; and Combined Licenses for Nuclear Power Plants," of the Code of Federal

Regulations. The North Anna ESP site is located approximately 40 miles north-northwest of

Richmond, Virginia, and is adjacent to two existing nuclear power reactors operated by Virginia

Electric and Power Company, which, like Dominion Nuclear North Anna, LLC, is a subsidiary of

Dominion Resources, Inc. In its application, Dominion seeks an ESP that could support a

future application to construct and operate one or more additional nuclear power reactors at the

ESP site, with a total nuclear generating capacity of up to 8600 megawatts (thermal).

This SER presents the results of the staff's review of information submitted in conjunction with

the ESP application. The staff has identified, in Appendix A to this SER, certain site-related

items that will need to be addressed at the combined license or construction permit stage,

should an applicant desire to construct one or more new nuclear reactors on the North Anna

ESP site. The staff determined that these items do not affect the staff's regulatory findings at

the ESP stage and are, for reasons specified in Section 1.7, more appropriately addressed at

later stages in the licensing process. In addition, Appendix A to this SER also identifies the

proposed permit conditions that the staff recommends the Commission impose, should an ESP

be issued to the applicant.

...
TABLE OF CONTENTS

ABSTRACT............................................................... iii

CONTENTS ............................................................... v

EXECUTIVE SUMMARY .................. xiii

ABBREVIATIONS ......................................................... XV

1. INTRODUCTION AND GENERAL DESCRIPTION .............................. 1-1

1.1 Introduction........ .. 1-1

1.2 General Site Description ................................. 1-3

1.3 Plant Parameter Envelope ......................... 1-5

1.4 Identification of Agents and Contractors ............................... 1-7

1.5 Summary of Principal Review Matters ............... .............. 1-7

1.6 Summary of Open and Confirmatory Items . ............................. 1-8

1.7 Summary of Combined License Action Items ....... .................... 1-8

1.8 Summary of Permit Conditions ...................................... 1-9

2. SITE CHARACTERISTICS . ....................................... 2-1

2.1 Introduction ...................................................-. 2-1

2.1.1 Site Location and Description ................................. 2-1

2.1.2 Exclusion Area Authority and Control ......... ................. 2-4

2.1.3 Population Distribution ..................................... 2-8

2.2 Nearby Industrial, Transportation, and Military Facilities .................. 2-13

2.2.1-2.2.2 Identification of Potential Hazards in Site Vicinity .... ....... 2-13

2.2.3 Evaluation of Potential Accidents ....... ..................... 2-17

2.3 Meteorology ................... ..................... 2-19

2.3.1 Regional Climatology ..................................... 2-20

2.3.2 Local Meteorology ....................................... 2-36

-2.3.3 Onsite Meteorological Measurements Program ........ ; ........ 2-42

2.3.4 Short-Term (Accident) Diffusion Estimates . .............. 2-46

2.3.5 Long-Term (Routine) Diffusion Estimates -....................... 2-51

2.4 Hydrology ........................................... 2-58

2.4.1 Hydrologic Description . .................. ....... 2-58 ;. 

2.4.2 Floods .. 2-67

2.4.3 PMF on Streams and Rivers. 2-73

2.4.4 Potential Dam Failures .. 2-84

.v
LA

2.4.5 Probable Maximum Surge and Seiche Flooding .2-89

2.4.6 Probable Maximum Tsunami Flooding .2-94

2.4.7 Ice Effects .2-99

2.4.8 Cooling Water Canals and Reservoirs .2-108

2.4.9 Channel Diversions .2-111

2.4.10 Flooding Protection Requirements .2-114

2.4.11 Low-Water Considerations .2-116

2.4.12 Ground Water .2-123

2.4.13 Accidental Releases of Liquid Effluents to Ground and Surface

Waters .2-128

2.4.14 Site Characteristics Related to Hydrology .2-137

2.5 Geology, Seismology, and Geotechnical Engineering .2-140

2.5.1 Basic Geologic and Seismic Information .2-140

2.5.2 Vibratory Ground Motion .2-168

2.5.3 Surface Faulting .2-202

2.5.4 Stability of Subsurface Materials and Foundations .2-209

2.5.5 Stability of Slopes .2-245

2.5.6 Embankments and Dams .2-250

3. DESIGN. ............................................................. 3-1

3.5.1.6 Aircraft Hazards .3-1

11. RADIOLOGICAL EFFLUENT RELEASE DOSE CONSEQUENCES FROM NORMAL

OPERATIONS .11-1

11.1 Source Terms .11-1

11.1.1 Technical Information in the Application .11-1

11.1.2 Regulatory Evaluation .11-1

11.1.3 Technical Evaluation .11-2

11.1.4 Conclusions .11-3

13. CONDUCT OF OPERATIONS .. 13-1

13.3 Emergency Planning .13-1

13.3.1 Significant Impediments to the Development of Emergency Plans . . 13-2

13.3.2 Contacts and Arrangements with Local, State, and Federal Agencies 13-6

13.3.3 Major Features of the Emergency Plans .13-8

13.6 Industrial Security ..................... 13-59

13.6.1 Technical Information in the Application ..................... 13-59

13.6.2 Regulatory Evaluation .................................. 13-59

13.6.3 Technical Evaluation ................................... 13-60

13.6.4 Conclusions .......................................... 13-62

vi
15. ACCIDENT ANALYSES ................................................ 15-1

15.1 Technical Information in the Application ........ ..................... 15-1

15.2 Regulatory Evaluation ............................................ 15-3

15.3 Technical Evaluation .......................................... 15-4

15.3.1 Selection of DBAs .............. 15-4

15.3.2 Design-Specific (Assumed) X/Q Values .......................... 15-5

15.3.3 Site-Specific x/Qs ....................................... 15-5

15.3.4 Source Terms and Radiological Consequence Evaluations ....... 15-5

15.4 Conclusions ................................................... 15-8

17. EARLY SITE PERMIT QUALITY ASSURANCE MEASURES ........ ........... 17-1

17.0 Introduction ......................................... 17-1

17.1 Organization . ......................................... 17-2

17.1.1 Technical Information in the Application ......... .............. 17-2

17.1.2 Regulatory Evaluation ..................................... 17-2

17.1.3 Technical Evaluation ..................................... 17-3

17.1.4 Conclusion .......................................... ;.17-4

17.2 Quality Assurance Program ........... 17-4

17.2.1 Technical Information in the Application ........ .............. 17-4

17.2.2 Regulatory Evaluation ...................... ' .'.17-4

17.2.3 Technical Evaluation ..................... 17-5

17.2.4 Conclusion ............ 17-6

17.3 Design Control ............................ 17-6

17.3.1 Technical Information in the Application ................ 17-6

17.3.2 Regulatory Evaluation ................................... 17-7

17.3.3 Technical Evaluation ................................... 17-7

17.3.4 Conclusion ............................................. . 17-10

17.4 Procurement Document Control .. ........................... 17-10

17.4.1 Technical Information in the Application ............ ;; 17-10

17.4.2 Regulatory Evaluation .... ... 17-10

17.4.3 Technical Evaluation . . .17-11

17.4.4 Conclusion ........... -..-. -... 17-12

17.5 Instructions, Procedures, and Drawings .............................. 17-12

17.5.1 Technical Information in the Application ......................... 17-12

17.5.2 Regulatory Evaluation ............... 17-12

17.5.3 Technical Evaluation . 17-13

17.5.4 Conclusion ............. .. .. ' . ; .. 17-14

vii
. - -- Li

17.6 Document Control ........... .................................. 17-15

17.6.1 Technical Information in the Application ..................... 17-15

17.6.2 Regulatory Evaluation .................................. 17-15

17.6.3 Technical Evaluation ................................... 17-15

17.6.4 Conclusion ........................................... 17-15

17.7 Control of Purchased Material, Equipment, and Services .... ........... 17-16

17.7.1 Technical Information in the Application ..................... 17-16

17.7.2 Regulatory Evaluation .................................. 17-16

17.7.3 Technical Evaluation ................................... 17-16

17.7.4 Conclusion ........................................... 17-21

17.8 Identification and Control of Materials, Parts, and Components .... ...... 17-21

17.8.1 Technical Information in the Application ..................... 17-21

17.8.2 Regulatory Evaluation... ...... : 17-21

17.8.3 Technical Evaluation .17-22

17.8.4 Conclusion .17-22

17.9 Control of Special Processes .17-22

17.9.1 Technical Information in the Application .17-22

17 .9.2 Regulatory Evaluation .17-22

17.9.3 Technical Evaluation .17-23

17.9.4 Conclusion .17-23

17.10 Inspection .17-23

17.10.1 Technical Information in the Application .17-23

17.10.2 Regulatory Evaluation .17-24

17.10.3 Technical Evaluation .17-24

17.10.4 Conclusion .17-25

17.11 Test Control .17-25

17.11.1 Technical Information in the Application .17-25

17.11.2 Regulatory Evaluation .17-26

17.11.3 Technical Evaluation .17-26

17.11.4 Conclusion .17-27

17.12 Control of Measuring and Test Equipment ......................... 17-27

17.12.1 Technical Information in the Application .................... 17-27

17.12.2 Regulatory Evaluation ................................. 17-28

17.12.3 Technical Evaluation .................................. 17-28

17.12.4 Conclusion .......................................... 17-29

17.13 Handling, Storage, and Shipping ................................ 17-29

viii
17.13.1 Technical Information in the Application ..... ............... 17-29

17.13.2 Regulatory Evaluation .17-30

17.13.3 Technical Evaluation .................................. 17-30

17.13.4 Conclusion .................... 17-31

17.14 Inspection, Test, and Operating Status .17-31

17.14.1 Technical Information in the Application .17-31

17.14.2 Regulatory Evaluation .17-32

17.14.3 Technical Evaluation .................... 17-32

17.14.4 Conclusion ......... .................................. 17-33

17.15 Nonconforming Materials, Parts, or Components ................... 17-33

17.15.1 Technical Information in the Application .................... 17-33

17.15.2 Regulatory Evaluation ................................. 17-33

17.15.3 Technical Evaluation .................................. 17-34

17.15.4 Conclusion .... ................................... 17-35

17.16 Corrective Action .17-35

17.16.1 Technical Information in the Application .17-35

17.16.2 Regulatory Evaluation .17-35

17.16.3 Technical Evaluation .................... 17-36

17.16.4 Conclusion .................... 17-36

17.17 Quality Assurance Records .................................... 17-37

17.17.1 Technical Information in the Application .................... 17-37

17.17.2 Regulatory Evaluation ................................... 17-37

17.17.3 Technical Evaluation ................................... 17-38

17.17.4 Conclusion ...... .................................... 17-39

17.18 Audits . ................................................... 17-39

17.18.1 Technical Information in the Application . .............. 17-39

17.18.2 Regulatory Evaluation .................................. 17-40

17.18.3 Technical Evaluation .................... 17-40

17.18.4 Conclusion -........................... 17-41

17.19 Conclusions . ............ 17-42

18. REVIEW BY THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS .... ... 18-1

19. CONCLUSIONS ............. ;.-...19-1

ix
ILi I

Appendices

A North Anna ESP Permit Conditions, COL Action Items, Site Characteristics, and

Bounding Parameters for the Site ............ ........................... A-1

B Chronology of Early Site Permit Application for the North Anna ESP Site .... ..... B-1

C References ..................................................... C-1

D Principal Contributors ................................................. D-1

E Report by the Advisory Committee on Reactor Safeguards ...... .............. E-1

Figures

2.2.1-1 Major roads, railways, and gas pipelines in the vicinity of the ESP site .... ..... 2-15

2.4.3-1 Depth-area-duration curves prepared for bracketing North Anna drainage area. . 2-78

2.4.3-2 Inflow and outflow hydrographs for North Anna reservoir during the PMF event .. 2-81

2.4.3-3 Reservoir elevation during the PMF event ............................... 2-81

2.4.3-4 Applicant's original (black line) and staff's conservative (red line) unit hydrographs 2-83

2.4.5-1 North Anna Power Station site and fetch length .. . 2-93

2.4.6-1 Landslide diagram resulting in wave traveling towards the ESP site. .. . 2-97

2.4.6-2 Initial conditions for the numerical model. .. . 2-98

2.4.6-3 Highest extent of wave runup on shore .. . 2-99

2.4.7-1 Accumulated degree-days since December 1, 1976, at the Piedmont Research

Station meteorologic station .. . 2-105

2.4.14-1 The proposed facility boundary for the ESP site .. . . 2-139

2.5.1-1 Regional physiographic map (200-mi radius) .. . 2-142

2.5.1-2 Simplified tectonostratigraphic map .. . 2-144

2.5.1-3 Quaternary features map ... 2-147

2.5.1-4 Seismic source zones and seismicity in central and eastern North America .... 2-150

2.5.1-5 Site topographic map (0.6-mi radius) ... 2-153

2.5.1-6 Map showing general area of coverage of Obermeier and McNulty (1998) liquefaction

study relative to interpretations of the Central Virginia Seismic Zone. ... 2-160

2.5.2-1 Magnitude-distance deaggregation for low frequencies (1 and 2.5 Hz) at a mean

annual frequency of 5x105 using updated source and ground motion models . . 2-179

2.5.2-2 Magnitude-distance deaggregation for high frequencies (5 and 10 Hz) at a mean

annual frequency of 5x105 using updated source and ground motion models . . 2-180

2.5.2-3 Comparison of performance-based spectrum, mean 5x10 5 scaled spectra, and

selected SSE spectrum (which overlaps the performance-based spectrum and

envelops the other two) .. . 2-182

2.5.2-4 Response Zone III-IV control point (Elevation 250 ft., Layer 1) - 5% Critical Damping

ARS - High Frequency (upper dark gray group) and Low Frequency (lower light

gray group) time histories. .. . 2-184

2.5.2-5 Transfer Function for ESP Site .. . 2-185

2.5.2-6 (SSAR Figure 2.5-48A) Selected Horizontal and Vertical Response Spectra for the

Hypothetical Rock Outcrop Control Point SSE at the Top of Zone III-IV Material 2-187

2.5.2-7 Regional seismicity for ESP site .. . 2-191

x
2.5.3-1 Site vicinity geologic map and seismicity (25-mi radius) .................... 2-204

2.5.4-1 Subsurface Profile A-A' ............................................ 2-211

2.5.4-2 Subsurface Profile B-B' ............................................. 2-212

2.5.4-3 Locations of previous boreholes ...................................... 2-218

2.5.4-4 ESP borehole locations ............................................ 2-219

2.5.4-5 Variation of normalized shear modulus with cycle shear strain .... .......... 2-226

2.5.4-6 Variation of damping ratio with cyclic shear strain ........................ 2-228

Tables

2.3.1-1 Applicant's Proposed Ambient Air Temperature and Humidity Site Characteristics 2-22

2.3.1-2 Applicant's Proposed Basic Wind Speed Site Characteristic ..... ............ 2-23

2.3.1-3 Applicant's Proposed Tornado Site Characteristics ........................ 2-24

2.3.1-4 Tropical Cyclones Reported within 100-Nautical Mile Radius of the North Anna ESP

Site from 1851 through 2003 ........................................ 2-24

2.3.1-5 Applicant's Proposed Winter Precipitation Site Characteristics .... ........... 2-25

2.3.1-6 Applicant's Proposed Ultimate Heat Sink Meteorological Site Characteristics .... 2-27

2.3.1-7 Staff's Proposed Regional Climatic Site Characteristics ..................... 2-34

2.3.4-1 Applicant's Proposed Short-Term (Accident Release) Atmospheric Dispersion Site

Characteristics .................... 2-48

2.3.4-2 Staff's Proposed Short-Term (Accident Release) Atmospheric Dispersion Site

Characteristics .............. ..................................... 2-51

2.3.5-1 Applicant's Long-Term (Routine Release) Diffusion Estimates .... ........... 2-53

2.3.5-2 Staff's Proposed Long-Term (Routine Release) Atmospheric Dispersion Site

Characteristics . .................................................. 2-56

2.4.2-1 Local Intense Precipitation (1-mi 2 PMP) at the North Anna ESP Site .... ....... 2-71

2.4.3-1 Probable Maximum Precipitation Values for the North Anna Dam Drainage Area . 2-77

2.4.3-2 PMP Depth-Duration Values for the North Anna Dam Drainage Area .... ...... 2-78

2.4.3-3 Time Distribution of PMP for the North Anna Dam Drainage ..... ............. 2-79

2.4.3-4 PMF into Lake Anna ............................................... 2-79

2.4.14-1 Staff's Proposed Site Characteristics Related to Hydrology ...... .......... 2-138

2.5.2-1 Updated Seismic Hazard Results at ESP Site ........................... 2-177

15.3-1 Staff's Proposed Short-Term (Accident Release) Atmospheric Dispersion Site

Characteristics (Site-Specific x/Q Values ................................ 15-7

xi
EXECUTIVE SUMMARY

Title 10, Part 52, "Early Site Permits; Standard Design Certifications; and Combined Licenses

for Nuclear Power Plants" of the-Code of Federal Regulations (10 CFR Part 52) contains

requirements for licensing, construction, and operation of new nuclear power plants.' These

regulations address early site permits (ESPs), design certifications, and combined licenses

(COLs). The ESP process (Subpart A, "Early Site Permits," of 10 CFR Part 52) is intended to

address and resolve site-related issues. The design certification process (Subpart B, "Standard

Design Certifications," of 10 CFR Part 52) provides a means for a vendor to obtain U.S. Nuclear

Regulatory Commission (NRC) certification of a particular reactor design. Finally, the COL

process (Subpart C, "Combined Licenses," of 10 CFR Part 52) allows an applicant to seek

authorization to construct and operate a new nuclear power plant. A COL may reference an

ESP, a certified design, both, or neither. It is incumbent on a COL applicant to resolve issues

related to licensing that were not resolved as part of an ESP or design certification proceeding

before the NRC can issue a COL.

This safety evaluation report (SER) describes the results of a review by NRC staff of an ESP

application submitted by Dominion Nuclear North Anna, LLC (Dominion or the applicant), for the

North Anna ESP site. The staff's review verified the applicant's compliance with the

requirements of Subpart A of 10 CFR Part 52. This SER serves to identify the matters resolved

in the safety review and to identify remaining items to be addressed by a future COL applicant.

The NRC regulations also contain requirements for an applicant to submit an environmental

report pursuant to 10 CFR Part 51, "Environmental Protection Regulations for Domestic

Licensing and Related Regulatory Activities." The NRC reviews the environmental report as

part of the Agency's responsibilities under the National Environmental Policy Act of 1969, as

amended. -The NRC presents the results of that review in a final environmental impact

statement, which is a report separate from this SER.

By letter dated September 25, 2003, Dominion submitted an ESP application (ADAMS.

Accession No. ML032731517)2 for the North Anna ESP site. The North Anna ESP site is

located approximately 40 miles north-northwest of Richmond, Virginia, and is adjacent to two

existing nuclear power reactors operated by Virginia Electric and Power Company.

In accordance with 10 CFR Part 52, Dominion submitted inforrmation in its ESP application that

includes (1) a description of the site and nearby areas that could affect or be affected by a

nuclear power plant(s) located at the site, (2) a safety assessment of the site on which the

'Applicants may also choose to seek a construction permit and operating license in accordance with

10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," instead of using the 10 CFR Part 52

process.

; 2ADAMS (Agencywide Documents Access and Management System) is the NRC's information system that

provides access to all image and text documents that the NRC has made public since November 1 1999. as well as

bibliographic records (some with abstracts and full text) that the NRC made public before November 1999.

Documents available to the public may be accessed via the Internet at - http://www.nrc.pov/readinp-rm/adams/web-based.html. Documents may also be viewed by visiting the NRC's Public

Document Room at One White Flint North, 11555 Rockville Pike, Rockville, Maryland. Telephone assistance for

using web-based ADAMS is available at (800) 397-4209 between 8:30 a.m. and 4:15 p.m., eastern standard time,

Monday through Friday, except Federal holidays. The staff is also making this SER available on the NRC's new

reactor licensing public Web site at http:llwww.nrc.aov/reactors/new-licensing/esp/north-anna.html.

xiii
facility would be located, including an analysis and evaluation of the major structures, systems,

and components of the facility that bear significantly on the acceptability of the site, and

(3) proposed major features of emergency plans. The application describes how the site

complies with the requirements of 10 CFR Part 52 and the siting criteria of 10 CFR Part 100,

"Reactor Site Criteria."3

This SER presents the conclusions of the staff's review of information the applicant submitted

to the NRC in support of the ESP application. The staff has reviewed the information provided

by the applicant to resolve the open and confirmatory items identified in the draft safety

evaluation report for the North Anna ESP, issued on December 20, 2004. In Section 1.6 of this

SER, the staff provides a brief summary of the process used to resolve these items; specific

details on the resolution for each open item is presented in the corresponding section of this

report.

The staff has identified, in Appendix A to this SER, the proposed permit conditions that it will

recommend the Commission impose, should an ESP be issued to the applicant. Appendix A

also includes a list of COL action items or certain site-related items that will need to be

addressed at the COL or construction permit stage, should an applicant desire to construct one

or more new nuclear reactors on the North Anna ESP site. The staff determined that these

items do not affect the staff's regulatory findings at the ESP stage and are, for reasons

specified in Section 1.7, more appropriately addressed at these later stages in the licensing

process. In addition, Appendix A lists the site characteristics and the bounding parameters

identified by the staff for this site.

Inspections conducted by the NRC have verified, where appropriate, the conclusions in this

SER. The scope of the inspections consisted of selected information in the ESP application

and its references. This SER identifies applicable inspection reports as reference documents.

The NRC's Advisory Committee on Reactor Safeguards (ACRS) also reviewed the bases for

the conclusions in this report. The ACRS independently reviewed those aspects of the

application that concern safety, as well as the safety evaluation report, and provided the results

of its review to the Commission in the interim report dated March 11, 2005 and in a final report

dated July 18, 2005. This SER incorporates the ACRS comments and recommendations, as

appropriate. Appendix E includes a copy of the report by the ACRS on the final safety

evaluation, as required by 10 CFR 52.53, "Referral to the ACRS."

3 The applicant has also submitted information intended to partially address some of the general design

criteria (GDC) in Appendix A, 'General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic

Ucensing of Production and Utilization Facilities." Only GDC 2, 'Design Bases for Protection Against Natural

Phenomena," applies to an ESP application, and it does so only to the extent necessary to determine the safeshutdown earthquake (SSE) and the seismically induced flood. The staff has explicitly addressed partial compliance

with GDC 2, in accordance with 10 CFR 52.17(a)(1) and 10 CFR 50.34(a)(12), only in connection with the applicant's

analysis of the SSE and the seismically induced flood. Otherwise, an ESP applicant need not demonstrate

compliance with the GDC. The staff has included a statement to this effect in those sections of the SER that do not

relate to the SSE or the seismically induced flood. Nonetheless, this SER describes the staff's evaluation of

information submitted by the applicant to address GDC 2.

xiv
ABBREVIATIONS

ABWR

ac

ACR-700

ADAMS

ALARA

ALI

ALWR

ANS

ANSI

ANSS

AP1000

ARA

ASCE

ASHRAE

ASME

ASTM

ASTM

BRH

BWR

CDE

CEUS

CFR

COL

COVRERP

CP

CPT

CVSZ

DAC

DBA

DCD

DEIS

DEM

DOE

DSER

EAB

EAC

EAL

EAS

ECFS

EDP

EDPI

EDS

EIS

EMI

ENS

EOC

EOF

advanced boiling water reactor

acre

Atomic Energy of Canada Advanced CANDU Reactor

Agencywide Documents Access and Management System

as low as is reasonably achievable

annual limits on intake

advanced light-water reactor

alert and notification system

American National Standards Institute

Advanced National Seismic System

Westinghouse Advanced Plant 1000

Applied Research Associates

American Society of Civil Engineers

American Society of Heating, Refrigerating and Air-Conditioning Engineers

American Society of Mechanical Engineers

American Society for Testing and Materials

American Society for Testing and Materials

Bureau of Radiological Health

boiling water reactor

committed dose equivalent

central and eastern United States

Code of Federal Regulations

combined license

Commonwealth of Virginia Radiological Emergency Response Plan

construction permit

cone penetrometer test

Central Virginia Seismic Zone

derived air concentration

design-basis accident

design control document

draft environmental impact statement

Department of Emergency Management

Department of Energy

draft safety evaluation report

exclusion area boundary

evacuation assembly center'

emergency action level

emergency alert system

East Coast fault system

engineering department procedure

engineering department instructions

engineering design spectrum

environmental impact statement

Emergency Management Instituteemergency notification system

emergency operations center

emergency operations facility

I !

Xv
EPA Environmental Protection Agency

EPDS electronic procedure distribution system

EPIP emergency plan implementing procedure

EPRI Electric Power Research Institute

EPZ emergency planning zone

ER Environmental Report

ERDS Emergency Response Data System

ERO emergency response organization

ESBWR General Electric Economic and Simple Boiling Water Reactor

ESE east-southeast

ESIM evacuation simulation model

ESP early site permit

EST earth science team

ETE evacuation time estimate

ETSZ Eastern Tennessee Seismic Zone

FAA Federal Aviation Administration

FEMA Federal Emergency Management Agency

FRERP Federal Radiological Emergency Response Plan

FRMAC Federal Radiological Monitoring and Assessment Center

FRP Federal Response Plan

FS factor of safety

FSER final safety evaluation report

ft foot/feet

gal gallon

GBU Global Business Unit

GDC general design criterion

GIS Geographical Information System

GSA Geological Society of America

GT-MHR General Atomics Gas Turbine Modular Helium Reactor

HEAR hospital emergency and administrative radio

HEC Hydrologic Engineering Center

HMR hydrometeorological report

HPN health physics network

Hz hertz

IEM Innovative Emergency Management, Inc.

In. inch

INPO Institute of Nuclear Power Operations

IRIS International Reactor Innovative and Secure Reactor

ISFSI independent spent fuel storage installation

ISO International Organization for Standardization

KI potassium iodide

kPa kiloPascals

lb pound

Ibf/ft pound-force per square foot

LFA lead Federal agency

LLNL Lawrence Livermore National Laboratory

LOCA loss-of-coolant accident

LPZ low-population zone

LWR light water reactor

M&TE measuring and test equipment

xvi
MCVH Medical College of Virginia Hospitals

MEI maximally exposed individual

mi/hr miles per hour

MIDAS meteorological information and dose assessment system

MMI modified mercalli intensity

mrem millirem

MSL mean sea level

mSv milliSievert

MT&E measuring and test equipment

MWt megawatt thermal

NAEP North Anna Emergency Plan

NAPS North Anna Power Station

NBU Nuclear Business Unit

NCDC National Climatic Data Center

NDCM Nuclear Design Control Manual

NDCP Nuclear Design Control Program

NGVD National Geodetic Vertical Datum

NE northeast

NEI Nuclear Energy Institute

NEP nuclear emergency preparedness

nmi nautical mile

NMSZ New Madrid Seismic Zone

NNE north-northeast

NOAA National Oceanic and Atmospheric Administration

NPSEPT Nuclear Power Station Emergency Preparedness Training.

NQAM Nuclear Quality Assurance Manual

NRC U.S. Nuclear Regulatory Commission

NRRL nuclear-required records list

NSSL National Severe Storms Laboratory

NUPIC Nuclear Utility Procurement Issues Committee

NWS National Weather Service

OBE operating-basis earthquake

ODEC Old Dominion Electric Cooperative

OL operating license

OREMS Oak Ridge Evaluation Modeling System

OSC operational support center

OW observation well

PAG protective action guideline

PAR protective action recommendation

PAZ protective action zone

PBMR pebble bed modular reactor

PGA peak ground acceleration

PMCL protective measures counterpart link

PMF probable maximum flood

PMH probable maximum hurricane

PMP probable maximum precipitation

PMWP probable maximum winter precipitation

PNNL Pacific Northwest National Laboratories

PO purchase order

PPE plant parameter envelope

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PPR potential problem reporting

PQAM project quality assurance manager

PSHA probabilistic seismic hazard analysis

psi pound per square inch

PWR pressurized-water reactor

QA quality assurance

QAPD quality assurance program description

QAPP quality assurance program plan

RAA remote assembly area

RAI request for additional information

RAP radiological assistance program

REI Risk Engineering, Inc.

RERP radiological emergency response plan

RERT Radiological Emergency Response Team

RIC Richmond International Airport

RG regulatory guide

RQD rock quality designation

RS review standard

RSCL reactor safety counterpart link

s second

S south

SCC State Corporation Commission

SCR stable continental regions

SCS Soil Conservation Service

SE southeast

SEI Structural Engineering Institute

SER safety evaluation report

SF scale factor

SPT standard penetration test

SQAP software quality assurance plan

SRCC Southern Regional Climate Center

SSAR site safety analysis report

SSC system, structure, and component

SSE safe-shutdown earthquake

SSHAC Senior Seismic Hazard Advisory Committee

SW southwest

SWR service water reservoir

TEDE total effective dose equivalent

TLD thermoluminescent dosimeter

TSC technical support center

UFSAR updated final safety analysis report

UHF ultra-high frequency

UHS ultimate heat sink

ULF ultra-low frequency

USACE U.S. Army Corps of Engineers

USBR United States Bureau of Reclamation

USGS United States Geological Survey

VCU Virginia Commonwealth University

VDEM Virginia Department of Emergency Management

VDGIF Virginia Department of Game and Inland Fisheries

xviii
VDH Virginia Department of Health

VSP Virginia State Police

VT Virginia Polytechnic Institute and State University

WHTF waste heat treatment facility

ZPA zero period acceleration

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1. INTRODUCTION AND GENERAL DESCRIPTION

1.1 Introduction

Dominion Nuclear North Anna, LLC (Dominion or the applicant), filed an application with the

U.S. Nuclear Regulatory Commission (NRC),'docketed on October 23, 2003, for an early site

permit (ESP) for a site the applicant designated as the North Anna ESP site. The proposed site

is located near Lake Anna in Louisa County, Virginia, approximately 40 miles (mi) northnorthwest of Richmond,' Virginia.

The staff has completed its review in the areas of seismology, geology,' meteorology, and

hydrology, as well as in the area of hazards to a nuclear power plant that could result from

manmade facilities and activities on or in the vicinity of the site. The staff also assessed the

risks 0f potential accidents that could occur as a result of the operation of a nuclear plant or

plants at'the site and evaluated whether the site could support adequate physical security

measures for a nuclear power plant or plants. 'The staff evaluated whether the applicant's

quality assurance measures are equivalent in substance to the measures discussed in

Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing

Plantse to Title 10, Part 50, "Domestic Licensing of Production 'and Utilization Facilities," of the

Code of Federal Regulations (10 CFR Part 50). The NRC has found that such measures

provide reasonable assurance that information derived from' ESP activities that would be used

in the design and/or construction of structur6s,- systems, and components (SSCs) important to

safety would support satisfactory performance of such SSCs once in service. The staff also

evaluated the adequacy of the applicant's program for compliance with 10 CFR Part 21, -

"Reporting of Defects and Noncompliance." -Finally, the staff reviewed the proposed major

features of the emergency plan that Dominion would implement if a new reactor(s) is eventually

constructed at the ESP site. The NRC would need to review the complete and integrated

emergency plan in a separate licensing proceeding.

The Dominion ESP application includes'the site safety analysis report (SSAR), which describes

the safety asses'sme'nt of the site, as required by 10 CFR 52.17, "Contents of Applications."

The public may inspect copies of this document via the Agencywide Documents Access and

Management System (ADAMS) using ADAMS Accession No. ML032731517.4 Dominion

subsequently revised the application to address requests from'the NRC staff for additional

information'. The-applicant submitted the m6st recent version of its-application, SSAR

Revision 5 (ADAMS Accession-No. ML052150226), to the'Commission by letter dated July 25,

2005. Throughout the course of the review, the'staff requested that the'applicant submit:

additional information' to clarify the description of the North Anna site. This report'discusses

some of the applicant's responses to these requests for additional information (RAls).

4

ADAMS (Agencywide Documents Access and Management System) is the NRC's information system that

provides access to all image and text documents that the NRC has made public since November 1,1 999, as well as

bibliographic records (some with abstracts and full text) that the NRC made public before November 199:

Documents available to the public may be accessed via the Internet at ' -

http://www.nrcd.cov/readinQ-rm/adams/web-based.htrml.- Documents may also be viewed by visiting the NRCs Public

Document Room at One White Flint North, 11555 Rockville Pike, Rockville, Maryland. Telephone assistance for

using web-based ADAMS is available at (800) 397-4209 between 8:30 a.m. and 4:15 p.m., eastern standard time,

Monday through Friday, except Federal holidays. The staff is also making this SER available on the NRC's new

reactor licensing public Web site at http//www nrc.aov/reactors/new-licensina/esp/north-anna.html.

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Appendix B to this report provides a chronological listing of the licensing correspondence

between the applicant and the Commission regarding the review of the North Anna ESP

application under Project No. 719 and Docket No. 52-008. The application and other pertinent

information and materials are available for public inspection at the NRC's Public Document

Room at One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The application and

this safety evaluation report (SER) are also available at the Louisa County Public Library, 881

Davis Highway, Mineral, Virginia, as well as on the NRC's new reactor licensing public Web site

at httD://www.nrc.oov/reactors/new-licensina/esp/north-anna.html.

This report summarizes the results of the NRC staff's technical evaluation of the suitability of

the proposed North Anna ESP site for a nuclear power plant or plants falling within the plant

parameter envelope (PPE) that Dominion specified in its application. This SER delineates the

scope of technical matters the staff considered in evaluating the suitability of the site. NRR

Review Standard (RS)-002, 'Processing Applications for Early Site Permits," issued May 2004,

provides additional details on the scope and bases of the NRC staff's review of the radiological

safety and emergency planning aspects of a proposed nuclear power plant site. This review

standard contains regulatory guidance based on NUREG-0800, "Standard Review Plan for the

Review of Safety Analysis Reports for Nuclear Power Plants," Revision 3, issued July 1981

(hereinafter referred to as the Standard Review Plan). The Standard Review Plan reflects the

many years of experience the NRC staff has had in establishing and promulgating guidance to

enhance the safety of nuclear facilities, as well as in evaluating safety assessments. Numerous

sections and chapters in Standard Review Plan are not within the scope of or addressed in an

early site permit (ESP) proceeding. The reader will therefore note "missing" chapter and

section numbers in this document. The subjects of chapters and sections in Standard Review

Plan not addressed herein will be addressed, as appropriate and applicable, in other regulatory

actions (design certification, construction permit, operating license, and/or combined license)

for a reactor or reactors that might be constructed on the North Anna ESP site. In addition, this

SER documents the resolution of the open and confirmatory items identified in the draft SER

(DSER) for the North Anna ESP, issued on December 20, 2004.

The applicant also filed an environmental report for the North Anna ESP site in which it

evaluated those matters relating to the environmental impact assessment that can be

reasonably reviewed at this time. The staff discussed the results of its evaluation of the

environmental report for the North Anna ESP site in a draft environmental impact statement

(DEIS) issued on December 7, 2004 (ADAMS Accession No. ML043380308; also available on

the NRC's new reactor licensing public Web site). The applicant also provided a site redress

plan, in accordance with 10 CFR 52.17(c), in order to perform the site preparation and limited

construction activities allowed by 10 CFR 52.25(a) (i.e., the activities listed in 10 CFR

50.10(e)(1)). The DEIS also includes the results of the staff's evaluation of that plan.

As described above, the applicant supplemented the information in the SSAR by providing

revisions to the document. The staff reviewed these revisions to determine their impact on the

conclusions in this SER. On June 16, 2005, the NRC issued its SER for the North Anna ESP

site and made it publically available. In light of the SER, Dominion identified several corrections

that needed to be made to Revision 4 of its application. By letter dated July 25, 2005, Dominion

provided Revision 5 to the North Anna ESP application. The changes reflected in Revision 5 of

the application included corrections to Figure 2.5-55A, depicting the selected horizontal and

vertical operating-basis earthquake (OBE) and safe-shutdown earthquake (SSE) spectra for the

hypothetical rock outcrop control point at the top of Zone III-IV material. In addition, Dominion

provided corrections to the coordinates for the ESP site footprint which was submitted to the

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NRC in its response to Open Item 2.4-1. The staff completed its review of the most recent

version, Revision 5 of the SSAR, as documented throughout this report and, for the reasons set

forth herein, finds it to be acceptable. The changes in Revision 5 to the application resulted in

minor modifications to the staff's SER issued June 16, 2005 including the following changes:

Appendix A to this report was modified to reflect the correct figures submitted with Revision 5 of

the application; Section 2.5 of this report was modified to incorporate the correct description of

the analysis conducted by Dominion to determine the SSE spectrum and reflect the description

in the evaluation; the table of contents was modified to follow the same layout as the standard

review plan, and as a result the source term analysis was moved from Chapter 3 and placed in

Chapter 11. The scope of all other changes to the SER issued on-June 16, 2005 resulting from

Revision 5 are limited to corrections of factual inaccuracies. These changes did not impact the

staff's conclusions. 'Independent of Revision 5 to the application, the staff also reformatted and

reorganized the SER without changing its substance or conclusions, and revised the definitions

of Bounding Parameters for hydrology in'Appendix A to better reflect the SER text.

Appendix A to this SER contains the list of site characteristics, permit conditions, combined

license (COL) action items, and the bounding parameters that the staff is recommending that

the Commission include in any ESP that might be issued for the proposed site. Appendix B to

this SER details a chronology of the principal actions and correspondence related to the staff's

review of the ESP application for the North Anna ESP site. Appendix C lists the references for

this SER, Appendix D lists the principal contributors to this report, and Appendix E includes a

copy of the report by the ACRS.

1.2 General Site Description

The ESP site is a parcel of land on the North Anna Power Station (NAPS) site in Louisa County,

Virginia, approximately 40 mi north-northwest of Richmond, Virginia. The NAPS site includes

other, existing nuclear facilities licensed by the NRC, specifically NAPS Units 1 and 2 (Docket

Nos. 50-338/339; NRC Facility Operating License Nos. NPF-4/7) and the North Anna'

Independent Spent Fuel Storage Installation (NRC Docket No.' 72-16; Materials LicenseNo. SNM-2507). 'As shown in SSAR Figure 1'.2-4,the ESP site is'adjacent to and generally

west of the existing nuclear reactor units. -Th6 Virginia Electric and Power Company (Virginia

Power) and the Old Dominion Electric Cooperative'(ODEC) own the NAPS site as tenanits'in

common. Virginia Power is the licensed operator of the existing nuclear units, with control of

these facilities and the authority to act as the agent of ODEC. Virginia Power and the ESP

applicant, Dominion Nuclear North Anna, LLC, are direct and indirect-wholly owned

subsidiaries, respectively, of Domninion Resources, Inc.

The application stated that the NAPS site comprises 1803 acres (ac), of which about 760 ac are

covered by water. Virginia Power and ODEC own, and Virginia Power controls,- all of the land

within the NAPS site boundary,- including those portions of the North Anna Reservoir and waste

heat treatment facility (WHTF) that lie within the site boundary; These companies also own ally

land outside the NAPS site boundary that forms Lake Anna, up to the expected high-water

marks. The NAPS site and all supporting facilities, including the North Anna Reservoir, the

WHTF, the earth dam, dikes, railroad spur, and roads,' constitute approximately 18,643 ac.

Lake Anna, which includes the North Anna Reservoir and the WHTF, was created to serve the:

needs of the power station. -

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The application indicates that, if the ESP is granted and Dominion decides to proceed with the

development of new nuclear units on the ESP site, it would enter into and obtain, to the extent

necessary, appropriate Virginia State Corporation Commission (SCC) approval to construct and

operate any new unit at the North Anna ESP site. The Virginia Code requires SSC approval of

any agreement between the COL applicant and the current owners of the site providing for joint

control of the exclusion area. The staff proposes to include a condition to govern exclusion

area control on any ESP that might be issued. Section 2.1.2 of this report discusses this issue

in detail.

The application also indicates that if the ESP were granted and Dominion were to decide to

undertake any preconstruction activities described in the ESP, pursuant to 10 CFR 52.25,

"Extent of Activities Permitted," Dominion would enter into and obtain, to the extent necessary,

appropriate State public utility commission approval(s) of site redress or related agreement(s)

with Virginia Power before conducting the activities. The application states that the approval(s)

and agreement(s) would authorize the applicant to conduct the preconstruction activities and

that they would confirm Dominion's obligation to perform any site redress that might be needed,

pursuant to the NRC-approved site redress plan. The application states that Dominion's site

redress obligation would be supported by a guaranty provided by its ultimate parent company,

Dominion Resources, Inc.

Should the ESP holder decide to perform the activities authorized by 10 CFR 52.25, the ESP

holder will need to obtain the authority to undertake those activities on the ESP site. In

obtaining such right, the ESP holder must also obtain the corresponding right to implement the

site redress plan described in the staff's final environmental impact statement, in the event no

plant is built on the ESP site. The staff intends to include, in any ESP that might be issued for

this application, a permit condition to address this matter, as discussed in Section 2.1.2 of this

SER.

The largest community within 10 mi of the site is the town of Mineral, Virginia. According to the

2000 census, Mineral has a population of 424 located within about 1 mi2 (incorporated). As

reported in the NAPS updated final safety analysis report, the population in 1990 was 452.

Therefore, the population of Mineral has remained essentially constant during the past decade.

The 2000 resident population within 6 and 10 mi of the site was 5,890 and 15,511 persons,

respectively. The applicant estimated the total peak daily transient population on Lake Anna

(including the WHTF and Lake Anna State Park) to be less than 11,270. The nearest

population center to the ESP site with more than 25,000 residents is the City of Charlottesville,

Virginia, with a population of 45,049. The closest point of Charlottesville to the site is 36 mi to

the west.

No military bases, missile sites, manufacturing plants, chemical plants, chemical or other

storage facilities, airports, major railroad lines, major water transportation, or hazardous

material (e.g., oil or gas) pipelines are located within 5 mi of the ESP site. As previously noted,

the only industrial facilities within 5 mi of the ESP site are the existing NAPS units. Major

highways, such as Interstates 95 and 64, are located more than 16 mi away from the site. U.S.

Route 522 is located about 5 mi west of the site. The closest point of Virginia Route 652 is

1.5 mi to the south of the site. The only road that provides access to the site is State

Route 700, coming from the southwest to within about 0.5 mi of the site. No public or

commercial highways, railroads, or waterways traverse the site.

1-4
Three airports are located within 15 mi of the ESP site. Operations at the Louisa County Airport

(Freeman Field), located 11 mi west-southwest of the site, primarily involve single-engine light

aircraft. The Lake'Anna Airport, near Bumpass, Virginia, is 7 mi south-southeast of the site.

This airport has limited facilities.

1.3 Plant Parameter Envelope

The regulations at 10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and

Combined Licenses for Nuclear Power Plants," and 10 CFR Part 100, "Reactor Site Criteria,"

that apply to an ESP do not require an ESP applicant to provide specific design information.

However, some design information may be required to address 10CFR 52.17(a)(1), which-calls

for "an analysis and evaluation of the major structures, systems, and components of the facility

that bear significantly on the acceptability of the site under the radiological consequence

evaluation factors identified in § 50.34(a)(1) of this chapter."

In Section 1.3 of the ESP SSAR, Dominion provided a list of postulated design parameters,

referred to as the plant parameter envelope'(PPE). The applicant stated that the PPE

approach provides sufficient design details to support the NRC's review of the ESP application,

while recognizing that new reactor technologies, not envisioned at the time Dominion submitted

its ESP application, may become available in the future. Therefore, the applicant stated that it

based the PPE on data from selected reactor designs and that the PPE is intended to bound

multiple reactor designs. The applicant also stated that the actual reactor design selected

would be reviewed at the COL stage to ensure that the design fits within the PPE.

In RAI 1.3-1, the staff asked the applicant to explain its use of the plant parameters in SSAR

Table 1.3-1 for the cases in which site-specific characteristics are provided. The staff also

requested that the applicant clearly identify site characteristics and plant'design parameters that

it proposed be included as the bases for an ESP, should one be issued. The applicant

responded by providing, in Revision 3 of the' ESP application, a new section (i.e., Section 1.9)

of its SSAR. In this section, the applicant provided a summryi~ listing of site characteristics that

were established-by analyses presented throughout the SSAR. The applicant proposed thissection as a listing of important site characteristics necessary to establish the findings required

by 10 CFR Parts 52 and 100 on the suitability-of the proposed ESP site. The applicant stated

that this section also provides a listing of design parameters and assumptions-about the design

of a future nuclear power plant or plants that might'be constructed on'the ESP site. According

to the applicant, the design parameters described inthis' section are those' that are needed to

assess the site characteristics.

In RAI 1.3-2, the staff requested that the applicant (1) clarify its use of "bounding values" in

Table 1.3-1, (2) add the dose criteria in 10 CFR 50.34(a)(1) to the 'table as'"bounding value

references" or explain why these references are not nreeded, 'and (3) clarify the use of "Bound =

Notes" in the table, including how they were used for the accident analyses.' In its response,

the applicant provided clarification and corrections to Table 1;3-1. --

In RAI 1.3-3, the staff requested that the applicant clarify-the relationship between the items in

the "bounding values" provided in Table 1.3-1 and thei'eferences. The applicant responded -

that the PPE is a compilation of parameters that generally'describe a bounding (or limiting)

plant design. According to the applicant, the PPE is not intended to reflect the design of any

single reactor type, but to provide assumed parameters for any future'reactor(s) that might be

built at the ESP site. The applicant stated that it developed assumed parameter values in the

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PPE from a diverse group of reactor designs, and the "bounding value" is the limiting value from

those designs. Finally, the applicant clarified that the "Bound Notes" column in Table 1.3-1

provides information as to the source of the bounding value and other pertinent information for

the parameter.

The applicant has provided, through its PPE, sufficient design information to allow it to perform

the evaluation required by 10 CFR 52.17(a)(1) to determine the adequacy of the proposed

exclusion area and low-population zone (LPZ) for the site. Chapter 15 of the SSAR reports the

results of this evaluation. In this evaluation, the applicant used design information limited to the

rate of release of radioactivity to the environment as a result of a design-basis accident for

hypothetical reactors similar to two representative reactor types from different vendors.

In addition to the information supporting the dose consequence evaluation, the applicant

provided other design information in its PPE. Because the applicant is not requesting that an

ESP be issued referencing a particular reactor design, the staff's review criterion for the PPE is

that the PPE values should not be unreasonable for a reactor that might be constructed on the

ESP site. The applicant's PPE is based on various reactor designs that are either certified by

the NRC, are in the certification process, or may be submitted for certification in the future. The

PPE references the following designs:

* ACR-700 (Atomic Energy of Canada, Ltd.)

* Advanced Boiling-Water Reactor (General Electric)

* AP1 000 (Westinghouse Electric Company)

* Economic and Simplified Boiling-Water Reactor (General Electric)

* Gas Turbine Modular Helium Reactor (General Atomics)

* International Reactor Innovative and Secure Project (consortium led by Westinghouse)

* Pebble Bed Modular Reactor (PBMR (Pty) Ltd.)

The staff reviewed the applicant's PPE values and found them to be reasonable. As previously

noted, the applicant identified certain PPE values as appropriate for inclusion in an ESP, should

one be issued. The staff also reviewed the applicant's proposed list of PPE values and

identified certain PPE values as bounding parameters or controlling PPE values as discussed in

the individual sections of this SER. A controlling PPE value, or bounding parameter value, is

one that necessarily depends on a site characteristic. As the PPE is intended to bound multiple

reactor designs, the actual design selected in a COL or construction permit (CP) application

referencing any ESP that might be issued in connection with this application would be reviewed

to ensure that the design fits within the bounding parameter values. Appendix A to this SER

lists the bounding parameters identified for the North Anna ESP site.

Should an ESP be issued for the North Anna ESP site, an entity might wish to reference that

ESP, as well as a certified design, in a COL or CP application. Such a COL or CP applicant

must demonstrate that the site characteristics established in the ESP bound the postulated site

parameters established for the chosen design, and that the design characteristics of the chosen

design fall within the bounding parameter values specified in the ESP. Otherwise, the COL or

CP applicant must demonstrate that the new design, given the site characteristics in the ESP,

complies with the Commission's regulations. Should an entity wish to reference the ESP and a

design that is not certified, the COL or CP applicant must demonstrate that the design

characteristics of the chosen design, in conjunction with the site characteristics established for

the ESP, comply with the Commission's regulations.

1-6
1.4 Identification of Agents and Contractors

Dominion is the applicant for the North Anna ESP application and has been the only participant

in the review of the suitability of the North Anna ESP site for a nuclear'power plant. Bechtel

Power Corporation, under contract with Dominion, served as primary contractor for

development of the ESP application, supplying personnel, systems, and project management.

Several subcontractors also assisted in the development of Dominion's ESP application. Tetra

Tech NUS, Inc., performed data collection and analysis and prepared several sections of the

applicant's environmental report. MACTEC Engineering and Consuiting, Inc.,, performed '

geotechnical field investigations and laboratory testing. William Lettis & Associates, Inc.,

performed geologic mapping and characterization of seismic sources.- Finally, Risk,

Engineering, Inc., performed probabilistic seismic hazard assessments and related sensitivity

analyses.

1.5 Summary of Principal Review Matters

This SER summarizes the results of the NRC staff's technical evaluation'of the North Anna ESP

site. The staff's evaluation included a technical review of the information and data the applicant

submitted, with emphasis on the following principal matters: '

population density and land use characteristics of the site environs and the physical

characteristics of the site, including seismology, meteorology, geology, and hydrology, -

to evaluate whether these characteristics had been adequately described and were:

,given appropriate consideration to determine whether the site-characteristics are in

- "accordance with theCormmission's siting criteria (Subpart B; Evaluation Factors for;

Stationary Power Reactor Site Applications on or after January 10, 1997," of 10 CFR

Part 100)

* potential hazards to a nuclear power plant or plants that might be constructed on the

ESP site posed by manmade facilities and activities (e.g.; mishaps involving storage of

hazardous materials (toxic chemicals, explosives), transportation accidents (aircraft,

marine traffic, railways, pipelines), and the existing nuclear power plants at the nearby

NAPS)

* -potential capability of the site to support the construction and operation of a nuclear

power plant or plants with design parameters falling within those specified in the.

applicant's PPE under the requirements of 10 CFR Parts 52 and 100

* suitability of the site for development of adequate physical security plans and measures

for a nuclear power plant or plants ; . ;

* 'proposed major features for an emergency plan to be developed, should an applicant

decide to seek a license to'construct and operate a nuclear power plant or plants on the

ESP site; any significant impediments to the development of emergency plans for the

North Anna ESP site; and a description of contacts and arrangements made with local,

State, anrd Federal Government agencies with emergency planning responsibilities

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* quality assurance measures applied to the information submitted in support of the

applicant's ESP application and safety assessment

* the acceptability of the applicant's proposed exclusion area and LPZ under the dose

consequence evaluation factors of 10 CFR 50.34(a)(1)

During its review, the staff held several meetings with representatives of the applicant and the

applicant's contractors and consultants to discuss various technical matters related to its review

of the North Anna ESP site (refer to Appendix B to this report). The staff also visited the site to

assist in its evaluation of safety matters.

1.6 Summary of Open and Confirmatory Items

As a result of its review of Dominion's application for the North Anna ESP, the staff identified

several issues that remained open at the time the DSER was issued on December 20, 2004.

The staff considers an issue to be open if the applicant has not provided requested information

and the staff is unaware of what will ultimately be included in the applicant's response. The

staff assigned each of these issues a unique identifying number for tracking purposes that

indicates the section of this report describing it. The resolution of each open item is discussed

in the SER section in which it appears. For example, Section 2.1 of this report discusses Open

Item 2.1-1.

In addition, the staff identified one confirmatory item in the DSER. An item is identified as

confirmatory if the staff and the applicant have agreed on a resolution of the particular item, but

the resolution has not yet been formally documented. The confirmatory item identified by the

staff, which is discussed in detail in Section 17.3 of this SER, required verification of information

obtained from the Internet. The staff determined that the applicant provided adequate quality

assurance measures to authenticate and verify data retrieved from Internet Web sites and

considers this confirmatory item complete.

The DSER was issued with 28 open items and 1 confirmatory item. As set forth in this report,

all open items have been resolved and the confirmatory item has been completed. This SER

documents the resolution of all the open and confirmatory items identified in the DSER.

1.7 Summary of Combined License Action Items

The staff has also identified certain site-related items that will need to be addressed at the COL

or CP stage, should a COL or CP applicant desire to construct one or more new nuclear

reactors on the North Anna ESP site. This report refers to these items as COL action items.

These COL action items relate to issues that are outside the scope of this SER. The COL

action items do not establish requirements; rather, they identify an acceptable set of information

to be included in the site-specific portion of the safety analysis report submitted by a COL or CP

applicant referencing the North Anna ESP. An applicant for a COL or CP should address each

of these items in its application. It may deviate from or omit these items, provided that the COL

or CP application identifies and justifies the deviation or omission. The staff determined that

the COL action items do not affect its regulatory findings at the ESP stage and are, for reasons

specified in this report for each item, more appropriately addressed at later stages in the

licensing process.

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At the time the DSER was issued, there were a total of 19 COL action items. The staff

reviewed the responses to open items provided by the applicant and identified a number of new

COL action items as a result. This report highlights these COL action items, and the staff

explains them in the applicable sections of this SER. Appendix A to this SER includes a list of

COL action items that must be addressed by a future COL or,CP applicant. The staff identified

COL action items with respect to individual site characteristics in order to ensure that particular

significant issues are tracked and considered during the COL or CP stage. The COL action

items focus on matters that may be significant in any COL or CP application referencing the

ESP for the North Anna site, should one be issued. Usually, COL action items are not

necessary for issues covered by permit conditions or explicitly covered by the bounding

parameters. The list of COL action items is not and should not be understood to be exhaustive.

1.8 Summary of Permit Conditions

The staff has identified certain permit conditions that it will recommend the Commission

impose, should an ESP be issued to the applicant. Appendix A to this SER summarizes these

conditions. These permit conditions, or limitations on the ESP, stem from the provisions of

10 CFR 52.24, Issuance of Early Site Permit."

At the time the DSER was issued, the staff had proposed a total of 18 permit conditions. This

report discusses these DSER permit conditions, which are identified with a unique assigned

number to indicate the corresponding section of the SER in which the condition is described.

The applicant provided responses to the DSER open items which resulted in the resolution of

some proposed DSER permit conditions. In addition, the staff determined that a permit

condition is not necessary when an existing NRC regulation requires a future regulatory review

and approval process to ensure adequate safety during design, construction, or inspection

activities for a new plant. Based on this criterion, the staff removed a number of permit

conditions proposed in the.DSER and, in some cases, added new permit conditions, COL

action items, or site characteristics, as appropriate, to account for the concern.

Appendix A to this SER contains the final list of permit conditions which have been highlighted

throughout this report. Each permit condition has been reassigned a number identifying the

sequence in which it appears in this SER. The staff has provided an explanation of each permit

condition in the applicable section of this report.

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2. SITE CHARACTERISTICS

2.1 Introduction

2.1.1 Site Location and Description

2.1.1.1 Technical Information in the Application

In Section 2.1.1.1 of the site safety analysis report (SSAR), the applicant presented information

concerning the site location and site area that would affect the design of structures, systems,

and components (SSCs) important to safety of a nuclear power plant or plants falling within the

applicant's plant parameter envelope (PPE) that might be constructed on the proposed early

site permit (ESP) site. The applicant did not provide latitude and longitude or Universal

Transverse Mercator coordinates for new units in the proposed ESP site. However, the North

Anna Units 1 and 2 Updated Final Safety Analysis Report (UFSAR) for the existing North Anna

Power Station (NAPS) does include them. The proposed ESP site is located within the existing

NAPS site.

The applicant provided the following information on site location and site area:

* the site boundary for new units in the proposed ESP site with respect to the existing

units

* the site layout for new units in the proposed ESP site with respect to the current and

future developments

* the site location with respect to political subdivisions and prominent natural and

manmade features of the area within the 6-mile (mi) low-population zone (LPZ) and

50-mile population zone

* the topography surrounding the proposed ESP site

* the distance from the proposed ESP site to the nearest exclusion area boundary (EAB),

including the direction and distance

* the potential radioactive material release points and their locations for the proposed new

units

* the distance of the proposed site from regional U.S. and State highways

* -the confirmation that no physical characteristics unique to the proposed ESP site were

identified that could pose a significant impediment to the development of emergency

plans

2.1.1.2 Regulatory Evaluation

Sections 1.8 and 2.1.1 of the SSAR identify the applicable U.S. Nuclear Regulatory

Commission (NRC) regulations and guidance regarding site location and description as defined

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in Title 10, Section 52.17, "Contents of Applications," of the Code of Federal Regulations

(10 CFR 52.17); 10 CFR Part 100, "Reactor Site Criteria"; 10 CFR 50.34(a)(1); and NRC

Review Standard (RS)-002, "Processing Applications for Early Site Permits," issued May 2004.

The staff reviewed this portion of the application for conformance with the applicable

regulations, and considered the corresponding regulatory guidance, as identified above.

The staff considered the following regulatory requirements in reviewing the site location and site

area:

* 10 CFR Part 100, insofar as it requires consideration of factors relating to the size and

location of sites

* 10 CFR 52.17, insofar as it requires the applicant's submission of information needed to

evaluate factors involving the characteristics of the site environs

According to Section 2.1.1 of RS-002, an applicant has submitted adequate information if it

satisfies the following criteria:

* The site location, including the exclusion area and the proposed location of a nuclear

power plant or plants of specified type falling within a PPE that might be constructed on

the proposed site, is described in sufficient detail to determine that the requirements of

10 CFR Part 100 and 10 CFR 52.17 are met, as discussed in Sections 2.1.2 and 2.1.3

and Chapter 15 of this safety evaluation report (SER).

* Highways, railroads, and waterways which traverse the exclusion area are sufficiently

distant from planned or likely locations of structures of a nuclear power plant or plants of

specified type falling within a PPE that might be constructed on the proposed site so that

routine use of these routes is not likely to interfere with normal plant operation.

2.1.1.3 Technical Evaluation

The proposed ESP site is located within the existing NAPS site. The ESP site boundary, as

shown in Figure 2.1-1, "Site Boundary," of the SSAR, is the same as the site boundary for the

existing NAPS units.

The staff has verified the following coordinates of the existing NAPS units provided in the North

Anna UFSAR:

Latitude Longitude Universal Transverse Mercator

Unit 1 3803'36"N 77047'23"W 4,215,990 mN-255,240 mN-zone 18S

Unit 2 3803'38"N 77047'26"W 4,215,960 mN-255,170 mN-zone 18S

The staff will review the exact coordinates of the new units at the time of a combined license

(COL) or construction permit (CP) application when the applicant selects new units in the

proposed ESP site. This is COL Action Item 2.1-1.

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The applicant has defined the EAB envelope at a radius of 5000 feet (ft) from the now

abandoned Unit 3 containment and the LPZ at a radius of 6 miles from the existing Unit 1

containment building. The applicant established the EAB and the LPZ to ensure that the

radiological consequence evaluation factors identified in 10 CFR 50.34(a)(1) and the siting

evaluation factors in Subpart B, "Evaluation Factors for Stationary~Power Reactor Site

Applications on or After January 10, 1997," of 10 CFR Part 100 are met. No persons live within

the EAB.

NAPS is located in the northeastern portion of Virginia in Louisa County. Louisa County

includes two incorporated towns, Louisa and Mineral. The proposed ESP site is on a peninsula

on the southern shore of Lake Anna at the end of State Route 700. Lake Anna was created to

serve the needs of NAPS. It is about 17 miles long and has 272 miles of irregular shoreline

with various contour and scenic views. The proposed ESP site lies along the lake shoreline.

The NAPS property comprises 1803 acres (ac), of which about 760 ac are covered by water.

Virginia Electric and Power Company (Virginia Power) and Old Dominion Electric Cooperative

(ODEC) own the NAPS site, which includes -the existing two nuclear power units and the

proposed ESP site, as tenants in common (see Section 2.1.2 of this SER).

The largest community within 10 miles of the proposed ESP site is the town of Mineral with a

population of 424, according to the 2000 census. It is situated about 6 miles west-southwest of

the proposed ESP site. Regionally, as shown in Figure 2.1-3,0"Fifty-Mile Surrounding Area," of

the SSAR, the proposed site is approximately 40 miles north-northwest of Richmond, Virginia;

36 miles east of Charlottesville, Virginia; 22 miles southwest of Fredericksburg, Virginia; and

70 miles southwest of Washington, D.C. Highways U.S. 1 and 1-95 pass within 15 and

16 miles, respectively, east of the proposed site. No highways, railroads, or waterways traverse

the proposed ESP exclusion area site boundary.

The staff has verified that the exclusion- area distance is consistent with the distance the

applicant used in its radiological consequence analyses described in Chapter 15, "Accident

Analyses," of the SSAR. The applicant stated that, consistent with the licenses for the existing

units, the gaseous effluent release limits for the proposed units would apply at or beyond the

proposed ESP EAB; the liquid effluent release limits for the new units would apply at the end of

the discharge canal, which is designated as the release point to unrestricted areas. The staff

finds that these release points are acceptable for determining the radiation exposures to the

public to meet the criterion 'as low as reasonably achievable," cited in Appendix I, "Numerical

Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion 'As

Low as is Reasonably Achievabl;6' for Radioactive Material in Light-Water-Cooled Nuclear

Power Reactor Effluents," to1 0 CFR Part 50, "Domestic Licensing of Production and Utilization

Facilities." - -

For the reasons set forth in Section 13.3 of this SER, the staff further finds that no physical

characteristics unique to the proposed ESP site have been identified that could pose a

significant impediment to the development of emergency plans. -

2.1.1.4 Conclusions'

As set forth above, the applicant has provided and substantiated information concerning the site

location and site area that would affect the design of SSCs important to safety of a nuclear

power plant or plants of specified type falling within the applicant's PPE that might be

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constructed on the proposed ESP site. The staff has reviewed the applicant's information as

described above and concludes that it is sufficient for the staff to evaluate compliance with the

siting evaluation factors in 10 CFR Part 100 and 10 CFR 52.17, as well as the radiological

consequence evaluation factors in 10 CFR 50.34(a)(1). The staff further concludes that the

applicant provided information concerning the site location and site area in sufficient detail to

allow the staff to evaluate, as documented in Sections 2.1.2 and 2.1.3 and Chapter 15 of this

SER, whether the applicant has met the relevant requirements of 10 CFR Part 100 and 10 CFR

52.17.

2.1.2 Exclusion Area Authority and Control

2.1.2.1 Technical Information in the Application

In SSAR Section 2.1.2, the applicant presented information concerning its plan to obtain legal

authority to determine all activities within the designated exclusion area, if it decides to proceed

with the development of new reactor units at the proposed ESP site. In Revision 3 of the

SSAR, the applicant stated the following:

If Dominion decides to proceed with the development of new units, it would enter

into and obtain appropriate regulatory approvals to purchase or lease the ESP

site from Virginia Power and ODEC. The agreement or conveyance documents

would provide for the mutual use of the NAPS site as a single exclusion area. As

part of this agreement, each party would agree to immediately notify the other in

the event of an emergency and to abide by the reasonable requests of the party

declaring an emergency to exclude non-plant personnel and property from the

exclusion area. The parties would also agree to work cooperatively to control

third party activity that might otherwise present an unacceptable hazard to

nuclear operations. Because the appropriate regulatory approvals of the

conveyance and agreement (pursuant to Virginia Code, 56-77 and 56-580)

would be a prerequisite to Dominion's development of the new units, such

arrangements would be in place before issuance of a COL for the new units.

In Request for Additional Information (RAI) 2.1.2-1, the staff asked the applicant for additional

information regarding its approach to obtaining appropriate regulatory approvals to purchase or

lease the ESP site. In its response, the applicant stated the following:

Virginia State Corporation and possibly North Carolina Utilities Commission

approval (other than NRC] would be required [to purchase or lease the proposed

ESP site]. The current NAPS exclusion area boundary (EAB) would continue to

be the EAB for the existing units and any new units. This single exclusion area

includes property that is not part of the ESP site. The use of the current

exclusion area for the new units would be established by agreement between

Dominion Nuclear North Anna and other NAPS owners. Dominion has not

determined a specified term for any lease. However, any lease would provide

that (1) the term of the lease would not expire until after termination of all NRC

licenses for any facilities on the leased property, and (2) the lease may not be

canceled or terminated, prior to the termination of all NRC licensees for any

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facilities on the leased property, except with prior written consent of the NRC

(e.g., consent in connection with the transfer of licenses under 10 CFR 50.80).

In RAI 2.1.2-2, the staff asked for the application for additional information on how an

agreement or conveyance document (e.g., a lease or deed) would provide for the use of NAPS

as a'single exclusion area, in the event that additional reactors are constructed on the site. In

its response, in a lbtter'to the NRC dated August 10, 2004,'the applicant stated the following:

Any lease or deed would provide mutual use of the existing site and the leased

-premises as a single exclusion area and single restricted area for all nuclear

units at the North Anna site. Each party would agree to immediately notify the

other in the event of an emergency and to abide by the reasonable request of

the party declaring the emergency condition to exclude non-plant personnel and

property from the exclusion area. The parties would agree to work cooperatively

to control third party activity within the exclusion area-and prevent any such

activity that might otherwise present an unacceptable hazard to nuclear

operations. ' This approach is consistent with the single exclusion area

established by agreement for the Indian Point units (when Units 1 and 2 were

owned by the Consolidated Edison Company and Unit 3 was owned by the

Power Authority of the State of New York) and for the Nine Mile Point and

Fitzpatrick plants.

2.1.2.2 Regulatory Evaluation

In SSAR Sections 1.8 and 2.1.2, the applicant identified the applicable NRC regulations and

regulatory guidance regarding exclusion area authority and control related to Subpart A, "Early

Site Permits," of 10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and

Combined Licenses for Nuclear Power Plants," 10 CFR Part 100, and RS-002. The staff finds

that the applicant correcty 'identified the applicable regulations and guidance. The staff

considered 10 CFR 100.21(a) and 10 CFR 100.3, "Definitions," in reviewing the applicant's legal

authority to determine all activities within the designated exclusion area. Pursuant to 10 CFR

100.21 (a), e'very site must have an exclusion area, defined in 10 CFR 100.3 as the following:

That area surrounding the reactor, in which the reactor licensee has the authority

to determine all activities including exclusion or removal of personnel and

property from the area. This area may be traversed by a highway, railroad or

waterway, provided these are not so close to the facility as to interfere with

normal operations of the facility and provided appropriate and effective

arrangements are rnade to control traffic on the highway, railroad, or waterway,

in case of emergency, to protect the public health and safety... Activities

unrelated to operation'of the reactor may be permitted in an exclusion area

under appropriate limitations,'provided that no significant hazards to the public

health and safety will result. - -

As stated in Section 2.1.2 of RS-002,- the applicant must demonstrate, before issuance of an

ESP, that it has an exclusion area and an LPZ, as defined in 10 CFR 100.3 and in accordance

with the requirements of 10 CFR Part 100. Furthermore, the applicant must show that it has

the authority within the exclusion area, as required by 10 CFR 100.3, or it must provide

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reasonable assurance that it will have such authority before start of construction of a reactor or

reactors that might be located on the proposed ESP site.

2.1.2.3 Technical Evaluation

As set forth in the application and in Section 2.1.2.1 of this SER, the exclusion area for the

North Anna ESP site is identical to the exclusion area for the existing reactors at the site, North

Anna Units 1 and 2. Further, the current owners of the ESP site, Virginia Power and ODEC,

have the requisite control over the exclusion area, and such control is vested in Virginia Power.

The applicant has stated that it intends to reach appropriate legal terms with the current owners

of the ESP site to obtain the requisite control over the exclusion area. The applicant would

enter into such an agreement with the current site owners at such time as the applicant elects

to construct a nuclear power plant on the site.

The applicant has not attempted to demonstrate that it currently has the authority to determine

all activities, including exclusion or removal of personnel and property from the area, as

required by 10 CFR 100.3. To meet the exclusion area control requirements of 10 CFR

100.21 (a) and 10 CFR 100.3, the applicant does not need to demonstrate total control of the

property before issuance of the ESP. In the draft safety evaluation report (DSER), the NRC

staff stated that the applicant must provide reasonable assurance that it can acquire the

required control (i.e., that it has the legal right to obtain control of the exclusion area). The staff

had not then obtained information sufficient to enable it to determine whether the applicant had

such a legal right. Accordingly, the NRC staff identified DSER Open Item 2.1-1, which stated

that the applicant should demonstrate that it has the legal right to control the exclusion area, or

has an irrevocable right to obtain such control.

In its response to the open item, the applicant indicated as follows: In accordance with Virginia

Code, §56-580 D, the ESP holder would be required to obtain the approval of the Virginia State

Corporation Commission (SCC) to construct and operate any new unit at the North Anna ESP

site, should it decide to do so. In such an event, SCC approval of any agreement between the

CP or COL applicant and the current owners of the site providing for construction and operation

of a new unit would be required pursuant to Virginia Code, §56-77. The same statute would

require SCC approval of any agreement among these entities providing for joint control of the

exclusion area. Other State approvals might also be required.

Based on the above information, the staff has determined that State approval would be required

for the agreements described above, and no new nuclear power plant could be built in the

absence of these approvals. Since the ESP holder would need to obtain the current owners'

agreement to construct and operate any new nuclear power plant on the North Anna ESP site

in order to seek State approval of such construction and .operation, there does not appear to be

any reason why the ESP holder could not obtain control of the exclusion area in a similar

manner. Accordingly, for purposes of an ESP, there is reasonable assurance that the current

owners would (as a corollary to any agreement for construction and operation) also agree to

joint control of the exclusion area with the ESP holder, as proposed by the applicant, and seek

the required State approvals of such an agreement or agreements. In addition, there does not

appear to be any impediment to joint control of the exclusion area in the event State approval of

such an arrangement is granted.

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The State approvals described above would not be granted until sought upon a decision to seek

a CP or COL, and do not cdrrehtly vest a legal right in the applicant to obtain control of the

exclusion area. Accordingly, the NRC staff proposes to include a condition in any ESP that

might be issued to govern exclusion area control as Permit Condition 1. This permit condition

would require that approvals called for by State law for, among other matters, agreements

providing for shared control of the North Anna ESP exclusion area, be obtained and the

agreements executed before construction of a nuclear power plant begins under a construction

permit or COL referencing the ESP. Such a permit condition provides reasonable assurance

that an ESP provides for control of the exclusion area. The condition requires that these

arrangements be obtained and executed before the granting of an application referencing the

ESP. Therefore, DSER Open Item 2.1-1 is closed.

Should the NRC grant the ESP and the'ESP holder decide to perform the activities authorized

by 10 CFR 52.25, "Extent of Activities Permitted," the ESP holder must obtain the authority to

undertake those activities on the ESP site. In obtaining such a right, the ESP holder must also

obtain the corresponding right to implement the site redress plan described in the staff's final

environmental impact statement in the event that no plant is built on the ESP site. The staff

proposes to include a condition in any ESP that might be issued requiring that the ESP holder

obtain the right to implement the'site'redress plan before initially any activities authorized by

10 CFR 52.25, as Permit Condition 2.

The North Anna exclusion area extends into Lake Anna and the waste heat treatment facility

(WHTF). 'Should the NRC grant the ESP and the ESP holder decide to apply for a COL (or for

a CP and operating license (OL)), the ESP holder, COL or CP applicant must make

arrangements with the appropriate Federal, State, or local agencies to provide for control of the

portions of Lake Anna and the WHTF that are within the exclusion area. These agencies,

together with COL or CP applicant, must have authority over these bodies of water sufficient to

allow for the exclusion and ready removal, in an'emergency, of any persons present on them.

This is COL Action Item 2.1-2; No State or county roads, railways, or waterways traverse the

North Anna ESP exclusion area.

2.1.2.4 Conclusions

As set forth above, the applicant has provided and substantiated information concerning its plan

to obtain legal authority to determine all activities within the designated exclusion area. Thestaff has reviewed the applicant's information and concludes that it is sufficient to evaluate

compliance with tue-exclusion area control requirements'of 10 CFR 100.21(a) and 10 CFR

100.3.

The applicant has appropriately described the exclusion area and the methods by which access

and occupancy of the-exclusion area will be controlled during normal operation and in the event

of an emergency situation.

Based on the foregoing, the staff concludes that the applicant's exclusion area is acceptable

and meets the requirements of 10 CFR Part 100, subject to the limitations and conditions

identified in this SER. -Such permit conditions provide'reasonable assurance that an ESP

provides for control of the exclusion area. Further, the ESP holder must demonstrate that it will

have authority to perform the activities authorized by 10 CFR 52.25, should it choose to do so,

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and the corresponding right to implement the site redress plan, as described in the discussion

of Permit Conditions 1 and 2.

2.1.3 Population Distribution

2.1.3.1 Technical Information in the Application

In SSAR Section 2.1.3, the applicant estimated and provided the population distribution

surrounding the proposed ESP site, up to a 50-mile radius, based on the most recent U.S.

census. In this section, the applicant also provided the population densities, the resident

population distribution within the LPZ, the nearest population center, and population densities

up to a 50-mile radius from the proposed ESP site.

The population distribution provided by the applicant encompasses nine concentric rings at

various distances out to 50 miles from the proposed ESP site and 16 directional sectors. The

applicant also estimated and provided transient population data out to 50 miles based on

recreational use of Lake Anna, Lake Anna State Park, two commercial campgrounds, the

WHTF, and Paramount's King's Dominion Amusement Park.

In RAI 2.1.3-1, the staff asked the applicant to project population estimates, including weighted

transient populations, up to 2065 (the projected year for the end of plant life). In its response,

the applicant reestimated and provided resident and weighted transient populations up to 2065,

thereby revising its original estimate of resident and weighted transient populations up to 2040.

The applicant incorporated this response into the SSAR.

In the revised Figure 2.1-14 of the SSAR, the applicant provided the cumulative population in

2000 and the projected cumulative population in 2065, as functions of the 10-mile to 50-mile

radial distance from the proposed ESP site, as well as the population density curves spanning

the same radial distances. The population density curves also included 500-persons-persquare-mile lines and 1000-persons-per-square-mile lines as a function of distance up to

50 miles from the site.

The applicant established the LPZ to ensure that the radiological consequences of design-basis

reactor accidents at the LPZ meet the dose consequence evaluation factors set forth in 10 CFR

50.34(a)(1). The applicant described the LPZ in Section 2.1.3.4 of the SSAR. The LPZ is

defined in 10 CFR 100.3 as "the area immediately surrounding the exclusion area which

contains residents, the total number and density of which are such that there is a reasonable

probability that appropriate measures could be taken in their behalf in the event of a serious

accident." The LPZ for the ESP site is the same as the LPZ for the existing North Anna units; it

consists of a circle with a radius of 6 miles centered on the North Anna Unit 1 containment

building. The applicant provided a map (Figure 2.1-2) of the LPZ and figures showing the

current and projected population data for the LPZ, including transient persons.

The applicant described the population center in Section 2.1.3.5 of the SSAR. The population

center is defined in 10 CFR 100.3 as "a densely populated center containing more than about

25,000 residents." The applicant stated that the nearest population center with a population

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greater than 25,000 people which is likely to exist over the lifetime of the proposed ESP site, is

the city of Charlottesville, with a population of 45,049. The closest point of Charlottesville is

36 miles west of the ESP site., The next closest population center is Fredericksburg, which is

22 miles northeast of the proposed ESP site. Fredericksburg has a projected population of

about 20,330 in 2065.

In RAI 2.1.3-2, the staff asked the applicant to describe appropriate protective measures that

could be taken on behalf of the populace in the LPZ in the event of a radiological emergency.

In its response, the applicant stated that, in the event of a radiological emergency, the plant

staff would notify the Commonwealth of Virginia and local authorities. The plant staff would

formulate protective action recommendations, as appropriate, and provide them to the Virginia

Emergency Operations Center. The Commonwealth of Virginia would make a protective action

decision and notify the affected populace.

2.1.3.2 Regulatory Evaluation

In SSAR Sections 1.8 and 2.1.3, the applicant identified the applicable NRC regulations and

regulatory guidance regarding population distribution, as described in 10 CFR 52.17; 10 CFR

Part 100; Regulatory Guide (RG) 4.7, Revision 2, "General Site Suitability Criteria for Nuclear

Power Stations," issued April 1998; and RS-002. The staff finds that the applicant correctly

identified the applicable regulations and guidance.

The staff considered the following regulatory requirements in its review of this section of the

SSAR:

* 10 CFR 52.17, insofar as it requires each applicant to provide a description and safety

assessment of the site, and insofar as it requires that site characteristics comply with

10 CFR Part 100

* 10 CFR Part 100, insofar as it establishes requirements with respect to population

density

In particular, the staff considered the population density and use characteristics of the site

environs, including the exclusion area, LPZ, and population center distance. The regulations in

10 CFR Part 100 provide definitions and other requirements for determining an exclusion area,

LPZ, and population center distance.

As stated in Section 2.1.3 of RS-002, the applicable requirements of 10 CFR 52.17 and 10 CFR

Part 100 are deemed to have been met if the population density and use characteristics of the

site meet the following criteria:

* Either there are no residents in the exclusion area, or if residents do exist, they are

subject to ready removal, in case of necessity.

* The specified LPZ is acceptable if it is determined that appropriate protective measures

could be taken on behalf of the enclosed populace in the event of a serious accident.

* The population center distance is at least one and one-third times the distance from the

reactor to the outer boundary of the LPZ. The population center distance is defined in

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10 CFR 100.3 as the distance from the reactor to the nearest boundary of a densely

populated center containing more than about 25,000 residents.

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* The population center distance is acceptable if there are no likely concentrations of

greater than 25,000 people over the lifetime (plus the term of the ESP) of a nuclear.

power plant or plants of specified type or falling within a PPE that might be constructed

on the proposed site closer than the distance designated by the applicant as the

population center distance. The boundary of the population center shall be determined

upon considerations of population distribution. Political boundaries are not controlling.

* The population data supplied by the applicant in the safety assessment are acceptable if

(1) they contain population data for the latest census, projected year(s) of startup of a

nuclear power plant or plants of specified type (or falling within a PPE) that might be

constructed on the proposed site (such date(s) reflecting the term of the ESP) and a

projected year(s) of end of plant life, all in the geographical format given in Section 2.1.3

of RG 1.70, "Standard Format and Content of Safety Analysis Reports for NuclearPower Plants-LWR Edition," Revision 3, issued November 1978, (2) they describe the

methodology and sources used to obtain the population data, including the projections,

(3) they'include information on transient populations in the site vicinity, and (4) the

population data in the site vicinity, including projections, are verified to be reasonable by

other means, such as U.S. Census Bureau publications, publications from State and

local governments, and other independent projections.

* If the population density at the ESP stage exceeds the guidelines given in RG 4.7,

Revision 2, special attention to the consideration of alternative sites with lower -

population densities is necessary. A site that exceeds the population density guidelines

of Regulatory Position C.4 of RG 4.7,-Revision 2, can nevertheless be selected and

approved if, on balance, it offers advantages compared with available alternative sites

when all of the environmental, safety, and economic aspects of the proposed and

alternative sites are considered.

2.1.3.3 Technical Evaluation

The staff reviewed the data on the population in the site environs, as presented in the

applicant's SSAR, to 'determine whether the exclusion area, LPZ, and population center

distance for the proposed ESP site comply -with the requirements of 10 CFR Part 100 and the

acceptance 'criteria in Section 2.1.3.2 of this SER. The staff also evaluated whether, consistent

with Regulatory Position C.4 of RG 4.7, Revision 2, the applicant should consider alternate sites

with lower population densities. "The staff also reviewed whether appropriate protective

measures could be taken on behalf of the enclosed populace within'the emergency planning

zone (EPZ), which encompasses the LPZ,' in the event of a serious accident.-

The staff compared and verified the'applicant's population data against U.S. Census Bureau

Internet data. As documented in Section 13.3 of this SER, the staff reviewed the projected

population data provided by the applicant.! The information reviewed by the staff included the

weighted transient populations for 2010,2020, 2030, 2040, 2050, 2060, and 2065.' If the NRC

were to approve and issue the ESP in 2006 and a COL application submitted near the end of

the ESP term, with a projected startup of new units in about 2025 and an operational period of

40 years for the new units, the projected year for end of plant life is about 2065. Accordingly,

thesta'fffinds that the applicant's projected population data cover an appropriate number of

years and are reasonable.

2-11
- MIII

The staff reviewed the transient population data provided by the applicant. The transient

population up to a 50-mile radius is based on recreational use of Lake Anna, Lake Anna State

Park, two commercial campgrounds, the WHTF, and Paramount's King's Dominion Amusement

Park. The applicant stated that recreational use of Lake Anna, including Lake Anna State Park,

is the greatest contributor to transient population in the area. The applicant collected

information concerning transient population of the area from a number of contributing factors,

including the number of boat ramps, wet slips, campsites, and picnic areas. Based on this

information, the staff finds that the applicant's estimate of the transient population is

reasonable.

The staff notes that no member of the public lives within the exclusion area.

The applicant evaluated representative design-basis accidents in Chapter 15 of the SSAR, and

the staff independently verified the applicant's evaluation in Chapter 15 of this SER to

demonstrate that the radiological consequences of design-basis reactor accidents at the

proposed LPZ would be within the dose consequence evaluation factors set forth in 10 CFR

50.34(a)(1).

The distances to Charlottesville and Fredericksburg, the nearest population centers, are well in

excess of the minimum population center distance of 7.8 miles (one and one-third times the

distance of 6 miles from the reactor to the outer boundary of the LPZ). In addition, no

population centers are closer than the population center distance specified by the applicant.

Therefore, the staff concludes that the proposed ESP site meets the population center distance

requirement, as defined in 10 CFR Part 100. The staff has determined that no realistic

likelihood exists that there will be a population center with 25,000 people within the 7.8-mile

minimum population center distance during the lifetime of any new units that might be

constructed on the site. This conclusion is based on projected cumulative resident and

transient population within 10 miles of the site during the lifetime of any new units to 2065.

The staff evaluated the site against the criterion in Regulatory Position C.4 of RG 4.7,

Revision 2, regarding whether it is necessary to give special attention to the consideration of

alternative sites with lower population densities. The criterion is whether the population

densities in the vicinity of the proposed site, including weighted transient population, projected

at the time of initial site approval and within about 5 years thereafter, would exceed

500 persons per square mile averaged over any radial distance out to 20 miles (cumulative

population at a distance divided by the area at that distance). The staff has determined that

such population densities for the proposed site would be well below this criterion. Therefore,

the staff concludes that the site conforms to Regulatory Position C.4 in RG 4.7, Revision 2.

Assuming construction of a new nuclear reactor or reactors at the proposed site beginning near

the end of the term of the ESP, and based on its review of the applicant's population density

data and projections, the staff finds that the site also meets the guidance of RS-002 regarding

population densities over the lifetime of facilities that might be constructed at the site, in that the

population density over that period would be expected to remain below 500 persons per square

mile averaged out to 20 miles from the site.

The staff reviewed information provided by the applicant regarding its ability to take appropriate

protective measures on behalf of the populace in the LPZ in the event of a serious accident. In

its response to RAI 2.1.3-2, the applicant stated that, in the event of a radiological emergency,

2-12
the plant staff would notify the Commonwealth of Virginia'and local'authorities. The plant staff

would formulate protective action recommendations, as appropriate, and provide them to the

Virginia Emergency Operations Center. The Commonwealth of Virginia would make a

protective action decision and notify the affected populace.

The staff finds that the applicant's response is satisfactory because it is consistent with

emergency planning for the 1 0-mile plume exposure EPZ. The LPZ is located entirely within

the 10-mile EPZ. Comprehensive emergency planning for the protection of all persons within

the 10-mile EPZ, as addressed in Section 13.3 of this SER, would include those persons within

the LPZ. Based on the information the applicant presented on this subject, and on the staff's

conclusions discussed in Section 13.3 of this SER, the staff concludes that appropriate,

protective measures could be taken on behalf of the enclosed populace within the LPZ in the

event of a serious accident.

2.1.3.4 Conclusions

As set forth above, the applicant has provided an acceptable description of current and

projected population densities in and around the site. These densities projected at the time of

initial plant operation (if one were to be constructed on the site) and within about 5 years

thereafter are within the guidelines of Regulatory Position C.4 of RG 4.7, Revision 2. The.

applicant has properly specified the LPZ and population center distance. The staff finds that

the proposed LPZ and population center distance meet the definitions'in 10 CFR 100.3.

Therefore, the staff concludes that the applicant's population data'and population distribution

are acceptable and meet the requirements of 10 CFR 52.17 and 10 CFR Part 100. In

Chapter'15 of this'SER, the staff documents that the radiological consequences of bounding

design-basis accidents at the outer boundary of the LPZ meet the requirements of 10 CFR

52.17.

2.2 Nearby Industrial, Transportation, and Military Facilities

2.2.1-2.2.2 Identification of Potential Hazards in Site Vicinity --

For an ESP application, the applicant provides information on relative location and separation

distance with respect to industrial, military, and transportation facilities and routes on the'site

and in its vicinity. Such facilities and routes may include air, ground, and water traffic; pipelines;

and fixed manufacturing, processing, and storage facilities. Section 2.2 of the SSAR presents

information concerning the industrial, transportation, and military facilities in the vicinity of the

proposed ESP site. The staff's review focused on potential external hazards or hazardous

materials that are present or which'ma yreasonably be expected to'be present during the'

projected lifetime of a nuclear~power plant or plants that might be constructed on the proposed

site. The staff has prepared Sections 2.2.1-2.2.2,'2.2.3, and 3.5.1.6 of this SER in accordance

with the review procedures described in RS-002, using information presented in SSAR

Section 2.2, responses to RAls, and the reference materials described in the applicable

sections of RS-002.

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_ 11111

2.2.1.1-2.2.2.1 Technical Information in the Application

In SSAR Section 2.2.2.1, the applicant stated that Louisa County, Virginia, the location of the

proposed site, is a rural and residential area. The applicant further stated that no substantial

industrial activities occur within 5 miles of the proposed ESP site. According to the applicant,

the county has granted its approval for a zoning ordinance allowing industrial development of

about 620 ac near the proposed ESP site's EAB. The applicant also noted that several other

areas located within 10 miles of the proposed site are zoned for industrial development,

although no current plans for development exist.

Because the applicant identified a zoning ordinance, approved by the Louisa County Board of

Supervisors, for industrial development of about 620 ac near the proposed site EAB, the staff

requested clarification, in RAI 2.2.2-1, regarding the location of the 620-ac development. The

applicant provided additional information describing the specific location of the development

and the type of industrial activity that is covered by the zoning ordinance.

In Section 2.2.2.2 of the SSAR, the applicant stated that no mining activities occur within

5 miles of the proposed ESP site.

Section 2.2.2.3 of the SSAR describes the roads within 10 miles of the proposed ESP site.

These consist of several Virginia State routes (Routes 208, 601, and 652), which pass no closer

than 1.5 miles to the proposed site; U.S. Route 522, which passes within about 5 miles of the

proposed site; and Virginia State Route 700, which provides access to the proposed site.

SSAR Section 2.2.2.4 states that the Chesapeake and Ohio Railway passes within about

5.5 miles of the proposed site. In Section 2.2.2.5, the applicant stated that six marinas near the

proposed ESP site provide access to pleasure craft on Lake Anna. The marina locations are

between 1.4 and 2.3 miles from the proposed site. The applicant stated that no large boats or

barges exist on Lake Anna.

With respect to aircraft activities in the vicinity of the proposed ESP site, the applicant described

nearby airports and airways. Specifically, Table 2.2-1 of Section 2.2.2.6.1 of the SSAR lists the

three airports that are within 15 miles of the proposed ESP site. Figure 2.2-1 of

Section 2.2.2.6.1 of the SSAR illustrates the airport locations. Two of the three airports are

within 10 miles of the proposed ESP site. In SSAR Section 2.2.2.6.2, the applicant stated that

one civil airway (V223) and three military training routes (IR714, IR760, and VR1 754) pass

within less than 5 miles of the proposed ESP site.

In Section 2.2.2.7 of the SSAR, the applicant stated that no oil or gas pipelines are located

within 5 miles of the proposed ESP site. Similarly, in Section 2.2.2.8 of the SSAR, the applicant

stated that no military facilities exist within 5 miles of the proposed ESP site. Figure 2.2.1-1

illustrates the locations of nearby major roads, railroads, and gas pipelines relative to the ESP

site.

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N o a, 5

A 2 .

Md..

10 Is 20 25I".I

- Transmission Lines [-- Counbes

- -- MajorRoads M Urban Areas

R Railroads [.ET;' Lakes

Gas Pipelines

Figure 2.2.1-1 Major roads, railways, and gas pipelines in the vicinity of the ESP site

2.2.1.2-2.2.2.2 Regulatory Evaluation

In SSAR Section 1.8, the applicant identified 10 CFR 52.17(a)(1) and -10 CFR 100.20, "Factors

to be Considered When Evaluating Sites," as the regulations applicable to SSAR Sections 2.2.1

and 2.2.2. In the same section, the applicant identified the following applicable NRC guidance

regarding potential hazards in the vicinity of the proposed ESP site:

* RG 1.91, Revision 1, "Evaluation of Explosions'Postulated to Occur on Transportation

Routes Near Nuclear Power Plant Sites," issued February 1978-

* 'RG 1.78, Revision 1; "Evaluating the Habitability of a Nuclear Power Plant Control Room

During a Postulated Chemical Release," issued December 2001

* RG 1.70, Revision 3,"Standard Format and Content of Safety Analysis Reports for

Nuclear Power Plants, LWR Edition," issued November 1978 - -

2-15
IIJ!!

* NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for

Nuclear Power Plants"

* RS-002

The staff considered the following regulatory requirements in reviewing information regarding

potential site hazards which would affect the safe design and siting of a nuclear power plant or

plants falling within the applicant's PPE that might be constructed at the proposed site:

* 10 CFR 52.17(a)(1)(vii), with respect to information on the location and description of

any nearby industrial, military, or transportation facilities and routes

* 10 CFR 100.20(b), with respect to information on the nature and proximity of manrelated hazards

The following RGs identify methods acceptable to the NRC staff to meet the Commission's

regulations identified above:

* RG 1.91, Revision 1

* RG 1.78, Revision 1

Sections 2.2.1-2.2.2, 2.2.3, and 3.5.1.6 of RS-002 and RG 1.70, Revision 3, provide guidance

on information appropriate for identifying, describing, and evaluating potential manmade

hazards.

2.2.1.3-2.2.2.3 Technical Evaluation

The staff evaluated the potential for manmade hazards in the vicinity of the proposed ESP site

by reviewing (1) the information the applicant provided in Sections 2.2.1-2.2.2 of the SSAR,

(2) the applicant's responses to the staff's RAls, (3) information the staff obtained during a visit

to the proposed ESP site and its vicinity, and (4) other publicly available reference material,

such as U.S. Geological Survey topographic maps, satellite imagery, and geographic

information system coverage files (Platts, 2004, POWER map Geographic Information System

Spatial Data, including map layers of natural gas pipelines, railroads, and electric transmission

lines; and Terraserver-usa.com, 2004, online 1-meter Aerial Imagery of the Lake Anna, Virginia,

region). Using these data, the staff found no additional hazards beyond those the applicant

identified.

The staff evaluated the information on the nearby 620-ac development that the applicant

provided in its response to RAI 2.2.1-1. Included among the 30 industrial uses permitted for

this area are "acetylene gas manufacture on a commercial scale," "fireworks or explosives

manufacture, nitrating process, the loading of explosives, or their storage in bulk," "petroleum

refining," and "sulphurous, sulphuric, nitric or hydrochloric or other corrosive or offensive acid

manufacture, or their use or storage, except on a limited scale (by conditional use permit) as

accessory to a permitted industry." Pursuant to this ordinance, an entity seeking permission for

a specific industrial use must apply for and obtain a "conditional use permit" from the Louisa

County Planning Commission. The request for a permit may be denied by the planning

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commission, the governing body, if there is a finding that the use would be detrimental to the

health and safety of the public7 -

Currently, there have been no hazardous industrial facilities identified on this site. Hence, the

site does not pose any industrial hazard at the present time. In the event that some industrial

use were implemented on the site, any hazard determination would be based upon specific

information'regardingthe nature of the hazard, as well as specific nuclear plant design

parameters, neither of which are available at this time. On this basis, the staff finds that the

620 ac site currently does not present any identifiable hazards,-and an evaluation of industrial

hazards, if any, associated with the site can be performed, if warranted, should a CP or COL

application referencing any ESP issued for the North Anna site be submitted. This is

COL Action Item 2.2-1.

2.2.1.4-2.2.2.4 Conclusions

As set forth above, the applicant has provided information in the SSAR regarding potential site

hazards in accordance with the guidance of RG 1.70, such that compliance with the

requirements of 10 CFR 100.20 and 10 CFR 100.21, "Non-Seismic Site Criteria," can be

evaluated. The applicant has reviewed the nature and extent of activities involving potentially

hazardous materials conducted on or in the vicinity of the site to identify hazards that might

pose undue risk to a facility falling within the applicant's PPE that might be constructed on the

proposed site. Based on its evaluation of the information presented in the SSAR, as well as

information the- staff -obtained independently, the staff concludes that all potentially hazardous

activities on and in the vicinity of the site have been identified. Sections 2.2.3 and 3.5.1.6 of

this SER discuss the evaluation of such hazards.

2.2.3 Evaluation of Potential Accidents

2.2.3.1 Technical Information in the Application

In SSAR Section 2.2.3, the applicant evaluated earth-bound and aircraft hazards.

Section 3.5.1.6 of this SER discusses the staff's evaluation of aircraft hazards.

Consistent with its identification of potential hazards in SSAR Sections 2.2.1 and 2.2.2, the

applicant limited its evaluation of earth-bound hazards to the effects of explosion and formation

of flammable'vapor clouds from nearby sources. The applicant stated that the largest explosive

load routinely transported by truck on Virginia highways contains 8500 gallons (gal) of gasoline.

The explosive force of this quantity of gasoline is estimated to be equivalent to 50,700 pounds

(lb) of TNT, using a simple TNT-equivalent yield formula.- The applicant, citing the methodology

of RG 1.91, concluded that, if this amount of gasoline were to explode,' a peak overpressure of

1 pound per square inch (psi) would be experienced as far as 1900 ft away from the point of

explosion. The closest point of Virginia Route 652 to the ESP site is 1.5 miles (6420 ft). The

applicant noted that RG 1.91 cites 1 psi as a conservative value of peak positive incident

overpressure, below which no significant damage would be expected. Thus, the applicant

concluded that no significant damage would occur in the event of an explosion resulting from a

gasoline truck traffic accident.

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- IlL1

The applicant did not evaluate pipeline hazards because no natural gas pipeline or mining

facilities are located within 10 miles of the ESP site, and no pipelines carrying potentially

hazardous materials are located within 5 miles of the ESP site. Therefore, the applicant

concluded that the potential for hazards from these sources that could adversely affect safe

operation of the plant is minimal.

In RAI 2.2.3-1, the staff asked the applicant to describe whether the existing NAPS units pose

any undue risk to a nuclear power plant or plants falling within the applicant's PPE that might be

constructed and operated on the proposed ESP site. In its response, the applicant stated that

no such hazards exist.

2.2.3.2 Regulatory Evaluation

In SSAR Sections 1.8 and 2.2, the applicant identified the following applicable NRC guidance

regarding potential hazards in the vicinity of the proposed ESP site:

* RG 1.91, Revision 1

* RG 1.78, Revision 1

* RG 1.70, Revision 3

* NUREG-0800

* RS-002

In SSAR Section 1.8, the applicant identified the regulation applicable to SSAR Section 2.2.3 as

10 CFR 100.20. It also identified the requirements of RS-002 as applicable.

The staff considered the following regulatory requirements in reviewing information regarding

potential site hazards which would affect the safe design and siting of a nuclear power plant or

plants falling within the applicant's PPE that might be constructed at the proposed site:

* 10 CFR 52.17(a)(1)(vii), with respect to information on the location and description of

any nearby industrial, military, or transportation facilities and routes

* 10 CFR 100.20(b), with respect to information on the nature and proximity of manrelated hazards

* 10 CFR 100.21 (e), with respect to the evaluation of potential hazards associated with

nearby transportation routes and industrial and military facilities

The following RGs identify methods acceptable to the NRC staff to meet the Commission's

regulations identified above:

* RG 1.91, Revision 1

* RG 1.78, Revision 1

Sections 2.2.1-2.2.2, 2.2.3, and 3.5.1.6 of RS-002 and RG 1.70 provide guidance on

information appropriate for identifying, describing, and evaluating potential manmade hazards.

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2.2.3.3 Technical Evaluation

The staff reviewed the applicant's analysis of the effects of potential explosions and the

formation of flammable vapor clouds. The'6nly potential source of explosions or flammable

vapor clouds within 5 miles of the proposed site is truck traffic on the nearby highways.

According to the applicant, the largest explosive load routinely transported by truck on Virginia

highways contains 8500 gal of gasoline. The staff has previously reviewed and evaluated the

explosive yield from this quantity of gasoline, as documented in-the'UFSAR for the existing

NAPS. The resulting TNT equivalent was found to be 50,700 lb, which yields a peak

overpressure of 1 psi at 1,900 ft from the point of explosion. Since the closest highway -

(Virginia Route 652) is 6429 ft from the proposed ESP site, the potential peak overpressure at

the proposed site would be less than 1 psi. Hence, using the criteria of RG 1.91, no significant

damage to safety-related SSCs that may be located on the proposed site would be expected.

The staff evaluated the information in the SSAR regarding the location of the ESP site relative

to the location of the existing NAPS units and the applicant's response to RAI 2.2.3-1. In its

response to this RAI, the applicant stated that it did not identify any hazards with respect to

NAPS Units 1 and 2 that would pose an undue risk to a nuclear power plant or plants that might

be constructed on the ESP site.

The staff independently reviewed possible hazards posed by the existing NAPS units. This

review did not identify any hazards that would preclude the'provision of protective or mitigative

design features for a nuclear power plant or plants to be constructed on the ESP site. This

view is supported by the fact that the staff found, during the licensing review for NAPS Units 1

and 2, that design features of those units would adequately protect the NAPS units against

identified hazards (e.g., release of toxic or flammable materials, internal and external missiles).

Design-specific interactions between the existing and new units would need to be'evaluated

and, if necessary, addressed at the COL stage. The need for consideration of design-specific

hazards interactions'is COL Action Item 2.2-2.

2.2.3.4 Conclusions

As set forth above, the applicant has identified potential accidents related to the presence of

hazardous materials or activities on and near the proposed ESP site which could affect a

nuclear power plant falling within the applicant's PPE. The staff finds that the applicant has

selected those potential accidents which'should be considered as design-basis events at the

COL stage, in accordance with 10 CFR Part 100. The staff also finds that the applicant has

identified and evaluated hazards from nearby facilities such that the staff concludes that such

facilities pose no undue risk to the type of facility proposed for the site, subject to confirmation

at the COL stage regarding design-specific hazards interactions. Therefore, the staff concludes

that the site location is acceptable with regard to potential accidents that could affect such a

facility and that it meets the requirements of 10 CFR 52.1 7(a)(1 )(vii), 10 CFR 100.20(b), and

10 CFR 100.21 (e).

2.3 Meteorology

To ensure that a nuclear power plant or plants could be designed, constructed, and operated on

an applicant's proposed ESP site in compliance with the Commission's regulations, the NRC

2-19
Illi

staff evaluates regional and local climatological information, including climate extremes and

severe weather occurrences that may affect the design and siting of a nuclear plant. The staff

reviews information concerning atmospheric dispersion characteristics of a nuclear power plant

site to determine whether the radioactive effluents from postulated accidental releases, as well

as routine operational releases, are within Commission guidelines. The staff has prepared

Sections 2.3.1 through 2.3.5 of this SER in accordance with the review procedures described in

RS-002, using information presented in SSAR Section 2.3, responses to staff RAls, and

generally available reference materials, as described in the applicable sections of RS-002.

2.3.1 Regional Climatology

2.3.1.1 Technical lnformation in the Application

In this section of the SSAR, the applicant presented information concerning the averages and

the extremes of climatic conditions and regional meteorological phenomena that could affect

the design and siting of a nuclear power plant that falls within the applicant's PPE and that

might be constructed on the proposed site. The applicant provided the following information:

* a description of the general climate of the region with respect to types of air masses,

synoptic features (high- and low-pressure systems and frontal systems), general airflow

patterns (wind direction and speed), temperature and humidity, precipitation (rain, snow,

and sleet), and relationships between synoptic-scale atmospheric processes and local

(site) meteorological conditions

* seasonal and annual frequencies of severe weather phenomena, including tornadoes,

waterspouts, thunderstorms, lightning, hail (including probable maximum size), and high

air pollution potential

* meteorological site characteristics to be used as minimum design and operating bases,

including the following:

* the maximum snow and ice load (water equivalent) on the roofs of safety-related

structures

- the ultimate heat sink (UHS) meteorological conditions resulting in the maximum

evaporation and drift loss of water and minimum water cooling

- the tornado parameters, including translational speed, rotational speed, and the

maximum pressure differential with the associated time interval

- the 100-year return period straight-line winds

- other meteorological conditions to be used for design- and operating-basis

considerations

The applicant characterized the regional climatology pertinent to the North Anna ESP site using

data reported by the National Weather Service (NWS) at the Richmond, Virginia, first-order

weather station, as well as nearby cooperative observer stations, such as Louisa, Partlow, and

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Piedmont, Virginia. The applicant obtained information on severe weather from a variety of

sources, including publications by the National Climatic Data Center (NCDC), the American

Society of Civil Engineers (ASCE), the American Society of Heating, Refrigerating, and AirConditioning Engineers (ASHRAE), and the American National Standards Institute (ANSI).

The North Anna ESP site is located in the eastern Piedmont climatic division of Virginia.

According to ithe applicant, the climate can be described as modified continental; the summers

are warm and humid, and the winters are generally mild. The Blue Ridge Mountains to the-west

act as a potential barrier to outbreaks of cold, continental air in winter. The open waters of the

Chesapeake Bay and the Atlantic Ocean contribute to the humid summers and mild winters.

Temperatures in'the site region rarely exceed 100 'F or fall below 0 "F. Table 2.3.1-1 presents'

the applicant's dry-bulb and wet-bulb site characteristics for the North Anna ESP site, based on

temperature and humidity data recorded at the Richmond weather station.

. . . . . . I

. . , ...

!,!! I 1''"-

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- till

Table 2.3.1-1 Applicant's Proposed Ambient Air Temperature and Humidity Site

Characteristics

SITE CHARACTERISTIC VALUE DESCRIPTION

Maximum 2% annual 90 0F with 75 OF concurrent wet bulb Wet-bulb and dryDry-Bulb exceedance bulb temperatures

Temperature associated with the

0.4% annual 95 0

F with 77 'F concurrent wet bulb listed exceedance

exceedance values and the

0% annual 104.9 OF with 79 OF concurrent wet bulb period

exceedance

100-year return 109 OF

period

Minimum 1% annual 18 OF

Dry-Bulb exceedance

Temperature 0.4% annual 14 OF

exceedance

1 00-year return -19 0F

period

Maximum 0.4% annual 79 OF

Wet-Bulb exceedance

Temperature 0% annual 84.9 OF

exceedance

1 00-year return 88°F

period I

The applicant stated that the area around the site receives an annual average rainfall of

approximately 44 inches (in.). Rainfall is fairly well distributed over the entire year, with the

exception of July and August when thunderstorm activity raises the monthly totals. Extratropical storms can also contribute significantly to precipitation during September.

Richmond, Virginia, averages about 12.4 in. of snow a year. Snow generally remains on the

ground for only 1 or 2 days, although durations of a week or more have occurred as a result of

heavy snowfall events immediately followed by cold weather patterns.

According to the applicant, the general synoptic conditions typically predominate in regard to

climatic characteristics of the site region. However, during periods of extreme temperatures or

light-wind conditions, the local conditions have an influence on the site's meteorology. Nearby

Lake Anna has a moderating effect with respect to extreme temperatures in the immediate

vicinity of the site. The Blue Ridge Mountains to the west also tend to channel winds along a

general north-south orientation during light-wind conditions.

In Revision 0 to the SSAR, the applicant stated that the extreme fastest-mile wind speed at

30 ft above the ground (100-year return period) is 80 miles per hour (mi/hr), with a fastest-mile

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wind speed value of 68 mi/hr recorded at Richmond during the period 1958-1989. In

RAI 2.3.1-1, the staff asked the applicant to provide a 3-second (s) gust wind speed that

represents a 100-year return period. In response to RAI 2.3.1-1, the applicant provided a

3-s gust wind speed value of 96 mVhr, which represents a 100-year return period at 33 ft above

the ground. '

In Revision 3 to the SSAR, the applicant revised its extreme fastest-mile 100-year return period

wind speed value to 64 mi/hr, based on a calculated value reported for Richmond by

ANSI A58.1-1982, "Minimum Design Loads for Buildings and Other Structures." In Revision 3

to the SSAR, the applicant identified the 64 mi/hr fastest-mile wind speed value as a basic wind

speed site characteristic.

In Open Item 2.3-1, the staff stated that the applicant's revised 1 00-year return period

fastest-mile basic wind speed site characteristic of 64 mi/hr is not conservative when compared

,to the minimum 50-year return period fastest-mile basic wind speed value of 70 mi/hr specified

in Section 6.5.2 of ANSI A58.1-1982. The applicant's chosen fastest-mile basic wind speed site

characteristic of 64 mi/hr is also not conservative when compared to the highest fastest-mile

wind speed value of 68 mi/hr recorded at Richmond during the 32-year period 1958-1989. In

'its submittal dated March 3, 2005, the applicant responded to Open Item 2.3-1 by proposing

that the 3-s gust wind speed value of 96 mi/hr be used as the basic wind speed site

characteristic instead of the 64 mi/hr fastest-mile wind speed value. Table 2.3.1-2 presents the

applicant's revised proposed basic wind'speed site-characteristic. --

Table 2.3.1-2 Applicant's Proposed'Basic Wind Speed Site Characteristic

SITE CHARACTERISTIC VALUE - DESCRIPTION

Basic Wind Speed 3-s gust wind velocity associated with a 100-year return period

at 33 ft above ground level in the site area '

In RAls 2.3.1-1 and 2.3.1-6, the staff asked the applicant to provide additional information

regarding site characteristic tornado data and the methodology used for determining tornado

characteristics. In its response, the applicant stated that a total of 235 tornadoes were reported

within a 2-degree square area around the North Anna ESP site (i.e.', an area enclosed by

2-degree longitudinal and latitudinal lines centered on the North Anna ESP site) during the

period 1950-2003. The applicant used these data to calculate the annual probability of a

tornado striking a point within this 2-degree square area as 5.94x1 05 per year. -This is

equivalent to a tornado mean recurrence interval of 16,835 years. The applicant also used

these data to generate the tornado site characteristics (based on a 10 7 per year occurrence),

shown in Table 2.3.1-3.

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-~ I V:'

Table 2.3.1-3 Applicant's Proposed Tornado Site Characteristics

SITE

CHARACTERISTIC VALUE DESCRIPTION

Maximum Wind 260 mi/hr Sum of the maximum rotational and maximum translation wind

Speed speed components at the site, due to passage of a tornado

having a probability of occurrence of 10' per year

Maximum 52 mi/hr Translation component of maximum wind speed at the site, due

Translational Speed to the movement across ground of a tornado having a

probability of occurrence of 10'7 per year

Maximum Rotational 208 mi/hr Rotation component of maximum wind speed at the site, due to

Speed passage of a tornado having a probability of occurrence of 10-7

per year

Radius of Maximum 150 ft Distance from the center of the tornado at which the maximum

Rotational Speed rotational wind speed occurs at the site, due to passage of a

tornado having a probability of occurrence of 1 07 per year

Maximum Pressure 1.5 Ibf/in.2 Decrease in ambient pressure from normal atmospheric

Drop pressure at the site, due to passage of a tornado having a

probability of occurrence of 10'7 per year

Maximum Rate of 0.76 Ibf/in.2/s Maximum rate of pressure drop at the site, due to passage of a

Pressure Drop tornado having a probability of occurrence of 10 7 per year

The SSAR states that, on average, a tropical cyclone or its remnants can be expected to impact

some part of Virginia each year. As stated in the SSAR, the National Oceanic and Atmospheric

Administration (NOAA) Coastal Services Center hurricane database reports that 55 tropical

cyclone centers or storm tracks have passed within a 1 00-nautical mile (nmi) radius of the North

Anna ESP site from 1851 through 2003. Table 2.3.1-4 presents the storm classifications and

respective frequencies of these tropical cyclone occurrences over this period.

Table 2.3.1-4 Tropical Cyclones Reported within 100-Nautical Mile Radius of the North

Anna ESP Site from 1851 through 2003

MAXIMUM SUSTAINED WIND

CLASSIFICATION NUMBER OF OCCURRENCES SPEED RANGE

Category 3 Hurricane 1 11 1-130 mi/hr

Category 2 Hurricane 1 96-110 mi/hr

Category 1 Hurricane 5 74-95 mi/hr

Tropical Storm 27 39-73 mi/hr

Tropical Depression 13 s38 mi/hr

Subtropical Depression 1 s38 mi/hr

Extra-Tropical Storm 7 undefined

2-24
According to the applicant, tropical cyclones are responsible for the-following record rainfall

events in the North Anna ESP site area:

* In August 1969, Hurricane Camille (a tropical depression by' the time it passed within

100 nmi of the North Anna ESP site) resulted in a record 24-hour rainfall of 11.18 in. at

the Louisa cooperative weather station.< The SSAR notes that this is the overall highest

24-hour rainfall total recorded at any station in the North Anna ESP site area.

* in August 1955, Hurricane Connie (a'tropical storm by the time it passed within 120 nmi

of the North Anna ESP site) resulted in a record 24-hour rainfall total of 8.79 in. at

Richmond.

According to the applicant, the occurrence of snowfalls greater than or equal to 1 in. in the v:

North Anna ESP site area ranges from about 3 to 5 days per year. Daily snowfall totals greater

than or equal to thresholds of 5 in. and 10 in. occur less than 1 day per year. The applicant

reported maximum 24-hour and monthly snowfall totals for the North Anna ESP site region of

21.6 in. at Richmond in January 1940 and 41.0 in. at Partlow in January'1966,-respectively.

The applicant reported the weight of the 100-year'return period snowpack for the North Anna

ESP site area as 30.5 pound-force per square foot (Ibf/ft2) and the 48-hour winter probable:

maximum precipitation (also known as the probable maximum winter precipitation (PMWP)) as

20.75 in. In response to Open Item 2.3-2, the applicant also reported a maximum ground snow

load of 45.4 lbf/ft2 as the weight of the 100-year snowpack plus 48-hour maximum snowfall. As

shown in Table 2.3.1-5,'the applicant selected the 100-year return peridd snowpack value of

30.5 Ibf/ft2, the 1 00-year snowpack plus 48-hour maximum snowfall value of 45.4 lbf/ft2, and the

48-hour PMWP value of 20.75 in. as winter precipitation site characteristics for use'in the

design of the roofs of safety-related structures.

Table 2.3.1-5 Applicant's Proposed Winter Precipitation Site Characteristics

SITE CHARACTERISTIC VALUE DESCRIPTION

100-Year Snowpack 30.5 lbf/ft 2 Weight, per uOnit area, of the 100-year return period snowpack - at the site

100-Year Snowpack plus 45.5 lbf/ft2 48-hour maximum snowfall (28.5 in. - 15 lbf/ft2 on top of

48-Hour Maximum 100-year return snowpack (30.51bf/ft2)

Snowfall -

48-Hour Winter Probable . 20.75 in. - 'Maximum probable winter rainfall in a 48-hour period

Maximum Precipitation -

According to the applicant, data published by the NCDC show that Louisa and Spotsylvania

Counties can expect, on average, hail with diameters greater than or equal to 0.75 in. about

1 day per year. Nearby counties to the south and east of the North Anna ESP site can expect

hail with diameters greater than or equal to 0.75 in. to occur from 1 to 2 days per year. Hail

events with diameters up to 1.75 in. have been reported in recent years in both Louisa and

Spotsylvania Counties, four in Louisa County in 1998 and three in Spotsylvania County in 1993.

Softball-size hail (about 4.5 in. in diameter) has been observed in recent years at two locations

in the general North Anna ESP site area-once in Free Union, Virginia (approximately 42 miles

2-25
_ IIJI.

west of the ESP site) on June 4, 2002, and once in Lignum, Virginia (approximately 28 miles

north-northwest of the ESP site), on May 4, 1996.

The applicant estimated that, on average, 36 thunderstorm-days per year occur in the site area,

resulting in an estimated 11.2 lightning flashes to earth per square mile per year. Given the

frequency of thunderstorms and the size of the North Anna ESP site PPE (site footprint within

which any new reactors would be located) (0.068 mi2), the expected frequency of lightning

flashes in the PPE is 0.76 per year.

According to the applicant, low-level inversions in the North Anna ESP site region based at or

below an elevation of 500 ft occur during approximately 30 percent of the year. Most of these

inversions are nocturnal in nature, generated through nighttime cooling. These inversions

occur most frequently during the autumn and winter seasons and least frequently during the

spring and summer seasons. Likewise, the autumn and winter seasons have the greatest

frequency of occurrence of shallow mixing depths, with autumn and winter having afternoon

mean maximum mixing height depths of about 4600 ft and 3300 ft, respectively.

The applicant examined temperature and humidity data from Richmond (1978-2003) to

determine the meteorological site characteristics for the UHS in accordance with RG 1.27,

"Ultimate Heat Sink for Nuclear Power Plants," issued January 1976. The applicant stated that

the controlling parameters for the type of UHS selected by the applicant (i.e., a mechanical draft

cooling tower over a buried water storage basin or other passive water storage facility) are the

wet-bulb temperature and the coincident dry-bulb temperature. The applicant considered the

worst (i.e., highest) 30-day daily average of wet-bulb temperatures and coincident dry-bulb

temperatures to represent the meteorological conditions resulting in maximum evaporation and

drift loss. Likewise, the applicant considered the worst (i.e., highest) 1-day and 5-day daily

average of wet-bulb temperatures and coincident dry-bulb temperatures to conservatively

represent the meteorological conditions resulting in minimum water cooling. Consequently, the

applicant calculated the worst 1-day, worst 5-day, and worst 30-day daily average wet-bulb

temperatures and coincident dry-bulb temperatures as UHS meteorological site characteristics

values. Table 2.3.1-6 presents these results.

In Open Item 2.3-3, the staff identified the need for an additional UHS meteorological site

characteristic for use in evaluating the potential for water freezing in the UHS water storage

facility, a phenomenon which would reduce the amount of water available for use by the UHS.

In its submittal dated March 3, 2005, the applicant responded to Open Item 2.3-3 by proposing

use of the maximum cumulative degree-days below freezing as the relevant site characteristic.

The applicant proposed a maximum cumulative degree-day below freezing site characteristic

value of 322 OF degree-days, based on the maximum value derived from December 1 through

March 31 for the period 1949-2001, using daily mean air temperatures recorded at Piedmont.

2-26
Table 2.3.1-6 Applicant's Proposed Ultimate Heat Sink Meteorological Site

Characteristics

SITE CHARACTERISTIC -VALUE - - DESCRIPTION

Worst 1 -Day Daily 78.9 0F wet-bulb temperature with Meteorological conditions

Average of Wet-Bulb coincident 87.7 'F dry-bulb temperature resulting in the minimum water

Temperatures and cooling during any 1 day

Coincident Dry-Bulb . Temperatures

Worst 5-Day Daily 77.6 *F wet-bulb temperature with Meteorological conditions

Average of Wet-Bulb coincident 80.9 0F dry-bulb temperature resulting in the minimum water

Temperatures and cooling during any consecutive

Coincident Dry-Bulb 5 days

Temperatures ._._.

Worst 30-Day Daily 76.3 'F wet-bulb temperature with Meteorological conditions

Average of Wet-Bulb coincident 79.5 0

F dry-bulb temperature resulting in the maximum

Temperatures and evaporation and drift loss

Coincident Dry-Bulb during any consecutive

Temperatures -30 days

Maximum Cumulative 322 0F.degree-days Meteorological condition

Degree-Days Below resulting in the maximum

Freezing formation of surface ice in the

UHS basin

2.3. 1.2 Regulatory Evaluation

In SSAR Section 1.8.1, the applicant identified the following applicable NRC regulations

regarding regional climatology:

Appendix A, uGeneral Design Criteria for Nuclear Power Plants," tol10 CFR Part 50,

General Design Criterion (GDC) 2, "Design Bases for Protection Against Natural

Phenomena," with respect to information on severe regional weather phenomena that

have historically been reported for the region and that are reflected in the design bases

for SSCs important to safety .

* Appendix A to 10 CFR Part 50, GDC 4, "Environmental and Dynamic.Effects Design

Bases," with respect to information on tornadoes that could generate missiles

* 10 CFR 100.20(c) and 10 CFR 100.21 (d) with respect to the consideration that has

been given to the regional meteorological characteristics of the site

In SSAR Sections 1.8.2 and 2.3.1, the applicant identified the following applicable NRC

guidance regarding regional climatology:

* RG 1.27 with respect to the meteorological conditions that should be considered in the

design of the UHS

2-27
I I .

* Section 2.3.1 of RG 1.70 with respect to the type of general climate and regional

meteorological data that should be presented

* RG 1.76, "Design Basis Tornado for Nuclear Power Plants," issued April 1974, with

respect to the characteristics of the design-basis tornado

The staff has reviewed this portion of the application in accordance with the guidance identified

by the applicant, and to determine if the application is in compliance with the identified

regulations, with the exception of the GDC. An ESP applicant need not demonstrate

compliance with the GDC with respect to regional climatology.

Section 2.3.1 of RS-002 and Section 2.3.1 of RG 1.70 provide the following guidance on

information appropriate for determining regional climatology:

* The description of the general climate of the region should be based on standard

climatic summaries compiled by NOAA. Consideration of the relationships between

regional synoptic-scale atmospheric processes and local (site) meteorological conditions

should be based on appropriate meteorological data.

* Data on severe weather phenomena should be based on standard meteorological

records from nearby representative NWS, military, or other stations recognized as

standard installations that long periods of data on record. The applicability of these data

to represent site conditions during the expected period of reactor operation should be

substantiated.

* Tornado site characteristics may be based on RG 1.76 or the staff's interim position on

design-basis tornado characteristics (see letter dated March 25, 1988, from the NRC to

the Advanced-Light Water Reactor Utility Steering Committee). An ESP applicant may

specify any tornado wind speed site characteristics that are appropriately justified,

provided that a technical evaluation of site-specific data is conducted.

* Basic (straight-line) wind speed site characteristics should be based on appropriate

standards, with suitable corrections for local conditions.

* The UHS meteorological data, as stated in RG 1.27, should be based on long-period

regional records which represent site conditions. Suitable information may be found in

climatological summaries for the evaluation of wind, temperature, humidity, and other

meteorological data used for UHS design.

* Freezing rain estimates should be based on representative NWS station data.

* High air pollution potential information should be based on U.S. Environmental

Protection Agency (EPA) studies.

* All other meteorological and air quality data to be used for safety-related plant design

and operating bases should be documented and substantiated.

2-28
2.3.1.3 Technical Evaluationi I

The staff evaluated regional meteorological conditions using information reported by the NCDC,

the National Severe Storms Laboratory (NSSL), the Southern Regional Climate Center (SRCC),

ASHRAE, ASCE, and the Structural Engineering Institute (SEI).' The staff reviewed statistics

for the following climatic stations located in the vicinity of the North Anna ESP site:-

* Partlow, Virginia, located approximately 5 miles east of the ESP site

* Louisa, Virginia, located approximately 11 miles west of the ESP site

* Piedmont, Virginia, located approximately 21 miles west-northwest of the ESP site

* Richmond, Virginia, located approximately 47 miles southeast of the ESP site

* Charlottesville, Virginia, located approximately 36 miles west of the' ESP site'-

Normal climatic data for the period 1971-2000 reported by NCDC for the eastern Piedmont

climatic division of Virginia indicate that the annual mean temperature in the area is about

56.6 'F and ranges froh, a low monthly mean value of about 35.9 0F in January to a high:-.

monthly mean value of about 76.8 0F in July (NCDC, "Eastern Piedmont,-Virginia, Divisional

Normals-Temperature, Period 1971-2000, Climatography of the United States No. 85"). One

of the highest temperatures recorded in the-site region was 106 OF at Partlow on both

August 31 and September 2,1953 (SRCC, uPartlow, Virginia, Period of Record Monthly Climate

Summary, Period of Record: 06/01/1952 to 12/31/1976"); one of the lowest temperatures

recorded in the site region was -21 'F at Louisa on February 5,1996 (SRCC, "Louisa, Virginia,

Period of Record Monthly Climate Summary, Period of Record: 08/01/1948 to 03/31/2004").

The annual mean wet-bulb temperature at Richmond is 52.3 OF, ranging from a high monthly

mean value of 71.5 OF in July to a low monthly mean value of 34.3 0F in January. The annual

mean relative humidity is 70 percent (NCDC, "Richmond, Virginia, 2002 Local Climatological

Data, Annual Summary with. Comparative Data").

For the reasons set forth below, the staff concurs with the temperature and humidity site

characteristics presented by the applicant. The applicant's 2- and 0.4-percent annual '

exceedance maximum dry-bulb temperatures, the 1- and 0.4-percent annual exceedance

minimum dry-bulb temperatures, and the 0.4 percent exceedance maximum wet-bulb

temperatures are based on Richmond data published by the NCDC ('Engineering Weather

Data CDROM").' The applicant's 0-percent annual exceedance maximum dry-bulb and

maximum'wet-bulb temperatures represent the highest values recorded at Richmond during the

period 1973-2002. -The 1 00-year return period maximum dry-bulb and maximum wet-bulb

temperatures provided by-the applicant were'extrapolated from the Richmond 1973-2002 data

using a least squares regression method,'as described in the applicant's response to NRC -

RAI 2.3.1(b). In order to verify the applicant's 100-year return period data, the staff alsocalculated 1 00-yearr return period maximum dry-bulb and maximum wet-bulb temperatures

using NCDC data for Richmond during the period 1961-1990 (NCDC, "Solar and

Meteorological Surface Observational Network (SAMSON) for Eastern U.S. CDROM") and

algorithms based on the Gumbel Type 1 extreme'value-distributiob as defined in Chapter 27 of

'The data presented by the applicant as the 1- and 0.4-percent annual exceedance

minimum dry-bulb temperatures are equivalent to the NCDC 99- and 99.6-percent annual

exceedance (i.e., occurrence) values.

2-29
Ill.

the 2001 ASHRAE Handbook-Fundamentals. The staff found that the 100-year return period

maximum dry-bulb and maximum wet-bulb temperature values calculated by the applicant

bound the equivalent values calculated by the staff.

The staff chose not to list the applicant's 0-percent annual exceedance maximum dry-bulb and

wet-bulb temperatures as site characteristics because these values are dependent upon the

length of the available period of record. The staff presented 100-year return period values

instead.

According to the 1971-2000 normal climatic data reported by NCDC for the eastern Piedmont

climatic division of Virginia ("Eastern Piedmont, Virginia, Divisional Normals-Precipitation,

Period 1971-2000, Climatography of the United States No. 85"), precipitation is well distributed

throughout the year, with monthly climate division normals for the North Anna ESP site region

ranging from a minimum of about 3.18 in. in December to a maximum of about 4.36 in. in July.

In September 1987, Charlottesville experienced one of the highest monthly amounts of

precipitation observed in the area-1 7.96 in. (SRCC, "Charlottesville, Virginia, Period of Record

Monthly Climate Summary, Period of Record: 08/05/1948 to 03/31/2004"). On August 20,

1969, Louisa recorded one of the highest 24-hour precipitation totals for the site

region-1 1.18 in. (SRCC, "Louisa, Virginia, Period of Record Monthly Climate Summary, Period

of Record: 08/01/1948 to 03/31/2004"). This rainfall was associated with Hurricane Camille.

Snowfall in the site vicinity averages approximately 16.6 in. per year, based on historical data

collected during 1952-1976 at the Partlow cooperative weather station (SRCC, "Partlow,

Virginia, Period of Record Monthly Climate Summary, Period of Record: 06/01/1952 to

12/31/1976"). Measurable snowfall has occurred from November through April, with the most

snow typically falling in January (5.7 in. on average in Partlow).

Damaging storms occur mainly from snow and freezing rain in winter, and from hurricanes,

tornadoes, and severe thunderstorms in other seasons (NCDC, "Richmond, Virginia, 2002

Local Climatological Data, Annual Summary with Comparative Data"). Damage may be caused

by wind, flooding, or rain, or by any combination of these. Tornadoes are infrequent, but some

occurrences have been observed within the area.

The applicant presented a 100-year return period fastest-mile wind speed value of 64 mi/hr in

Revision 3 to the SSAR. The applicant's chosen 100-year return period fastest-mile wind speed

is not conservative when compared to the minimum 50-year return period fastest-mile basic

wind speed of 70 mi/hr specified in Section 6.5.2 of ANSI A58.1-1982. The applicant's chosen

value is also not conservative when compared to the highest fastest-mile wind speed of

68 mi/hr recorded at Richmond during the 32-year period of record, 1958-1989. Consequently,

the staff does not endorse the use of the 64 mi/hr 100-year return period fastest-mile wind

speed value as a basic wind speed site characteristic. This concern resulted in Open

Item 2.3-1.

In its response to Open Item 2.3-1, the applicant proposed using a 100-year return period 3-s

gust wind speed value of 96 mi/hr as the basic wind speed site characteristic. The applicant

determined this value in accordance with the guidance provided by the ASCE and the SEI

industry standard on building loads ("Minimum Design Loads for Buildings and Other

Structures," SEV/ASCE 7-02). Therefore, the staff concludes that a 3-s gust wind speed site

characteristic of 96 mi/hr is acceptable.

2-30
According to NSSL (NCDC, "Severe Thunderstorm Climatology, Total Threat"), the mean

number of days per year with ihe threat of tornados occurring within 25 miles of the North Anna

ESP site is approximately 0.4 to 0.6 for any tornado, approximately 0.05 to 0.10 for a significant

tornado (F2 or. greater; wind speeds in excess of 113 mi/hr), and less than 0.005 for a violent

tornado (F4 or greater; wind speeds in excess of 207 mi/hr). '

At the NRC's direction, Pacific Northwest National Laboratories (PNNL) 'prepared a technical

evaluation'report evaluating the tornado site characteristics fdr the North Anna ESP site

(Ramsdell, Jr., V.J., 'Technical Evaluation Report on Design' Basis Tornadoes for the North

Anna ESP Site"). 'This report derived a best estimate annual tornado strike probability of

1.6x1 0-4, based on tornado data from the period January 1950 through August 2003.; This

probability corresponds'to a mean recurrence interval of 6250 years. Using a slightly different

methodology and period of record, the applicant calculated a similar but higher tornado return

period of 16,835 years. The PNNL report also derived a best estimate 1 O' per year occurrence

tornado site characteristics wind speed of 245 mi/hr, which is bounded by the applicant's

tornado site characteristics wind speed of 260 mi/hr. The applicant derived the remaining

tornado site characteristics (i.e., pressure drop and rate of pressure drop) assuming the radius

of the'maximum'rotational wind speed is 150 ft and the ratio between the rotational wind speed

and the translational wind speed is 4. These assumptions are consistent with'the'staff's interim

position on design-basis tornado characteristics. Therefore, the staff concludes that the"

applicant's tornado site characteristics are acceptable.

During the period 1900-2002, a total of 4 hurricanes and 17 tropical storms directly hit Virginia

(Landreneau, .D., "Atlantic Tropical Storms and Hurricanes Affecting the United States:

1899-2002," NOAA Technical Memorandum NWS SR-206 (updated through 2002)). These

storms typically weaken as they move inland, so wind damage is usually confined to the coastal

regions,'while damage inland comes primarily frorm heavy rain and flooding. One of the most

significant tropical cyclones to affect portions of east-central Virginia during the last several

decades was Hurricane Isabel on September 18-19, 2003. Isabel made landfall -near Drum

Inlet, North Carolina, as a Category 2 hurricane (maximum sustained winds between 96 and

100 milhr), then weakened to a tropical storm over southern Virginia as'it tracked horthwest into

central Virginia, just west of Richmond. The highest sustained wind speed recorded at

Richmond was 38 mrihr; the highest gust recorded at Richrnmnd was 73 mi/hr.- The unusually

large wind field resulted in the most extensive power outages ever-experienced in Virginia.

Inland flooding also resulted from rainfall amounts ranging from 4 to 7 in., which occurred overparts of the Piedmont regions of central and south central Virginia (Bevena, J.,and H.Cobb,

"Tropical Cyclone Report, Hurricane Isabel, 6'&19 September 2003," National Hurricane Center

and NCDC Storm Event Database, "Storm Events for Virginia,'01/01/1950 through

04/30/2004"). 'Although Hurricane Isabel had a significant impact on the ESP site region, it did

not result in any recordbreaking wind or rainfall statistics and, as such, has no impact on the

climatic site characteristics of the North Anna ESP site.

The highest monthly and annual total snowfalls recorded at the Partlow station were 41 in. and

54 in., respectively. - One' of the' highest reported 24-hour snowfall observations in the site

region was 21.6 in. in January 1940 at Richmond '(NCDC, "Richmond, Virginia, 2002 Local

Climatological Data, Annual Summary with Comparative Data"). One of the highest snow

depths recorded in the site region was 24 in. on January 26, 1987, and on January 30, 1966, in

Louisa'(SRCC, "Louisa, Virginia, Period of Record Monthly Climate Summary, Period of'.

Record: 08/01/1948 to 03/31/2004"). - :

2-31
- :1lL

RG 1.70 specifies both the weight of the 100-year return period snowpack and the weight of the

48-hour PMWP to assess the potential snow loads on the roofs of safety-related structures.

The staff's interim position on winter precipitation loads (see memorandum dated March 24,

1975, from H. R. Denton to R. R. Maccary) provides clarification as to the load combinations to

be used in evaluating the roofs of safety-related structures. Consistent with the staff's interim

position on winter precipitation loads, the winter precipitation loads to be included in the

combination of normal live loads to be considered in the design of a nuclear power plant or

plants that might be constructed on a proposed ESP should be based on the weight of the

100-year snowpack or snowfall, whichever is greater, recorded at ground level. Likewise, the

winter precipitation loads to be included in the combination of extreme live loads to be

considered in the design of a nuclear power plant or plants that might be constructed on a

proposed ESP should be based on the weight of the 100-year snowpack at ground level plus

the weight of the 48-hour PMWP at ground level for the month corresponding to the selected

snowpack. A COL or CP applicant may choose and justify an alternative method for defining

the extreme winter precipitation load by demonstrating that the 48-hour PMWP could neither fall

nor remain on the top of the snowpack and/or building roofs.

The applicant has identified a 100-year return period snowpack of 30.5 lbf/ft2 for the North Anna

ESP site. The applicant determined this value in accordance with the guidance of

SEI/ASCE 7-02. Because the applicant performed its analysis in accordance with the

appropriate guidance and the results bound the observations described above, the staff

concludes that a 100-year return period snowpack site characteristic value of 30.5 lbf/ft2 is

acceptable.

The applicant has identified a 48-hour PMWP value of 20.75 in. of water for the North Anna

ESP site. Because the applicant determined this value in accordance with the guidance of

NUREG/CR-1 486, "Seasonal Variation of 10-Square-Mile Probable Maximum Precipitation

Estimates, United States East of the 105'h Meridian," issued April 1980, the staff concludes that

a 48-hour PMWP site characteristic value of 20.75 in. of water is acceptable.

Open Item 2.3-2 requests that the applicant justify exclusive use of snowpack weight for

calculating snowload or provide an alternative method. In response to Open Item 2.3-2, the

applicant has proposed an additional winter precipitation site characteristic. The applicant

defined this additional winter precipitation site characteristic as the sum of the 100-year return

period snowpack and the 48-hour maximum winter snowfall event. The applicant used the

maximum monthly snowfall recorded for Richmond (28.5 in. of snow, which is approximately

equivalent to 15 lbf/ft2) to conservatively define the 48-hour maximum winter snowfall event.

The staff has chosen not to include the applicant's proposed sum of the 100-year return period

snowpack (30.5 lbf/ft2) and the 48-hour maximum winter snowfall event (15 Ibf/ft2), 45.5 Ibf/ft2,

as an additional winter precipitation site characteristic. Once the roof design is known, the COL

or CP applicant has the option to demonstrate that the 48-hour PMWP could neither fall nor

remain entirely on top of the 100-year snowpack and/or building roofs.

The following discussion on freezing rain, hail, and lightning is intended to provide a general

climatic understanding of the severe weather phenomena in the site region but does not result

in the generation of site characteristics for use as design or operating bases.

The NCDC reports a 50-year return period uniform radial ice thickness of 0.75 in. resulting from

freezing rain, with a concurrent 3-s gust wind speed of 30 mi/hr for the North Anna ESP site

2-32
area (Jones, K., et al., "The Development-of a U.S.-Climatologyof Extreme Ice Loads,"

Technical Report 2002-01).

Hail often accompanies severe thunderstorms. According to the NCDC storm events database

(NCDC Storm Event Database, 'Storm Events for Virginia, 01/01/1950 through 07/31/2003"),

66 occurrences of hail with dia'meters of 0.75 in. or greater were reported in the five-county

region surrounding the site between January 1, 1955, and July 31, 2003. Seventeen of these

occurrences reported hail diameters of 1.5 in. or more. The largest reported size was 2.5 in.

which occurred on July 9, 1977, in Caroline County, approximately'25-30 miles southeast of the

site. According to'NSSL (NCDC, "Severe Thunderstorm Climatology, Total Threat"), the threat

of hail occurring within 25 miles of the North' Anna ESP site is approximately 2 days per year for

damaging hail or hail 0.75 in.' in diameter or greater, and 0.25 to 0.50 days per year for hail 2 in.

or more in diameter.

The applicant has estimated that approximately 11.2 lightning flashes per year per square mile

occur around the site area. The applicant's estimate is consistent with the mean annual ground

flash density of 4 flashes per square kilometer (10.4 flashes per square mile) presented in

NUREG/CR-3759, "Lightning'Strike Density for the Contiguous United States from

Thunderstorm Duration Records," issued in' 1984 for the North Anna ESP site region.

Large-scale episodes of atmospheric stagnation are not infrequent in the site region.

Korshover ("Climatology of Stagnating Anticyclones East of the Rocky Mountains, 1936-1975")

reports that, during the 40-year period between 1936 and 1975, high-pressure stagnation

conditions, lasting for 4 days or more, occurred about 49 times, with an average of

4.8 stagnation days per case. Five of these stagnation cases lasted 7 days or longer.'

The staff found that, according to Holzworth ("Mixing Heights, Wind Speeds, and Potential for

Urban Air Pollution throughout the Contiguous United States"), seasonal mixing heights range

from an average low of 400 met6rs (1300 ft) during autumn mornings to an average high of

1800 meters (5900 ft) during spring and summer afternoons. According to Hosler ("Low-Level

Inversion Frequency in the Contiguous United States"), low-level, mostly nocturnal inversions

are expected to occur approximately 30 percent of the time, with the greatest frequency during

the fall and winter (approximately 34 percent of the time and 33 percent of the time,

respectively) and With the least frequency during the spring and summer (approximately

28 percent of the time for each season).

The above discussion on atmospheric stanation, mixing heights; and inversions is intended to

provide a general climatic understanding of the air pollution potential in the region.

'Section 2.3.2 of this SER discusses the ESP air quality conditions considered for design and

'operating bases. Section 2.3.4 and 2.3.5 of this SER present the atmospheric dispersion site

characteristics used to evaluate short-term postaccident airborne releases and long-term

routine airborne releases, respectively.

In order to verify the applicant's UHS meteorological site characteristic resulting in minimum

water cooling and maximum evaporation and drift loss, the staff examined 30 years

(1961-1990) of hourly temperature and humidity data from Richmond ("Solar and

Meteorological Surface Observational Network (SAMSON) for Eastern U.S. CDROM"). The

staff calculated 1 -day, 5-day; and 30-day average wet-bulb temperatures from the hourly data

and selected the periods with the highest average wet-bulb temperatures as the worst periods.

2-33
--_l:1:

The resulting maximum 1-day, 5-day, and 30-day average wet-bulb temperature values were

similar to the values presented by the applicant.

In Open Item 2.3-3, the staff identified the need for an additional UHS meteorological site

characteristic for use in evaluating the potential for ice formation in the UHS water storage

facility. In its response to Open Item 2.3-3, the applicant identified a maximum cumulative

degree-days below freezing value of 322 IF degree-days as a UHS meteorological site

characteristic for use in evaluating the potential for water freezing in the UHS water storage

facility. Section 2.4.7 of this SER describes the staff's independent evaluation of the

meteorological conditions resulting in the maximum formation of surface ice (and therefore the

minimum initial volume of liquid water available to the UHS). Using daily temperature data from

Piedmont, the staff was able to reproduce a maximum cumulative degree-days below freezing

value similar to the value presented by the applicant.

Based on the discussion presented above, the staff concludes that the UHS meteorological site

characteristics proposed by the applicant are acceptable.

The staff intends to include the regional climatic site characteristics listed in Table 2.3.1-7 in

any ESP permit that might be issued for the North Anna ESP site.

Table 2.3.1-7 Staff's Proposed Regional Climatic Site Characteristics

SITE CHARACTERISTIC VALUE DESCRIPTION

Ambient Air Temperature and Humidity

Maximum 2% annual 90 0F with 75 0F concurrent wet-bulb The ambient dry-bulb temperature (and

Dry-Bulb exceedance coincident wet-bulb temperature) that will be

Temperature exceeded 2% of the time annually

0.4% annual 95 IF with 77 0F concurrent wet-bulb The ambient dry-bulb temperature (and

exceedance coincident wet-bulb temperature) that will be

exceeded 0.4% of the time annually

100-year 109 F The ambient dry-bulb temperature that has a

return period 1% annual probability of being exceeded

(100-year mean recurrence interval)

Minimum Dry- 99% annual 18 IF The ambient dry-bulb temperature below which

Bulb exceedance dry-bulb temperatures will fall 1% of the time

Temperature annually

99.6% annual 14 F The ambient dry-bulb temperature below which

exceedance dry-bulb temperature will fall 0.4% of the time

annually

100-year -19 °F - The ambient dry-bulb temperature for which a

return period 1% annual probability of a lower dry-bulb

temperature exists (100-year mean recurrence

interval)

Maximum 0.4% annual 79 F The ambient wet-bulb temperature that will be

Wet-Bulb exceedance exceeded 0.4% of the time annually

Temperature

100-year 88 0F The ambient wet-bulb temperature that has a

return period 1% annual probability of being exceeded

(100-year mean recurrence interval)

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SITE CHARACTERISTIC VALUE DESCRIPTION

Basic Wind Speed _ .

3-s Gust 96 mi/hr ' The 3-s gust wind speed at 33 ft above the

ground that has a 1% annual probability of being

exceeded (100-year mean recurrence interval)

TornadoMaximum Wind Speed 260 mi/hr Maximum wind speed resulting from passage of

a tornado having a probability of occurrence of

Io" per year

Translational Speed 52 mi/hr Translation component of the maximum tornado

wind speed

Rotational Speed 208 mi/hr Rotation component of the maximum tornado

wind speed

Radius of Maximum Rotational. 150 ft - - Distance from the center of the tomado at which

Speed . the maximum rotational wind speed occurs

Maximum Pressure Drop 1.5 lbf/in? Decrease In ambient pressure from normal

- ,atmospheric pressure resulting from passage of

Maximum Rate of Pressure 0.76 Ibfin.2

/s - Rate of pressure drop resulting from the

Drop passage of the tornado

Winter Precipitation '

i00-Year Snowpack 30.5 lbf/ft2 Weight of the 100-year return period snowpack

(to be used in determining normal precipitation

loads for roofs)

48-Hour Probable Maximum 20.75 in. of water Probable maximum precipitation during the

Winter Precipitation winter months (to be used In conjunction with

the 100-year snowpack In determining extreme

winter precipitation loads for roofs) -

Ultimate Heat Sink

Meteorological Conditions 78.9 OF wet-bulb temperature with Historic worst 1 -day daily average of wet-bulb

Resulting In the Minimum coincident 87.7 OF dry-bulb temperature temperatures and coincident dry-bulb.

Water Cooling During Any temperatures

, 1 Day

Meteorological Conditions - ' . 77.6 0F.wet-bulb temperature with Historic worst 5-day daily average of wet-bulb

Resulting in the Minimum coincident 80.9 'F dry-bulb temperature temperatures and coincident dry-bulb

Water Cooling During Any temperatures resulting in minimum water

Consecutive 5 Days - C- cooling

Meteorological Conditions 76.3 OF wet-bulb temperature with Historic worst 30-day daily average of wet-bulb

Resulting in the Maximum coincident 79.5 OF dry-bulb temperature temperatures and coincident dry-bulb

Evaporation and Drift Loss temperatures

During Any Consecutive

30 Days

Meteorological Conditions 322 OF degree-days below freezing Historic maximum cumulative degree-days

Resulting In Maximum Water below freezing

Freezing in the UHS Water , , . - --

Storage Facility '

The staff acknowledges that long-term climatic change resulting from human .or natural causes.

may introduce trends into design conditions. However, no conclusive evidence or consensus of

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-

11'.

opinion is available on the rapidity or nature of such changes. If in the future the ESP site is no

longer in compliance with the terms and conditions of the ESP (e.g., new information shows

that the climatic site characteristics no longer represent extreme weather conditions due to

climate change), the staff may seek to modify the ESP or impose requirements on the site in

accordance with the provisions of 10 CFR 52.39, "Finality of Early Site Permit Determinations,"

if necessary, to bring the site into compliance with Commission requirements to assure

adequate protection of the public health and safety.

2.3.1.4 Conclusions

As set forth above, the applicant has presented and substantiated information relative to the

regional meteorological conditions important to the safe design and siting of a nuclear power

plant or plants falling within the applicant's PPE that might be constructed on the proposed site.

The staff has reviewed the available information provided and, for reasons given above,

concludes that the identification and consideration of the regional and site meteorological

characteristics set forth above meet the requirements of 10 CFR 100.20(c) and 10 CFR

100.21 (d).

The staff finds that the applicant has considered the most severe regional weather phenomena

in establishing the site characteristics identified above. The staff has generally accepted the

methodologies used to determine the severity of the weather phenomena reflected in these site

characteristics, as documented in SERs for previous licensing actions. Accordingly, the staff

concludes that the use of these methodologies results in site characteristics containing margin

sufficient for the limited accuracy, quantity, and period of time in which the data have been

accumulated. In view of the above, the site characteristics previously identified are acceptable

for use as part of the design bases for SSCs important to safety, as may be proposed in a COL

or CP application.

With regard to tornado wind speed, the applicant conducted a technical assessment of sitespecific tornado data. The staff finds the assessment sufficient to justify the applicant's

proposed site tornado characteristics, which deviate from the staff's interim position on designbasis tornado characteristics. In addition, the staff finds that these tornado site characteristics

are acceptable for the design-basis tornado used for the generation of missiles.

The staff has reviewed the applicant's proposed site characteristics related to climatology for

inclusion in an ESP for the applicant's site, should one be issued, and finds these

characteristics to be acceptable. The staff has also reviewed the applicant's proposed design

parameters (PPE values) for inclusion in such an ESP (SSAR Section 1.3) and finds them to be

reasonable. The staff did not perform a detailed review of these parameters.

2.3.2 Local Meteorology

2.3.2.1 Technical Information in the Application

In Section 2.3.2 of the SSAR, the applicant presented local (site) meteorological information.

This SSAR section also addresses the potential influence of construction and operation of a

nuclear power plant or plants falling within the applicant's PPE on local meteorological

conditions that might in turn adversely impact such a plant or plants or the associated facilities.

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Finally, the applicant provided a topographical description of the site and its environs. The

applicant presented the following information:

* a description of the local (site) meteorology in terms of airflow, temperature,

atmospheric water vapor, precipitation, fog, atmospheric stability, and air quality

* an assessment of the influence on the local meteorology of construction and operation

of a nuclear power plant or plants falling within the applicant's PPE that might be

constructed on the proposed site and its facilities, including the effects of plant

structures, terrain modification, and heat and moisture sources resulting from plant

operation

* a topographical description of the site and its environs, as modified by the structures of

a nuclear power plant or plants falling within the applicant's PPE that might be

- -constructed on the proposed site

The applicant used data from the NWS first-order weather station at Richmond, Virginia, as well

as data provided by NCDC from six nearby cooperative observer weather stations, to

characterize temperature, rainfall, and snowfall for the North Anna ESP site area. The

applicant also provided wind, humidity, and fog data collected at Richmond.

In general, the applicant considered the more extensive meteorological data available for:

Richmond to be fairly representative of conditions in the ESP site area. -However, the applicant

noted slight differences in the Richmond data with respect to minimum temperature extremes,

diurnal temperature ranges, and average annual snowfall, as compared to corresponding data

observed at nearby cooperative weather stations. The applicant attributed these differences to

the consequences of urban heating for the more urban Richmond location.

The applicant also characterized local meteorological conditions using data collected from the

meteorological monitoring program at the existing NAPS. According to the applicant, the

meteorological variables collected by the NAPS monitoring program are appropriate for use in

describing local meteorological conditions because of the proximity of the NAPS meteorological

tower to the ESP site. -

The applicant presented historical normals (e.g., 30-year averages) and extremes of

temperature, rainfall, and snowfall for the seven nearby NWS and cooperative weather stations

in the North Anna ESP site area. Daily mean temperatures among the observing stations are

fairly similari ranging from 54.2 0F to 57.6 cF. Extreme maximum temperatures have ranged

from 100 0F to 107 0F; whereas extreme minimum temperatures have ranged from -10 0F to

-21 "F. -Normal annual precipitation totais are also fairly comparable among these observing

stations, ranging from 42.24 in. to 48.87 in. Normal annual snowfall totals range from 12.4 in.

to 18.8 in.

According to the applicant, an average of 27.2 days per year of heavy fog has been reported for

Richmond, which is the location closest to the North Anna ESP site for which a fog data set

exists. Low regions at the site and in the vicinity of Lake Anna would be expected to have a

higher frequency of fog occurrences because of the accumulation of relatively cool surface air

from flows draining from higher elevations, as compared to the relatively flat region of the

Richmond weather station.

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Ill.

According to information provided by the applicant, onsite winds occur along a north-south

orientation on an annual basis, with seasonal variations. Wind data taken from the 33-ft level of

the onsite meteorological tower for the 14-year period between 1974 and 1987 indicate that the

predominant wind directions are from the south-southwest (about 10 percent of the time), north

(about 9 percent of the time), northwest (about 9 percent of the time), and west-northwest

(about 8 percent of the time). Winds from the northeast clockwise through south-southeast and

from the west-southwest and the west occur least frequently (each about 4 percent of the time).

Wind direction distributions based on data from the 159-ft level are similar to those based on

the lower-level data. The onsite annual average wind speeds are 6.3 mi/hr at the 33-ft level

and 8.6 mi/hr at the 159-ft level.

The SSAR presents atmospheric stability data based on delta-temperature measurements

between the 159-ft and 33-ft levels on the onsite meteorological tower. Neutral (Pasquill

type "D") and slightly stable (Pasquill type "E") conditions predominate, occurring about 31 and

26 percent of the time, respectively. Moderately stable (Pasquill type "F") and extremely stable

(Pasquill type "G") conditions occur about 8 and 5 percent of the time, respectively.

The applicant stated that the dimensions of the new plant structures and associated paved,

concrete, and other improved surfaces would be insufficient to generate discernable impacts on

local and regional meteorological conditions beyond the areas immediately adjacent to the site

structures and improved surfaces. The applicant concluded that the small and localized surface

water temperature increases on Lake Anna resulting from the operation of an open-cycle

cooling system for the applicant's proposed Unit 3 would not be expected to significantly impact

the ongoing moderation of temperature extremes and alterations of local wind patterns by the

lake. Induced fogging conditions under extreme humidity conditions during cooler seasons

would most likely coincide with naturally occurring fogging conditions, and the applicant does

not expect the proposed Unit 3 to significantly increase the occurrence of local fog. Similarly,

the applicant expects that any increases in ambient temperatures resulting from the operation

of a closed-loop dry tower system proposed for Unit 4 would be very localized to the ESP site

and would not affect the ambient ground and atmospheric temperatures beyond the site

boundary.

In Open Item 2.3-4, the staff stated that the applicant has not described the impact of potential

increases in atmospheric temperature resulting from the operation of closed-cycle (dry) cooling

towers associated with proposed Unit 4 on plant design and operation. In its response to Open

Item 2.3-4, the applicant stated that the operation of the dry cooling towers would be expected

to have minimal impact on the design and operation of the new Units 3 and 4. The dry cooling

towers would be approximately 150 ft high and would consist of a series of modules, each

containing air circulating fans. According to the applicant, the warm air plume from the dry

cooling towers would tend to rise vertically, driven by the velocity imparted by the fans and

thermal buoyancy. During most expected atmospheric conditions, the resulting heated plume

would be expected to rise above the top of the tallest powerblock structures in the plant

envelope area. Only a strong wind blowing across the bank of cooling towers could cause

plume downwash because of building wake effects. This strong wind would also enhance the

mixing with cooler air from outside the plume, resulting in negligible changes in temperature at

ground level.

Since the specific design of the ESP facility is not known, the applicant stated that it is not

possible to predict with certainty the impact of the warm air dry cooling tower plumes on specific

2-38
- -

plant features, such as heating,'ventilation, and air-conditioning intakes. The applicant stated

that potential impact of the dry cooling towers on the design and operation on the ESP facility

would be considered as part of detailed engineering.

According to the applicant, the North Anna ESP site region is characterized by gently rolling

terrain that rises to an average height of 50 to 150 ft above Lake Anna. The primary

topographic influences on local meteorological conditions at the North Anna ESP site are Lake

Anna and the North Anna River Valley. Because of the complex configuration of the lake, overwater trajectories would generally be less than 2.5 miles. As a result of the gently rolling

terrain, cold air drains into low-lying areas at night.- Some wind channeling along Lake Anna is

expected during low wind speed conditions. The Blue Ridge Mountains, which are located 40

to 50 miles northwest of the site, also tend to channel the prevailing winds from the south and

south-southwest during the summer months.

The applicant stated that, should additional units be constructed, a portion of the currently

undeveloped area of the ESP site would be cleared of existing vegetation and subsequently

graded to accommodate the new units and the ancillary structures. No large-scale cut and fill

activities would be needed to accommodate the new units since a large portion of the area to

be developed is already relatively level. Therefore, the applicant expects that terrain

modifications associated with development of the ESP facility would be limited to the existing

NAPS site and would not impact terrain features around the lake and valley nor significantly

alter the site's existing 'gently undulating surface that is characteristic of its location in the

Piedmont region of Virginia.

The applicant stated that it did not expect air quality characteristics to be a significant factor in

the design' and operating bases for any new facilities that might be constructed on the ESP site.

The North Anna ESP site is located within the Northeastern Virginia Intrastate Air Quality

Control Region, which has been designated as being in attainment or unclassified for all EPAdesignated national ambient air quality standards. The nuclear steam supply'systern and

related radiological systems associated with any new facilities that might be constructed on the

ESP site would not be sources of criteria pollutants or other air tbxics. Further, the applicant

does not expect the addition 6f supporting auxiliary boilers, 'emergency diesel generators,

station blackout generators, and other sources of nonradiological emissions to be significant

sources of criteria pollutant emissions because these units will operate on an intermittent test.

and/or emergency basis.

2.3.2.2 Regulatory Evaluation

In SSAR Section'1.8.1, the applicant identified the following applicable NRC regulations

regarding local meteorology:

* Appendix A to 10 CFR Part 50, GDC 2,'with respect to information on severe regional

weather phenomena that has historically'been reported for the 'region and that is

reflected in the design bases for SSCs.important to safety ;'

* 10 CFR'100.20(c) and 10 CFR 100.21(d), with respect to the consideration that has

been given to the regional meteorological characteristics of the site.-'

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-~~ .li.

In SSAR Section 1.8.2, the applicant identified the following applicable NRC guidance regarding

local meteorology:

* RG 1.23, Revision 0, "Onsite Meteorological Programs," dated February 1972 and

proposed Revision 1, dated September 1980, with respect to the criteria for an

acceptable onsite meteorological measurements program

* Section 2.3.2 of RG 1.70, with respect to the type of local meteorological information

that should be presented, including the potential impact of the plant on local

meteorology and the local meteorological and air quality conditions used for design and

operating basis considerations

The staff has reviewed this portion of the application in accordance with the guidance identified

by the applicant, and to determine if the application is in compliance with the identified

regulations, with the exception of the GDC. An ESP applicant need not demonstrate

compliance with the GDC with respect to local meteorology.

Section 2.3.2 of RS-002 and Section 2.3.2 of RG 1.70 provide the following guidance on

information appropriate for presentation on local meteorology:

* Local meteorological data based on onsite measurements and data from nearby NWS

stations or other standard installations should be presented in the format specified in

Section 2.3.2 of RG 1.70. RG 1.23 provides guidance related to onsite meteorological

measurements.

* A topographical description of the site and environs should be provided. Section 2.3.2.2

of RG 1.70 provides guidance on the topographical description.

* A discussion and evaluation of the influence of a nuclear power plant or plants of

specified type (or falling within a PPE) that might be constructed on the proposed site

and its facilities on local meteorological and air quality conditions should be provided.

Potential changes in the normal and extreme values resulting from plant construction

and operation should be discussed.

2.3.2.3 Technical Evaluation

The staff evaluated local meteorological conditions using data from the NAPS onsite

meteorological monitoring system, as well as climatic data reported by NCDC. Section 2.3.3 of

this SER provides a discussion of the representativeness of the NAPS onsite data.

Normal climatic data for the period 1971-2000 reported by NCDC for the eastern Piedmont

climatic division of Virginia indicate that the annual mean temperature in the area is about

56.6 OF (NCDC, "Eastern Piedmont, Virginia, Divisional Normals-Temperature, Period

1971-2000, Climatography of the United States No. 85"). This value compares well with the

range of daily mean temperatures reported by the applicant for nearby weather stations.

Monthly mean temperatures for the eastern Piedmont climatic division range from a low

monthly mean value of about 35.9 0F in January to a high monthly mean value of about 76.8 OF

in July (NCDC, "Eastern Piedmont, Virginia, Divisional Normals-Temperature, Period

1971-2000, Climatography of the United States No. 85").

2-40
Precipitation for the Piedmont climatic division averages 45.00 in. per year (NCDC, "Eastern

Piedmont, Virginia, Divisional Normals-Precipitation, Period 1971-2000, Climatography of the

United States No. 85"). This value is compatible with the range of normal annual precipitation

totals reported by the applicant for nearby-weather stations. Precipitation is well distributed

throughout the year, with monthly climate division normals for the North Anna ESP site region

ranging from a minimum of about 3.18 in. in December to a maximum of about 4.36 in. in July.

The staff reviewed the applicant's description of the local meteorology and determined that the

information is representative of conditions at and near the site.; The wind and atmospheric

stability data are based on onsite data recorded by the NAPS meteorological monitoring

system. Section 2.3.3 of this SER provides a discussion of the NAPS onsite data. The other

meteorological summaries are based on data from nearby stations with long periods of record.

The applicant demonstrated that synoptic-scale conditions are generally responsible for periods

of excessive heat and cold outbreaks that resulted in the recording of compatible extreme

temperatures throughout the ESP site area. A review of these recorded extreme values shows

that they are reflected in the site characteristics presented in SSAR Section 2.3.1.

The staff reviewed topographic maps and topographic cross sections to ensure that the

information needed is well labeled and can be readily extracted.

Because of the limited and localized nature of the expected terrain modifications associated

with the development of the ESP facility, the staff finds that these terrain modifications, along

with the resulting plant structures and associated improved surfaces, will not have enough of an

effect on local meteorological conditions to affect plant design and operation. Similarly,

because the operation of an open-cycle cooling system for the applicant's proposed Unit 3 is

not expected to significantly impact either atmospheric temperature extremes or increase the

occurrence of local fog, the staff finds that the atmospheric impact of the operation of an opencycle cooling system for the proposed Unit 3 will not affect plant design and operation.

In Open Item 2.3-4, the staff requested that the applicant describe the impact of potential

increases in atmospheric temperature resulting from the operation of closed-cycle dry cooling

tower and associated with proposed Unit 4 on plant design and operations. In its response to

Open Item 2.3-4, the applicant noted that it is not possible to predict with certainty the warm air

transport and dispersion from the cooling tower to specific plant features because the design of

the plant is not known at this time.

Since the specific layout and design of the ESP facility is not known, the staff finds that it is not.

possible to accurately predict the impact of the Unit 4 dry cooling tower plumes on specific plant

features.- The potential impact of the dry cooling towers on the design and operation of the ESP

facility should be considered as part of detailed engineering and will need further evaluation at

the time of the COL application. This is COL Action Item 2.3-1;

Since the North Anna ESP site is located in an air quality control region that has been

designated as being either in-attainment or unclassifiable for all EPA-designated national

ambient air quality standards, the staff agrees with the applicant that the ESP site air quality

conditions should not be a significant factor in the design and operating bases for the new units.

2-41
* Il.1

2.3.2.4 Conclusions

As set forth above, the applicant has presented and substantiated information on local

meteorological, air quality, and topographic characteristics of importance to the safe design and

operation of a nuclear power plant or plants falling within the applicant's PPE that might be

constructed on the proposed site. The staff has reviewed the available information provided

and, for the reasons given, concludes that the applicant's identification and consideration of the

meteorological, air quality, and topographical characteristics of the site and the surrounding

area meet the requirements of 10 CFR Part 100, 10 CFR 100.20(c), and 10 CFR 100.21 (d) and

are sufficient to determine the acceptability of the site.

The staff has also reviewed available information relative to severe local weather phenomena at

the site and in the surrounding area. As set forth above, the staff concludes that the applicant

has identified the most severe local weather phenomena at the site and surrounding area.

2.3.3 Onsite Meteorological Measurements Program

2.3.3.1 Technical Information in the Application

In Section 2.3.3 of the SSAR, the applicant presented information concerning its Onsite

Meteorological Measurements Program, including instrumentation and measured data.

Specifically, the applicant provided the following information:

* description of meteorological instrumentation, including siting of sensors, sensor

performance specifications, methods and equipment for recording sensor output, the

quality assurance program for sensors and recorders, and data acquisition and

reduction procedures

* meteorological data, including consideration of the period of record and amenability of

the data for use in characterizing atmospheric dispersion conditions

The applicant used the existing Onsite Meteorological Measurements Program for the NAPS

facility to collect data for the North Anna ESP site and intends to use it for the proposed ESP

facility.

The applicant upgraded the existing NAPS monitoring program in June 1977, and, according to

the applicant, it meets the system accuracy criteria presented in proposed Revision 1 to

RG 1.23. Measurements are available from both a primary and backup system. The backup

system is intended to function when the primary system is out of service, providing assurance

that basic meteorological information will be available during and immediately following an

accidental airborne radioactivity release.

The primary NAPS meteorological monitoring program consists of a guyed, triaxial, open-lattice

160-ft tower located approximately 1900 ft east of the NAPS Unit 1 reactor containment

building. Wind speed, wind direction, and horizontal wind direction fluctuation (sigma theta) are

measured at the 33-ft and 1 59-ft elevations. Ambient temperature and dew point temperature

are measured at the 33-ft elevation, and vertical temperature difference (delta-temperature) is

2-42
measured between the 160-ft anid 33-ft elevations. Precipitation is monitored at the ground

level.

The backup NAPS meteorological monitoring program consists of a freestanding 33-ft tower

located approximately 1300 ft northeast of the NAPS Unit 1 reactor containment building. Wind

speed, wind direction, and horizontal wind direction fluctuation (sigma theta) are measured at

the top of the tower. The bases of both towers are at similar elevation to plant grade, and the

ground cover at the base of the primary tower (which measures delta-temperature) is primarily

native grasses;

Signal cables from both the primary and backup towers are routed through conduit into an

instrument shelter at the base of each tower. Inside each shelter, the signals are provided as

input to the appropriate signal-conditioning equipment, with output going to digital data"

recorders. These data are transmitted daily via modem to the applicant's corporate

headquarters, where they are reviewed to identify anomalous data and then archived. Output

from the signal-conditioning equipment is also sent to strip chart recorders in the control room

and the emergency response facility data system for use in emergency response. -

The primary tower wind sensors are mounted on booms approximately twice the tower face

width and are positioned so that the tower will not influence the prevailing south-southwest wind

f low. The ambient temperature, dew point temperature, and delta-temperature sensors are

housed in motor-aspirated shields to insulate them from the effects of precipitation and thermal

radiation.

The meteorological m'onitoring system is calibrated at least semiannually. 'Data recovery for the

1996-1998 period of record used to evaluate atmospheric-dispersion exceeded 90 percent.

2.3.3.2 Regulatory Evaluation

In SSAR Section 1.8.1, the applicant identified the following applicable NRC regulations

regarding the Onsite Meteorological Measurements Program: --

* 10 CFR 50.47, "Emergency Plans," aind Appendix E, "Emergency Planning and

Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, as they relate

to additional meteorological measurements taken for emergency preparedness planning

* Appendix I to 10 CFR Part 50, as it relates to meteorological data used to determine

compliance with the numerical guides for doses in meeting the criterion of "as low as is

reasonably achievable"

* 10 CFR 100.20(c) and 10 CFR 100.21(d), as they relate to meteorological data collected

for use in characterizing the meteorological conditions of the site

In SSAR Sections 1.8.2 and 2.3.3, the applicant identified the following applicable NRC

guidance regarding onsite meteorological me-aurements programs: -

*' RG 1.23, Revision 0, and proposed Revision 1, with respect to the criteria for an

acceptable onsite meteorological measurements program

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* .111:

* Section 2.3.3 of RG 1.70, with respect to describing the meteorological measurements

at the site and providing joint frequency distributions of wind speed and direction by

atmospheric stability class

* Section 2.3 of RG 4.2, "Preparation of Environmental Reports for Nuclear Power

Stations," issued July 1976, with respect to providing at least one annual cycle of onsite

meteorological data

* Appendix 2 to NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of

Radiological Emergency Response Plans and Preparedness in Support of Nuclear

Power Plants," issued November 1980; NUREG-0696, "Functional Criteria for

Emergency Response Facilities," issued February 1981; and NUREG-0737,

"Clarification of TMI Action Plan Requirements," issued October 1980, with respect to

meteorological measurements taken for emergency preparedness planning

The staff has reviewed this portion of the application in accordance with the guidance identified

by the applicant, and to determine if the application is in compliance with the identified

regulations. However, this section of the application did not address the requirements of

10 CFR 50.47 and Appendix E to 10 CFR Part 50. Consequently, the staff did not review this

section for compliance with these requirements.

Both RG 1.23 and Section 2.3.3 of RS-002 document the criteria for an acceptable onsite

meteorological measurements program. The onsite meteorological measurements program

should produce data that describe the meteorological characteristics of the site and its vicinity

for the purpose of making atmospheric dispersion estimates for both postulated accidental and

expected routine airborne releases of effluents, and for comparison with offsite sources to

determine the appropriateness of climatological data used for design considerations.

Section 2.3.3 of RS-002 and Section 2.3.3.7 of RG 1.70 provide guidance on information

appropriate for presentation on an onsite meteorological measurements program. As set forth

in this guidance, at least one annual cycle of onsite meteorological data should be provided.

These data should be presented in the form of joint frequency distributions of wind speed and

wind direction by atmospheric stability class in the format described in RG 1.23. If a site has a

high occurrence of low wind speeds, a finer category breakdown should be used for the lower

speeds so data are not clustered in a few categories. A listing of each hour of the hourly

averaged data should also be provided on electronic media in the format described in

Appendix A to Section 2.3.3 of RS-002. Evidence of how well these data represent long-term

conditions at the site should be discussed.

2.3.3.3 Technical Evaluation

The staff evaluated the Onsite Meteorological Measurements Program by reviewing the

program description presented in the SSAR, as well as conducting a site visit. The site visit

consisted of reviewing the meteorological monitoring system location and exposure, sensor

type and performance specifications, data transmission and recording, data acquisition and

reduction, and instrumentation maintenance and calibration procedures. In addition, the staff

reviewed an hourly listing of the 1996-1998 meteorological database provided by the applicant

in its response to RAI 2.3.3-1.

2-44
The staff considers the meteorological data collected by the existing NAPS monitoring program

to be representative of the dispersion conditions at the North Anna ESP site. The North Anna

ESP site is within the existing NAPS site, and the proposed facility is intended to be in close

proximity to the existing facility. The NAPS primary meteorological tower is located far enough

away from existing plant structures to preclude any adverse impact on measurements. The

base of the tower is at an elevation similar to plant grade at both NAPS and the proposed ESP

facility. The ground cover at the base of the meteorological tower'is primarily native grasses.

The staff reviewed the location of the primary and backup towers with respect to nearby ground

features and potential obstructions to flow (e.g., trees, buildings), including existing plant

structure'layouts, and concluded that thesefeatures pose minimal adverse effects on the

measurements taken at the towers. The nearby instrument shelters for both towers'are less

than 10 ft in height. Pine trees, previously 30-35 ft in height and located approximately 135 ft

northwest and south of the primary tower, were cut'in 2002 to 23-27 ft in height: Dominion

Energy has put these trees on a 3-year pruning schedule to ensure they remain below 30 ft in

height (i.e., below the lower measuring height on the Odrimary tower), as recommended in

proposed Revision 1 to RG 1.23.

The staff evaluated the types and heights of the meteorological variables being measured and

found them to be compatible with the'criteria of RG'1.23. During the site visit, the staff also

reviewed the applicant's sensor types and performance specifications, data transmission and

recording methods, and the inspection, maintenance, and calibration procedures and

frequencies. The staff found them to be 'cosistent with RG 1.23.

The staff performed a quality review of the NAPS 1996-1998 hourly meteorological database'

provided by the applicant in' response to RAI 2.3.3-1 using the methodology described in

NUREG-0917, "Nuclear Regulatory Commission Staff Computer Programi for Use with -

Meteorological Data," issued July 1982. The staff performed further review using computer

spreadsheets. Examination of the data revealed generally stable and neutral atmospheric

conditions at night and unstable and neutral conditions during the day; as expected. Wind

speed, wind direction, and stability class frequency distributions for each measurement channel

were similar from year to year, and the 1996-1998 wind direction and stability class frequency

distributions were reasonably consistent with the 1974-1987 data-'presented in Section 2.3.2 of

the NAPS UFSAR. A comparison between the joint frequency distribution used b-y the licensee

as input to PAVAN and XOQDOQ and a staff-generated joint frequency distribution from -

the hourly database are'compatible. " - .

2.3.3.4 Conclusions

As set forth'above, the applicant has provided and substantiated information on the Onsite

Meteorological Measurements Program. The staff has reviewed the available information

relative to the meteorological measurements program and the data collected by the program.

On the basis of this review and aasset fortih abbve, the'staff 'concludes that'the system provides

data adequate to represent onsite meteorological conditions,' as required by 10 CFR 100.20.

The onsite data also provide an acceptable basis for (1) making estimates of atmospheric

dispersion for design-basis accident and routine releases from a nuclear power plant or plants

falling within' the applicant's PPE that might be constructed on the proposed site and.,

(2) meeting the requirements of 10 CFR Part 100 and Appendix I to 10 CFR Part 50.

2-45
- II:

2.3.4 Short-Term (Accident) Diffusion Estimates

2.3.4.1 Technical Information in the Application

In this section of the SSAR, the applicant presented atmospheric dispersion estimates for

postulated accidental airborne releases of radioactive effluents to the EAB and LPZ. The

applicant provided the following information:

* atmospheric transport and diffusion models to calculate relative concentrations for

postulated accidental radioactive releases

* meteorological data summaries used as input to diffusion models

* specification of diffusion parameters

* probability distributions of relative concentrations

* determination of relative concentrations used for assessment of consequences of

postulated radioactive atmospheric releases from design-basis and other accidents

The applicant used the NRC-sponsored computer code PAVAN (NUREG/CR-2858, "PAVAN:

An Atmospheric Dispersion Program for Evaluating Design Basis Accidental Releases of

Radioactive Materials from Nuclear Power Stations," issued in 1982) to estimate relative

concentration (X/Q) values at the EAB and LPZ for potential accidental releases of radioactive

material. The PAVAN model implements the methodology outlined in RG 1.145, Revision 1,

"Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear

Power Plants," issued November 1982.

The PAVAN code estimates X/Q values for various time-averaging periods ranging from 2 hours

to 30 days. The meteorological input to PAVAN consists of a joint frequency distribution of

wind speed, wind direction, and atmospheric stability data. The PAVAN code computes X/Q

values at the EAB and LPZ for each combination of wind speed and atmospheric stability for

each of the 16 downwind direction sectors. The code then ranks X/Q values for each sector in

descending order, and it derives an associated cumulative frequency distribution based on the

frequency distribution of wind speed and stabilities for that sector. The X/Q value that is

equaled or exceeded 0.5 percent of the total time is determined for each sector, and the highest

0.5-percentile X/Q value among the 16 sectors becomes the maximum sector-dependent X/Q

value. The code also ranks X/Q values independent of wind direction into a cumulative

frequency distribution for the entire site. The PAVAN program then selects the X/Q value that is

equaled or exceeded 5 percent of the total time. The larger of the two values, the maximum

sector-dependent 0.5-percent X/Q value and the overall site 5-percent X/Q value, are used to

represent the X/Q value for a 0-2-hour time period.

To determine X/Q values for longer time periods, PAVAN calculates an annual average X/Q

value. Logarithmic interpolation is then used between the 0-2-hour X/Q values and the annual

2-46
average X/Q values to calculate the values for intermediate time periods (i.e., 8 hours, 16 hours,

72 hours, and 624 hours).

In RAI 2.3.4-1, the staff asked the applicant to rerun the PAVAN computer code using the wind

speed categories discussed in Section 4.6 of NUREG/CR-2858 ahd provide a copy of the

resulting input files used to execute PAVAN. The applicant'complied with this request in its

response to RAI 2.3.4-1.

The applicant used the following input data and assumptions in applying the PAVAN model for,

the North Anna site:

* The meteorological input to PAVAN consisted of a joint frequency distribution of wind

speed, wind direction, and atmospheric stability data based on 3 years (1 996-i 998) of

onsite meteorological data. The applicant used wind data from the 33-ft level of the

' onsite meteorological tower, and it derived the stability data from the vertical - - -

temperature difference (delta-temperature) measurements taken between the 159-ft and

* 33-ft levels of the onsite meteorological tower.

The applicant modeled one conservative ground-level release point and took no credit

for building wake effects.

* The EAB is the perimeter of a 5000-ft radius circle from the center 6f the abandoned

Unit 3 containment. In order to calculate the X/Q values for the EAB, the applicant used

the shortest distances from the ESP plant envelope area boundary to the EAB. The

- LPZ is a 6-mi-radius circle centered at the Unit 1 containment building. Similarly, in

order to calculate the X/Q values for the LPZ, the applicant used the shortest distances

from the ESP plant envelope area boundary to the LPZ.

Based on the PAVAN modeling results, the applicant proposed short-term (accident release)

atmospheric dispersion site characteristics for inclusion in an ESP, as presented in

Table 2.3.4-1, should one be issued for the applicant's proposed ESP site.

2-47
-- .11.

Table 2.3.4-1 Applicant's Proposed Short-Term (Accident Release) Atmospheric

Dispersion Site Characteristics

SITE CHARACTERISTIC VALUE DEFINITION

0-2 hr X/Q Value © EAB 2.26x10-4 s/M3 The atmospheric dispersion factor used in the safety

analysis to estimate dose consequences of accidental

airborne releases

0-8 hr X/Q Value © LPZ 2.05x10-5 s/M3 The atmospheric dispersion factor used in the safety

analysis to estimate dose consequences of accidental

airborne releases

8-24 hr X/Q Value © LPZ 1 .36x1 0-5 s/M3 The atmospheric dispersion factor used in the safety analysis to estimate dose consequences of accidental

airborne releases

1-4 day X/Q Value @ LPZ 5.58x1 0-6 s/M3 The atmospheric dispersion factor used in the safety

analysis to estimate dose consequences of accidental

airborne releases

4-30 day X/O Value © LPZ 1 .55x1 0-6 s/M3 The atmospheric dispersion factor used in the safety analysis to estimate dose consequences of accidental

airborne releases

2.3.4.2 Regulatory Evaluation

In SSAR Section 1.8.1, the applicant identified the applicable NRC regulation regarding shortterm (accident release) diffusion estimates as 10 CFR 100.21, with respect to the

meteorological considerations used in the evaluation to determine an acceptable exclusion area

and LPZ.

In SSAR Sections 1.8.2 and 2.3.4, the applicant identified the following applicable NRC

guidance regarding accident release diffusion estimates:

RG 1.5, "Assumptions Used for Evaluating the Potential Radiological Consequences of

a Steam Line Break Accident for Boiling Water Reactors," issued March 1971; RG 1.24,

"Assumptions Used for Evaluating the Potential Radiological Consequences of a

Pressurized Water Reactor Radioactive Gas Storage Tank Failure," issued March 1972;

RG 1.25, "Assumptions Used for Evaluating the Potential Radiological Consequences of

a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and

Pressurized Water Reactors," issued March 1972; RG 1.77, "Assumptions Used for

Evaluating a Control Rod Ejection Accident for Pressurized Water Reactors," issued

May 1974; and RG 1.78, Revision 1, with respect to an acceptable basis for

implementing the requirements of 10 CFR Part 100

RG 1.23, Revision 0, and proposed Revision 1, with respect to the criteria for an

acceptable onsite meteorological measurements program

2-48
* Section 2.3.4 of RG 1.70, with respect to providing conservative and realistic estimates

of atmospheric diffusion at the EAB and LPZ, based on the most representative

meteorological data and impacts caused by local topography

* RG 1.1 11, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous

Effluents in Routine Releases from Light-Water-Cooled Reactors," issued July 1977,

with'respect to criteria for characterizing atmospheric transport and diffusion conditions

for evaluating the consequences of routine releases

* RG 1.145, Revision 1, with -respect to acceptable methods for choosing atmospheric

dispersion factors (X/Q values) for evaluating the consequences of potential accidents

* RG 4.7, with respect to discussing the major site characteristics related to public health

and safety that the staff considers in determining the suitability of the site

The staff has reviewed this portion of the application in accordance with the guidance identified

by the applicant, and to determine if the application' is in compliance with the identified

regulations.

Section 2.3.4 of RS-002 and Section 2.3.4 of RG 1.70 provide'guidance on information

appropriate for presentation on short-term (accident release) diffusion estimates. The

application should present or describe the following:

* -.conservative estimates of atmospheric transport and diffusion conditions at appropriate

'distances from the source for postulated accidental releases of radioactive materials to

' the atmosphere

* a description of the atmospheric dispersion models used to calculate relative

concentrations (X/Q values) in air resulting from accidental releases of radioactive

' material to the atmosphere, with models documented in detail and substantiated within

the limits of the model so that the staff can evaluate their appropriateness to site

characteristics, plant characteristics (to the extent known), and release characteristics

* the meteorological data used for the evaluation (as input to the dispersion models),

which represent annual cycles of hourly values of wind direction, wind speed, and

atmospheric stability for each mode of accidental release

* an explanation of the variation of atmospheric diffusion parameters used to characterize

lateral and vertical plume spread (ay and o,) as a function of distance, topography, and

atmospheric conditions, as related to measured meteorological parameters, and

description of a methodology for establishing these relationships that is appropriate for

estimating the consequences of accidents within the range of distances that are of

interest with respect to site characteristics and established regulatory criteria

* cumulative probability distributions of relative concentrations (X/Q values) and the

probabilities of these X/Q values being exceeded, presented for appropriate distances

(e.g., the EAB and LPZ) and time periods as specified in Section 2.3.4.2 of RG 1.70, as

well as an adequate description of the methods used for generating these distributions

2-49
___ U:

the relative concentrations used for assessing the consequences of atmospheric

radioactive releases from design-basis and other accidents

2.3.4.3 Technical Evaluation

The applicant generated its atmospheric diffusion estimates for postulated accidental airborne

releases of radioactive effluents to the EAB and LPZ using the staff-endorsed computer code

PAVAN. The staff evaluated the applicability of the PAVAN model and concluded that no

unique topographic features preclude the use of the PAVAN model for the North Anna ESP

site. The staff also reviewed the applicant's input to the PAVAN computer code, including the

assumptions used concerning plant configuration and release characteristics and the

appropriateness of the meteorological data input. The staff found that the applicant made

conservative assumptions by ignoring building wake effects and treating all releases as groundlevel releases. The staff made an independent evaluation of the resulting atmospheric diffusion

estimates by running the PAVAN computer model and obtained similar results.

From this review, the staff concludes that the applicant has used an adequately conservative

atmospheric dispersion model and appropriate meteorological data to calculate relative

concentrations for appropriate offsite (EAB and LPZ) distances and directions from postulated

release points for accidental airborne releases of radioactive materials.

In order to evaluate atmospheric dispersion characteristics with respect to radiological releases

to the control room, detailed design information (e.g., vent heights, intake heights, and distance

and direction from release vents to the room) is necessary. Because little detailed design

information is available for the nuclear power plant or plants that might be constructed on the

proposed site, the COL or CP applicant should assess the dispersion of airborne radioactive

materials to the control room at the COL or CP stage. This is COL Action Item 2.3-2.

The staff intends to include the short-term (accident release) atmospheric dispersion factors

listed in Table 2.3.4-2 as site characteristics in any ESP that might be issued for the North Anna

ESP site.

2-50
Table 2.3.4-2 Staff's Proposed Short-Term (Accident Release) Atmospheric Dispersion

Site Characteristics

SITE CHARACTERISTIC - VALUE DEFINITION

0-2-hr X/Q Value @ EAB 2.26x1 0-4 s/m3 The G-2-hour atmospheric dispersion factor to be used

to estimate dose consequences of accidental airborne

releases at the EAB

0-8-hr X/Q Value @ LPZ 2.05x1 0-5 s/m3 The 0-8-hour atmospheric dispersion factor to be used

to estimate dose consequences of accidental airborne

releases at the LPZ

8-24-hr x1Q Value @ LPZ 1 .36xA 05 s/m3 the 8-24-hour atmospheric dispersion factor to be

used to estimate dose consequences of accidental

airborne releases at the LPZ

1-4-day X/a Value @ LPZ 5.58x10-6 s/m3 The' 1-4-day atmospheric dispersion factor to be used

to estimate dose consequences of accidental airborne

releases at the LPZ

4-30-day X/Q Value @ LPZ 1 .55x1 0-6 s/m3 The 4-30-day atmospheric dispersion factor to be

used to estimate dose consequences of accidental

airborne releases at the LPZ .

2.3.4.4 Conclusions

As set forth above, the applicant has made conservative assessments of postaccident

atmospheric dispersion conditions using its meteorological data and appropriate diffusion

models. The applicant has calculated representative atmospheric transport and diffusion

conditions for the EAB and the LPZ. The staff has reviewed the applicant's proposed shortterm atmospheric dispersion site characteristics for inclusion in an ESP for the applicant's site,

should one be issued, and, as discussed above, finds these characteristics to be acceptable.

Therefore, the staff concludes that the applicant's atmospheric dispersion estimates are

appropriate for the assessment of consequences from radioactive releases for postulated (i.e.,

design-basis) accidents, in accordance with 10 CFR 100.21.

Based on these considerations, the staff concludes that the applicant's short-term atmospheric

-dispersion estimates are acceptable and meet the relevant requirements of 10 CFR Part 100.

The staff will address atmospheric dispersion estimates used to evaluate radiological doses for

the control room in its review of any COL or CP application that references this information.

2.3.5 Long-Term (Routine) Diffusion Estimates

2.3.5.1 Technical Information in the Application -

In this section of the SSAR, the applicant presented its atmospheric diffusion estimates for

routine releases of effluents to the atmosphere. Specifically, the applicant provided the

following information:

2-51
_.11J

* the atmospheric dispersion models used to calculate concentrations in air and the

amount of material deposited as a result of routine releases of radioactive material to

the atmosphere

* the meteorological data used as input to diffusion models

* diffusion parameters

* relative concentration (X/Q) and relative deposition (D/Q) values used to assess the

consequences of routine airborne radioactive releases

* points of routine release of radioactive material to the atmosphere, the characteristics of

each release mode, and the location of potential receptors for dose computations

The applicant used the NRC-sponsored computer code XOQDOQ (NUREG/CR-2919,

"XOQDOQ: Computer Program for the Meteorological Evaluation of Routine Effluent Releases

at Nuclear Power Stations," issued in 1982) to estimate X/Q and D/Q values resulting from

routine releases. The XOQDOQ model implements the methodology outlined in RG 1.111.

The applicant used the following input data and assumptions in applying the XOQDOQ model

for the North Anna ESP site:

* The meteorological input to XOQDOQ consisted of a joint frequency distribution of wind

speed, wind direction, and atmospheric stability data based on 3 years (1996-1998) of

onsite meteorological data. The wind data were from the 33-ft level of the onsite

meteorological tower, and the stability data were derived from the vertical temperature

difference (delta-temperature) measurements taken between the 159-ft and 33-ft levels

of the onsite meteorological tower.

* The applicant modeled one conservative ground-level release point, assuming a

minimum building cross-sectional area of 24,220 square ft.

* Because the PPE area proposed for the North Anna ESP site is an area, not a point, the

applicant used the shortest distances from any point on the plant envelope to the

receptors of interest as input to the XOQDOQ model.

The applicant calculated annual average undepleted/no decay, undepleted/2.26-day decay, and

depleted/8.00-day decay X/Q values and D/Q values for the site boundary and special receptors

of interest (nearest resident, meat animal, and vegetable garden within 5 miles in each

downwind sector), as identified in the North Anna Power Station 2001 Radiological

Environmental Monitoring Program Annual Report.

Table 2.3.5-1 lists the long-term atmospheric dispersion estimates that the applicant derived

based on the XOQDOQ modeling results.

2-52
Table 2.3.5-1 Applicant's Long-Term (Routine Release) Diffusion Estimates

X/Q VALUE (s/m3 )

TYPE OF' UNDEPLETED UNDEPLETED DEPLETED: D/0 VALUE

LOCATION NO DECAY 2.26-DAY DECAY 8.00-DAY DECAY (urn2)

EAB 3.7x10 6 3.7x106 3.3x10 6 1.2x108

(0.88 mi ESE) (0.88 ml ESE) (0.88 mi ESE) (0.62 mi S)

Residence 2.4x1 0-6 2.4x1 0-6 2.1x1 0-6 7.2x10-9

(0.96 mi NNE) (0.96 mi NNE) (0.96 mi NNE) (0.96 mi NNE)

Meat Animal 1.4x1 6 1.4xl0 6 1.2x10-6 3.1x10-9

* (1.37 mi SE) (1.37 mi SE) (1.37 mi SE) (1.56 mi NNE)

Vegetable Garden 2.0x10-6 ' 2.x10-6 1.8x10-6 6.0x10-9

(0.94 ml NE) (0.94 mi NE) (0.94 mi NE) (0.94 ml NE)

2.3.5.2 Regulatory Evaluation

In SSAR Section 1.8.1, the applicant identified the applicable NRC regulations regarding longterm (routine release) diffusion' estimates' as Appendix I to 10 CFR Part 50, with respect to

demonstrating compliance with the numerical guides for doses contained in this appendix by

characterizing atmospheric transport and diffusion conditions in order to estimate the

radiological consequences of routine releases of materials to the atmosphere.

The staff finds that the applicant should have also identified 10 CFR 100.21 (c)(1), which

requires that site atmospheric dispersion characteristics be evaluated and dispersion

parameters established such that radiological effluent release limits associated with normal

operation from the type of facility proposed to be located at the site can be met for any

individual located offsite. Nonetheless, for'the reasons set forth below, the staff finds that the

applicant has met these regulatory requirements.

In SSAR Sections 1.8.2 and 2.3.5, the applicant identified the following applicable NRC

guidance regarding routine release diffusion-estimates:

* 'Section 2.3.5 of RG 1.70, with respect to providing realistic estimates of annual average

atmospheric transport and diffusion characteristics to a'distance of 50 miles from the

plant, including a detailed description of the model used and a calculation of the

maximum annual average atmospheric dispersion factor (X/Q value) at or beyond the

site boundary for each venting location -

* RG 1.1 11, with respect to criteria for characterizing atmospheric transport and diffusion

conditions for evaluating'the consequences of routine releases -

The staff also identified the followuing RGs-as applicable NRC guidance regarding routine

release diffusion estimates: ' ' -

* RG 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor

Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,"

2-53
_ 1.

issued October 1977, with respect to the criteria to be used for specific receptors of

interest (applicable to the extent the applicant provides receptors of interest at the ESP

stage)

RG 1.112, "Calculation of Releases of Radioactive Materials in Gaseous and Liquid

Effluents from Light-Water-Cooled Power Reactors," issued May 1977, with respect to

the criteria to be used to identify release points and release characteristics (applicable to

the extent the applicant provides release points and release characteristics at the ESP

stage)

As discussed below, the staff finds that the applicant has met the criteria in all applicable RGs

for performing routine release diffusion estimates.

Section 2.3.5 of RS-002 and Section 2.3.5 of RG 1.70 provide the following guidance on

information appropriate for presentation on long-term (routine release) diffusion estimates.

* The applicant should provide a description of the atmospheric dispersion models used to

calculate concentrations in air and the amount of material deposited as a result of

routine releases of radioactive material to the atmosphere. The models should be

sufficiently documented and substantiated to allow a review of their appropriateness for

site characteristics, plant characteristics (to the extent known), and release

characteristics.

* The applicant should discuss the relationship between atmospheric diffusion

parameters, such as vertical plume spread (a,), and measured meteorological

parameters. The applicant should substantiate the use of these parameters in terms of

the appropriateness of their use in estimating the consequences of routine releases

from the site boundary to a radius of 50 miles from the plant site.

* The applicant should provide the meteorological data used as input to the dispersion

models. Data used for this evaluation should represent hourly average values of wind

speed, wind direction, and atmospheric stability, which are appropriate for each mode of

release. The data should reflect atmospheric transport and diffusion conditions in the

vicinity of the site throughout the course of a year.

* The applicant should provide the relative concentration (X/Q) and relative deposition

(D/Q) values used for assessing the consequences of routine radioactive gas releases,

as described in Section 2.3.5.2 of RG 1.70.

* The applicant should identify points of routine release of radioactive material to the

atmosphere, the characteristics of each release mode, and the location of potential

receptors for dose computations (if available at the ESP stage). Bounding values for

these parameters may be provided at the ESP stage. In such a case, the applicant will

need to confirm, at the COL or CP stage, that the parameters provided at the ESP stage

bound the actual values provided at the COL or CP stage, and that the calculational

methodology used for the confirmation is consistent with that employed at the ESP

stage.

2-54
2.3.5.3 Technical Evaluation

The applicant generated its atmospheric diffusion estimates for routine airborne releases of

radioactive effluents to the site boundary and special receptors of interest using the staffendorsed computer code XOQDOQ. The staff evaluated the applicability of the XOQDOQ

model and concluded that no unique topographic features preclude the use of the XOQDOQ

model for the North Anna ESP site. The staff also reviewed the applicant's input to the

XOQDOQ computer code, including the assumptions it used concerning plant configuration and

release characteristics and the appropriateness of the meteorological data input. The staff

found that the applicant made conservative assumptions by treating all releases as ground-level

releases. The staff made an independent evaluation of the resulting atmospheric diffusion

estimates by running the XOQDOQ computer model and obtaining similar results.

From this review, the staff concludes that the applicant used an appropriate atmospheric

dispersion model and adequate meteorological data to calculate relative concentration and

relative deposition at appropriate distances from'postulated release points for the evaluation of

routine airborne releases of radioactive' material.' Any COL or CP applicant referencing this

information should verify that the specific release point characteristics (e.g., release height and

building wake dimensions) and specific locations of receptors of interest (e.g., nearest resident

or garden) used to generate the ESP long-term (routine release) atmospheric dispersion site

characteristics bound the actual values provided at the COL or CP stage. This is COL Action

Item 2.3-3.

The staff intends to include the long-term' (routine release) atmospheric dispersion factors listed

in Table 2.3.5-2 as site characteristics in any ESP that the NRC might issue for the North Anna

ESP site.

2-55
-- U.1.

Table 2.3.5-2 Staff's Proposed Long-Term (Routine Release) Atmospheric Dispersion

Site Characteristics

SITE CHARACTERISTIC VALUE DEFINITION

Annual Average 3.7x10-6 s/M3 The maximum annual average EAB undepleted/no

Undepleted/No Decay decay X/Q value for use in determining gaseous

X/Q Value @ EAB pathway doses to the maximally exposed individual

Annual Average 3.7x10-6 s/M3 The maximum annual average EAB undepleted/2.26-

Undepleted/2.26-Day Decay day decay X/Q value for use in determining gaseous

X/Q Value @ EAB pathway doses to the maximally exposed individual

Annual Average 3.3x10-6 s/M3 The maximum annual average EAB depleted/8.00-day

Depleted/8.00-Day Decay decay X/Q value for use in determining gaseous

X/Q Value @ EAB pathway doses to the maximally exposed individual

Annual Average 1.2x10 8 1/M2 The maximum annual average EAB D/0 value for use

D/0 Value @ EAB in determining gaseous pathway doses to the

maximally exposed individual

Annual Average 2.4x10-6 s/M3 The maximum annual average resident undepleted/no

Undepleted/No Decay decay X/Q value for use in determining gaseous

X/Q Value © Nearest pathway doses to the maximally exposed individual

Resident *

Annual Average 2.4x10-6 s/M3 The maximum annual average resident

Undepleted/2.26-Day Decay undepleted/2.26-day decay x/Q value for use in

X/Q Value © Nearest determining gaseous pathway doses to the maximally

Resident exposed individual

Annual Average 2.1x10-6 s/M3 The maximum annual average resident

Depleted/8.00-Day Decay depleted/8.00-day decay X/Q value for use in

X/Q Value © Nearest determining gaseous pathway doses to the maximally

Resident exposed individual

Annual Average 7.2x10-9 1/M 2 The maximum annual average resident D/Q value for

D/0 Value © Nearest use in determining gaseous pathway doses to the

Resident maximally exposed individual

Annual Average 1.4x10-6 s/M3 The maximum annual average meat animal

Undepleted/No Decay undepleted/no decay X/Q value for use in determining

X/Q Value @ Nearest Meat gaseous pathway doses to the maximally exposed

Animal individual

Annual Average 1.4x10 6 s/m3 The maximum annual average meat animal

Undepleted/2.26-Day Decay undepleted/2.26-day decay X/Q value for use in

x/Q Value @ Nearest determining gaseous pathway doses to the maximally

Meat Animal exposed individual

Annual Average 1.2x10-6 s/m3 The maximum annual average meat animal

Depleted/8.00-Day Decay depleted/8.00-day decay x/Q value for use in

x/Q Value @ Nearest determining gaseous pathway doses to the maximally

Meat Animal exposed individual

2-56
f-r. ,

at . :1 ,

SITE CHARACTERISTIC VALUE DEFINITION

'Annual Average 3.lxl o 1/r9 2 The maximum annual average meat animal D/Q value

:0D/0 Value a Nearest - for use in determining gaseous pathway doses to the

Meat Animal maximally exposed individual

Annual Average 2.Oxl o- 6 s/rm3 The maximumrmannual average vegetable garden

Undepleted/No Decay undepleted/no decay x1Q value for use in determining

X/Q Value @'Nearest gaseous pathway doses to the maximally exposed Vegetable Garden individual .

Annual Average 2.0x10-6 s/M3 The maximum annual average vegetable garden

Undepleted/2.26-Day Decay .' undepleted/2.26-day decay X/Q value for use in -

X/Q Value @ Nearest -determining gaseous pathway doses to the maximally Vegetable Garden - exposed individual

'Annual Average -- 1 Lxi -6 s/r 3 The maximum annual average vegetable garden Depleted/8.00-Day Decay depleted/8.00-day decay X/Q value for'use in

X/Q Value @ Nearest determining gaseous pathway doses to the maximally Vegetable Garden exposed individual

Annual Average 6.0x10-9 1/r2 The maximum annual average yegetable garden D/Q

D/Q Value @ Nearest value for use in determining gaseous pathway doses

Vegetable Garden to the maximally exposed individual

2.3.5.4 Conclusions

As set forth above, the applicant has provided meteorological data and an atmospheric

dispersion model that are appropriate for the characteristics of the site and release points. The

applicant has calculated representative atmospheric transport and diffusion conditions for

16 radial sectors from the site boundary to a distance of 50 miles, as well as for specific

receptor locations: The staff has reviewed the long-term atmospheric dispersion estimates that

the applicant proposed for inclusion as site characteristics in an ESP for its site (should one be

issued) and, for the reasons set forth above, finds these estimates tobe acceptable.

Therefore, the staff concludes that the applicant has provided the information needed to

address the requirements of 10 CFR 100.21 (c)(1).

Based on these considerations, the staff concludes that the applicant's characterization of longterm atmospheric transport and diffusion conditions is appropriate for use in demonstrating

compliance with the numerical guides for doses contained in Appendix I to 10.CFR Part 50.'.'

The applicant provided bounding values for points of routine release of radioactive material to

the atmosphere, the characteristics of each release mode, and the location of potential

receptors for dosecomputations. Any.COL or CP applicant must confirm that the parameters

provided atthe ESP stage bound-the'actual values provided at the COL or CP stage, and that

the calculational methodology used for the confirmation is consistent with that employed at the

ESP stage.

2-57
I

2.4 Hydrology

To ensure that a nuclear power plant or plants could be designed, constructed, and operated on

the applicant's proposed ESP site in compliance with the Commission's regulations, the NRC

staff evaluates hydrology information that may affect the design and siting of such a plant. The

staff has prepared Sections 2.4.1 through 2.4.14 of this SER in accordance with the review

procedures described in RS-002, using information presented in SSAR Section 2.4, the

applicant's responses to RAls, and generally available reference materials, as described in the

applicable sections of RS-002.

The proposed site is adjacent to the currently operating NAPS Units 1 and 2. The water source

for the proposed units on the ESP site is the impoundment of the North Anna River, referred to

as Lake Anna. Lake Anna currently serves as the principal water source for the two existing

units, both of which use once-through cooling systems to dissipate heat from the turbine

condenser. The proposed units would also use Lake Anna as the source of cooling water

during normal operation. The applicant stated that the proposed Unit 3 would use a oncethrough cooling system, and the proposed Unit 4 would use a dry cooling tower system for heat

rejection during normal operation. Therefore, the water supply needs for Unit 4 would be

minimal compared to those of the two existing units and the proposed Unit 3. Neither of the

proposed units would rely directly on the lake for safety-related cooling needs. If the selected

plant design includes a UHS for each of the proposed units, it would consist of mechanical draft

towers over a buried engineered water storage basin.

2.4.1 Hydrologic Description

2.4.1.1 Technical Information in the Application

SSAR Section 2.4.1 states that the ESP site is located near Lake Anna, which was created by a

dam constructed across the North Anna River as part of the overall development of the NAPS

site. The North Anna Dam is located about 4 miles north of Bumpass, Virginia, and about

5 miles downstream from the ESP site. Lake Anna is about 17 miles long, with an irregular

shoreline approximately 272 miles in length.

A series of dikes and canals separates Lake Anna into two segments. The larger segment,

approximately 9600 ac in area, is named the North Anna Reservoir and serves as the storage

impoundment. The smaller segment, approximately 3400 ac in area, is the WHTF and

functions to dissipate heat to the atmosphere from cooling water that has been discharged from

the existing units.

The applicant stated that the North Anna Dam is the only significant water control structure on

the North Anna River. The dam is an earth-filled structure, approximately 5000 ft long and 30 ft

wide at the crest at an elevation of 265 ft mean sea level (MSL).1 The dam has a 200-ft-long

'Mean Sea Level (MSL): A datum, or "plane of zero elevation," established by

averaging all stages of oceanic tides over a 19-year tidal cycle or "epoch." This plane is

corrected for the curvature of the earth and is the standard reference for elevations on the

earth's surface. Another term for MSL is the National Geodetic Vertical Datum.

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es f - .1 - -1 r ,

concrete spillway founded on bedrock. The spillway has three radial crest gates, each of which

is 40 ft wide and 35 ft high. Two skimmer gates, each 8.5 ft by 8.5 ft, allow regulation of small

discharges.

SSAR Section 2.4.1 states that.the proposed ESP site will house two new reactor units.

However, the applicant did not clearly demarcate the proposed locations of the units through

survey coordinates, making it difficult to determine the feasibility of constructing intake tunnels

and related structures. In RAI 2.4.1-1, the staff requested additional information on these

survey coordinates, locations of any existing aquifers in the ESP site area, layout of intake

tunnels and pipes from Lake Anna to the proposed new units, total service water'flow rate for

the two existing units, and the combined service water flow rate when all four units (two existing

and two new) would be operating. In response to RAI 2.4.1-1, the applicant provided a figure

that lists coordinates of the ESP plant perimeter corners. Regarding aquifers, the applicant

stated that the subsurface beneath the ESP site consists of a single aquifer that belongs to the'.

Piedmont Physiographic Province aquifer system. Other aquifers nearest'the ESP site belong

to the Coastal Plain Physiographic Province, but occur about 15 miles, away. The applicant

stated that, because the entire subsurface beneath the ESP site belongs to a single aquifer

system, a drawing of the aquifer system is not required.

The applicant also stated in this RAI response that intake tunnels for Unit 3 will be routed from

the ESP intake area about 200 ft south to the ESP footprint, and the discharge tunnel for Unit 3

will be routed from the ESP footprint about 1900 ft east to the ESP discharge. The applicant

stated that adequate space is available for these tunnels to ensure that they would not interfere

with the'underground piping and structures of th& existing units.

The applicant also stated that the service water reservoir supplies servi6e' water for NAPS i

Units 1 and 2. The service water system for Units 1 and 2 is a'single, two-loop system. Four

pumps with a capacity of 11,500 gallons per minute (gpm), two for each unit, service these two

loops. Two of these pumps operate during normal operation, three during a unit shutdown, and

all four during an accident condition. Two more' identical pumps are'l6cated in the intake

structure as backup to the normal service water supply. The applicant stated that the service

water flowpath for any additional units on the ESP site is not defined, but that service water

flows can be estimated to be approximately 5 percent of total circulating water flow.

The applicant stated that the non-safety-related cooling water need for all four units,-including

the proposed additional units, is 121 cubic feed 'per second (cfs), which includes both natural

and forced evaporation from the lake. The applicant estimated a margin of 209 cfs in the water

budget, assuming that the average net inflow of 370 cfs is available, with a minimum release of

40 cfs from Lake Anna.

The applicant revised the SSAR to be consistent with the above RAI responses:

SSAR Section 2.4.1.1 originally stated that, during critical low-flow periods, makeup water forcooling would be obtained from Lake Anna and supplemented by an external source that the

COL applicant would identify. In'RAI 2.4.1-2, the staff requested that the applicant identify the - quantity of supplemental water. In resp6nse'to RAI 2.4.1-2, the applicant stated that, because

of uncertainty concerning the adequacy of makeup water for the proposed Unit 4, it changedthe cooling system from wet cooling towers to dry cooling towers. The applicant informed the

NRC of a revised approach to cooling the proposed Unit 4 in a letter dated March 31, 2004.

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The applicant stated that dry cooling towers have no evaporative water losses, require no

makeup water, and have no blowdown discharges. However, if the dry cooling tower system

contains a secondary cooling water loop with a free water surface pump sump, a small amount

of evaporation loss, on the order of 1 gpm, would occur. The applicant stated that, with this

change in the cooling system, the consumptive cooling water use for the proposed Unit 4 would

decrease from 35 cfs to 0.002 cfs or less during normal plant operation. The applicant revised

the SSAR to be consistent with these RAI responses.

Figure 2.4-10 in the SSAR shows the combined stage-storage relationship for Lake Anna and

the WHTF. In RAI 2.4.1-3, the staff requested that the applicant provide the data for and a

description of the method used to construct this stage-storage relationship. The staff indicated

that the stage-storage relationship should extend at least down to stage elevation 219 ft MSL.

In response to RAI 2.4.1-3, the applicant stated that it derived the stage-storage curve for Lake

Anna from topographic contour maps. The applicant constructed contour maps from aerial

photogrammetry of the proposed lake area before the North Anna Dam was built. It measured

surface areas enclosed by the contours using a planimeter, and it determined incremental

storage volume between two contours, assuming a truncated square pyramid shape between

these contours. The applicant checked the stage-storage curve for accuracy on photo sheets

and on U.S. Geological Survey (USGS) topographic maps. The applicant also provided a table

showing the stage-storage curve and revised the SSAR to be consistent with the RAI response.

In SSAR Section 2.4.1.1, the applicant stated that the cooling water withdrawal rate for Unit 3

will be 2540 cfs, and that for Unit 4 this rate will be 44 cfs. In RAI 2.4.1-4, the staff requested

that the applicant clarify whether these values are based upon annual averages or maximums.

If these values are annual averages, the staff asked the applicant to provide estimates of

maximums. In RAI 2.4.1-4, the staff also requested the applicant to provide the basis for the

estimation of consumptive loss from the Unit 4 cooling tower. In response to RAI 2.4.1-4, the

applicant stated that the cooling water withdrawal rate of 2540 cfs for Unit 3 is a nominal design

coolant flow. This is the nominal flow during periods of peak lake temperature. The applicant

stated that the actual daily maximum circulating water flow for Unit 3 would be within a few

percent of the nominal value. The applicant informed the NRC of a revised approach to cooling

the proposed Unit 4 in a letter dated March 31, 2004, and subsequently revised the SSAR to

reflect this approach. The revised application states that the proposed Unit 4 would use a

closed-cycle cooling system with dry cooling towers. This approach eliminates the use of Lake

Anna as a source of makeup water for Unit 4. The applicant also stated that the secondary

cooling loop evaporative losses for the proposed Unit 4 may consume a small amount of water,

on the order of 1 gpm.

2.4.1.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

GDC 2 in Appendix A to 10 CFR Part 50, 10 CFR 52.17(a), and 10 CFR 100.20(c), as well as

the applicable regulatory guidance, RG 1.70 and RS-002. The staff reviewed this portion of the

application for conformance with the applicable regulations, and considered the corresponding

regulatory guidance, as identified above, with the exception that an ESP applicant need not

demonstrate compliance with the GDC.

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Section 2.4.1 of RS-002 provides the following review guidance used by the staff in evaluating

this SSAR section.

The SSAR should address 10 CFR Parts 52 an- d 100, as they relate to identifying and

evaluating hydrologic features of the site; The regulations at 10 CFR 52.17(a) and 10 CFR

100.20(c) require that the physical characteristics of a site (including'seismology, meteorology,

geology, and hydrology) be taken into account to determine its acceptability for a nuclear power

reactor. In addition, 10 CFR 100.20(c) addresses the hydrologic characteristics of a proposed

site that may affect the consequences of an escape of radioactive material from the facility.

Factors important to hydrologic radionuclide transport, described in 10 CFR 100.20(c)(3),

should be obtained from onsite measurements. The staff evaluated SSAR Section 2.4.1 in light

of these requirements.

To satisfy the hydrologic requirements of 10 CFR Parts 52 and 100, the applicant's SSAR -

should contain a description of the surface and subsurface hydrologic characteristics of the site

and region. This description should be sufficient to assess the acceptability of the site and the

potential for those characteristics to influence the design of the SSCs'of a nuclear power plant

or plants (or a facility falling within a PPE) that might be constructed on the'proposed site.

Meeting this guidance provides reasonable assurance that the hydrologic characteristics of the

site and potential hydrologic phenomena 'would pose no undue risk to the type of facility (or

facility falling within a PPE) proposed for the site. Further, it provides reasonable assurance' -

that such a facility would pose n'o undue risk of radioactive contarmination'to surface or

subsurface water from either normal operations or as the result of a reactor accident. '

To meet the requirements of the hydrologic aspects of 10 CFR Parts 52 and 100, SSAR

Section 2.4.1 should form the basis for hydrologic engineering analysis with respect to

subsequent sections of the application for an ESP. Therefore, completeness and clarity are of

paramount importance. Maps should be legible and adequate in coverage to substantiate'-

applicable data. Site topographic maps should be of good quality and of sufficient scale'to

allow independent analysis of preconstruction drainage patterns. Data on surface water users,

location with respect to the site, type of use, and quantity of surface water used are necessary.

Inventories of surface water users should be consistent with regional hydrologic inventories

reported by applicable Federal and State agencies. The description'of the hydrologic

characteristics of streams, lakes, and shore regions should 'correspond to those of the USGS,

NOAA, Soil Conservation Service (SCS), U.S.'Army Corps of Engineers (USACE); or"

appropriate State and river basin agencies. Descriptions of all existing or proposed reservoirs

and dams (both upstream and downstream) that could influence conditions at the'site should be

provided. Descriptions may be obtained from reports of the USGS, U.S. Bureau of

Reclamation (USBR),' USACE,' and others.' Generally, reservoir descriptions of 'a quality similar

to those contained in pertinent'data'sheets'of a standard USACE hydrology design

memorandu'm are adequate. 'Tabulations of drainage areas, types of structures, -

appurtenances,' ownership, seismic and spillway' design criteria, elevation-storage relationships,

and short-.and long-term storage allocations should be provided. ' -

2.4.1.3 Technical Evaluation

The staff conducted a site visit in accordance with the guidance provided in Section 2.4.1 of

RS-002. The staff used information from the site visit, digital maps, and streamf low data from

., 1 ,

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the USGS to verify the hydrologic description provided in Section 2.4.1 of the SSAR. Because

Virginia Electric and Power Company (which, like the applicant, is a subsidiary of Dominion

Resources, Inc.) built the reservoir and continues to operate it, the company has a large volume

of historical data pertaining to the reservoir. The applicant has supplemented that data with

maps, charts, and data from Federal, State, and regulatory bodies describing hydrologic

characteristics and water use in the site vicinity.

The staff verified the combined surface area of Lake Anna and the WHTF using the USACE

major dams map layer. This map layer dataset lists the combined surface area of Lake Anna

and the WHTF as 13,000 ac, compared to 13,096 ac reported by the applicant.

The applicant stated in SSAR Section 2.4.1.2.1 that the catchment area of the North Anna

River above the North Anna Dam is about 343 mi2. The staff verified this statement by

comparing the catchment area reported by the applicant with the 344 mi2 drainage area of

USGS streamflow gauge 01670400, at the North Anna River near Partlow, Virginia. The

applicant stated in SSAR Section 2.4.1.2.1 that the discharge measured at the Partlow

streamflow gauge reflects the regulated outflow from Lake Anna for the entire period of record

since the dam was completed in 1972. The staff notes that measurements of discharge from

the dam are not available from the closure of the dam sometime in 1972 until October 1, 1978.

The staff independently searched for streamflow gauges in the site vicinity and found that the

USGS has maintained four streamflow gauges near the plant. Two gauges measured

streamflows of tributaries draining into Lake Anna, and two measured streamflows downstream

of the Lake Anna Dam. The longest streamflow record exists for the North Anna River near the

Doswell, Virginia, gauge. This gauge reflects the release from Lake Anna and runoff from an

additional 97 mi2 of watershed downstream of the Lake Anna Dam. Streamflow at this gauge

was recorded from April 1929 through October 1988. Streamflow immediately downstream

from the Lake Anna Dam (North Anna River near Partlow, Virginia) was recorded from October

1978 through October 1995. The gauge on Contrary Creek, which drains into Lake Anna,

reflects only 5.53 mi2 of the watershed and has a record from October 1975 through January

1987. Another stream gauge upstream of Lake Anna (Pamunkey Creek at Lahore, Virginia)

records runoff from 40.5 mi2 of the Pamunkey Creek drainage area for the period from August

1989 through July 1993. The two upstream gauges record flows representative of only 46 mi2,

or approximately 13 percent of the total upstream area contributing flow to Lake Anna. The

staff could not use the limited upstream tributary inflow data to independently estimate historical

frequency distribution of water levels at the ESP site. Consequently, the staff used a different

empirical approach to estimate low-water conditions at the ESP site, as discussed in

Section 2.4.11.3 of this SER.

In RAI 2.4.1-1, the staff requested additional information on coordinates of grid sectors for the

individual NAPS units. The staff also requested a layout of the intake piping/tunnel from the

lake to the proposed units and locations of existing perched aquifers in the site area to

demonstrate ESP site feasibility. In this RAI, the staff asked the applicant to provide the total

service water flow rate needed for the two existing units with once-through cooling systems, as

well as the integrated cooling flow demand for all four units, to determine whether sufficient

margin exists in the available water flow from the North Anna Reservoir to account for any

uncertainties associated with water and land-use changes in the vicinity of the plant.

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The applicant's response to RAI 2.4.1-1 included a figure that lists the coordinates of the

corners of the ESP PPE (ESP site footprint). However, the applicant did not identify the

coordinate system. The staff needed information regarding the coordinate reference system

and the units of these coordinates to fully define the boundaries of the ESP site footprint. This

was Open Item 2.4-1. The staff identified in Open Item 2.4-1 the need for information regarding

the coordinate reference system and the units of measurement of these coordinates to fully

define the boundaries of the ESP site footprint.

In its submittal dated March 3,' 2005 (Dominion, "Responses to Draft Safety Evaluation Report

Open Items"),' the applicant stated that map coordinates used the Virginia State Plane North

American Datum (NAD) 83 South Zone coordinate system, and that map coordinates are

expressed in' feet. The staff reviewed the applicant's response and determined that the

additional information provided by the applicant is sufficient to fully define the boundaries of the

ESP site footprint. Accordingly, the staff considers Open Item 2.4-1 to be resolved.

In response to RAI 2.4.1-1, the applicant explained that unconfined aquifer conditions exists

beneath the ESP site in the unconsolidated deposits and bedrock, which form the Piedmont

Physiographic Province aquifer system. -(Unconfined aquifer conditions are those in which

there is no impervious layer confining the water bearing strata.) Since the ESP site and the

general area are underlain by the Piedmont Physiographic Province aquifer system, the staff

finds that there is no concern regarding perched aquifers at the ESP site.

The applicant provided a figure that contains a layout of the ESP intake and discharge tunnels.-

Based on SSAR Figure 1.2-4, the staff determined that parts of the ESP intake and discharge:-

tunnels will be located outside the PPE (ESP footprint). In the DSER, the staff stated that the

applicant needed to specify minimum distances from the SSCs of the existing units to the ESP

intake and discharge tunnels to ensure that no interference will occur with SSCs of the existing

units. This was Open Item 2.4-2. -The staff planned to impose these distances as DSER

Permit Condition 2.4-1 to ensure that no such interference would occur if a COL or CP were

ultimately granted.

In response to Open Item 2.4-2, the applicant explained in its submittal dated March 3,-2005,-

that the discharge tunnel for proposed Unit 3 would be routed from the ESP footprint east a

distance of up to 1800 ft to the ESP discharge. SSAR Figure 1.2-4 shows the locations of the

ESP intake area,'the ESP footprint, and the ESP discharge. These layouts generally coincide

with those originally planned for abandoned Units 3 and 4, which were never completed. The'

proposed Unit 4 would use a closed-cycle cooling system with dry cooling towers to transfer

rejected heat to the atmosphere. As shown in' SSAR Figure 1.2-4, proposed Unit 3 would have

its own intake west of the existing units' intake and its own outfall adjacent to the existing units'

outfall at the head of the discharge canal. The preliminary construction strategy would be to

use existing structures and routes to the extent possible. 'In the event that the existing tunnels

from the abandoned units are deemed unsuitable, new tunnels would be constructed in the

same vicinity. While the routing for these tunnels' would pass' beneath roadways, power lines, ~-

fence lines, and other structures, the tunnels would remain well away from the existing units'--.

major powerblock structures. . -' - '' -

In its response, the applicant also described potential construction techniques that could be

used to build the new discharge tunnel, and it stated that it would be-feasible to perform the

construction activities associated with the intake and discharge tunnels with no adverse

2 -63
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interactions with the existing units' SSCs. Based on the above, the staff has determined that it

is feasible to construct the proposed Unit 3 discharge tunnel in the future, should the existing

abandoned discharge tunnel be determined to be unsuitable during the design of the proposed

Unit 3. Any construction on the ESP site prior to issuance of a COL or CP will be constrained

by the existing plants' operating licenses as governed by 10 CFR Part 50, including the

requirements of 10 CFR 50.59. Since the current licensee controls access to the exclusion

area, as described in Section 2.1.2 of this SER, the holder of any ESP issued for the North

Anna site, and any COL or CP applicant referencing such an ESP will be able to construct and

operate a new unit only in accordance with the terms of an agreement with the licensee of the

existing units. The licensee of the existing units is obligated to satisfy the provisions of 10 CFR

50.59, and it will ensure that such an agreement reflects the results of any evaluation

performed pursuant to 10 CFR 50.59. Accordingly, the requirements of Part 50 will ensure that

any changes to the existing units SSCs resulting from construction on the ESP site will be

adequately controlled. Therefore, the staff has determined that it is not necessary to impose

DSER Permit Condition 2.4-1.

For this site permit review, the staff does not endorse any proposed construction technique;

instead, the applicant's response is used only for a feasibility determination. The Section 50.59

process, or, should discharge tunnel construction be described in a COL or CP application, the

future COL or CP review process will ensure the safety of any new construction. In the latter

circumstance, the staff would review the layout of intake and discharge tunnels and the

construction techniques to be used by any COL or CP applicant before commencement of

construction activities. This is COL Action Item 2.4-1. Based on the above, the staff considers

Open Item 2.4-2 to be resolved.

The applicant estimated a margin of 209 cfs in the water budget, assuming that the average net

inflow of 370 cfs would be available. All units, including the proposed additional units, need

121 cfs of non-safety-related cooling water. The State of Virginia requires a minimum release

of 40 cfs from Lake Anna for water surface elevation at or above 248 ft MSL and a minimum

release of 20 cfs below it. However, during periods of low flow, the expected inflow into Lake

Anna can be substantially lower than the average inflow. These periods may be critical for nonsafety-related cooling needs. The staff asked the applicant to describe the potential impacts of

low-flow conditions on the operation of all units. This was Open Item 2.4-3.

In response to Open Item 2.4-3, the applicant stated, in its submittal dated March 3, 2005, that

Section 5.2.2 of the environmental report describes a water budget analysis carried out to

determine potential impacts of low-flow conditions on the operation of all units. The applicant

carried out the water budget analysis to assess potential impacts of low-flow conditions on the

operation of all units. This analysis determined that the minimum water surface elevation in

Lake Anna during the simulation period, which included the severe 2001-2002 drought, would

be 242.6 ft MSL when proposed Unit 3 is assumed to operate along with NAPS Units 1 and 2.

The applicant also stated that, at the time of the submission of the SSAR, modifications were

underway to reconfigure the intake of NAPS Units 1 and 2 to allow operation of these units

down to a low water surface shutdown elevation of 242 ft MSL. These modifications were

complete as of March 3, 2005, the date of applicant's response to staff's open items. The low

water surface shutdown elevation for operation of NAPS Units 1 and 2, and of proposed Unit 3,

is now 242 ft MSL. The applicant stated that, since the low water surface shutdown elevation in

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Lake Anna for normal operation bf proposed Unit 3 (242 ft MSL) is less than the minimum water

surface elevation determined by applicant's water budget analysis (242.6 ft MSL), the normal

operation of proposed Unit 3 would not be impacted, even during extended periods of low inflow

to Lake Anna.

The staff evaluated the water budget as set forth below. The staff estimated inflows for the -

drainage upstream of Lake Anna using data from the adjacent Little River drainage basin -

adjusted for the differences in 'drainage areas. -The reason for using an adjacent drainage

basin is that too few of the tributaries'flowing into Lake Anna'are gauged for the data to be

useful in constructing an inflow sequence for the analysis. The staff also decided that the flow

downstream from Lake Anna' Dam cannot be used to estimate inflows to Lake Anna because

they are too heavily influenced by consumptive'losses from Units 1 and 2 and the flow

regulation resulting from the lake. The Little River drainage is a 107 mi2 area adjacent to the

North Anna drainage with streamflow measurements from October 1961 to the present. The

direct precipitation input to the lake was based on precipitation records from the meteorological

station at the Richmond, Virginia airport.

The staff estimated outflows from the lake based on the current operating rules for the Lake

Anna Darn,-which are regulated by the State of Virginia. Releases are generally performed to

maintain a water surface elevation of 250 ft MSL.- When the water surface elevation drops

below 250 ft MSL because of inadequate'inflow to offset the natural and induced evaporative

losses, the release is maintained at the normal minimum flow of 40 cfs. -If the water surface

elevation declines below 248 ft MSL,-releases were assumed to decrease to 20 cfs

immediately. The minimum-operating depth for the intake pumps for ESP Unit 3 as well as

those for Units 1 and 2 is 242 ft MSL.

Based on the applicant's PPE estimate of 29 cfs, the staff-estimated minimum lake elevation

that would occur anytime during the period from 1978-2003 was 242.8 ft MSL. Therefore, the

staff concluded that any drop below 242 ft MSL would be infrequent.

The staff's water budget analysis also addressed the 'gradual decrease -in water surface

elevation in Lake Anna during normal operation of all units, including the proposed Unit 3, for an

extended period of time that also included a severe 2-year drought during water years 2001 and

2002. The staff used precipitation data from the Richmond, Virginia,-airport (period of record

from January 1, 1921, to'May 31, 2004) in its water budget analysis; In terms of precipitation,

water year 1924 was the driest, and water year 2002 was the second driest. Combined

precipitation during water years 2001 and 2002 was the driest 2-year period in the record. -

The staff's concern in Open Item 2.4-3 was to determine if water surface elevation in Lake

Anna could fall rapidly and/or frequently enough to result in an excessive reliance of proposed

Unit 3 on its UHS, if the selected plant design includes a UHS. a -

The staff's water budget analysis estimated that, during the severe 2001-2002 2-year historical

drought,-the water surface elevation in Lake Anna would not have fallen below 242.6 ft MSL

with the existing units running at full capacity and the proposed Unit 3 running using a oncethrough cooling system, also at full capacity.. In an alternative configuration, with the existing

units running at full capacity and the proposed Unit 3 operating at full capacity with a wet

cooling tower, water surface elevation in Lake Anna would have fallen to 242 ft MSL, the

proposed low water surface elevation for shutdown of proposed Unit 3. The staff used

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conservative estimates of consumptive water use by the Unit 3 wet cooling tower for this

alternative configuration. In this alternative configuration, it took 71 days for water surface

elevation in Lake Anna to fall from 244 ft MSL to 242 ft MSL. While it is possible for a more

rapid decrease in water surface elevation in Lake Anna to occur in the presence of a more

severe combination of starting water surface elevation, low inflow, and little precipitation, the

staff considers the 71-day period for the water surface elevation to fall from 244 ft MSL to 242 ft

MSL indicative of Lake Anna's large capacity to allow a gradual decrease in its water surface

elevation, even under extreme droughts. Therefore, the staff concludes that water surface

elevation in Lake Anna does not fall rapidly and that sufficient time will be available to plant

operators before the low water surface elevation shutdown threshold is reached to plan a

shutdown of the proposed Unit 3 without endangering its safety, even under severe drought

conditions. Based on the staff's independent water budget analysis described above, the staff

also concludes that the water surface elevation in Lake Anna does not fall near the low water

surface elevation shutdown threshold frequently enough to result in an excessive reliance of

Unit 3 on its UHS, if the selected plant design includes a UHS. Accordingly, the staff considers

Open Item 2.4-3 to be resolved.

SSAR Section 2.4.1.1 originally stated that, during critical, low-flow periods, makeup water

would be obtained from Lake Anna, supplemented by an external source which the COL

applicant would identify. In RAI 2.4.1-2, the staff requested that the applicant identify the

source and quantity of the makeup flow. The applicant informed the NRC in a letter dated

March 31, 2004, that proposed Unit 4 would use dry cooling towers as its normal cooling

system. The applicant stated that the change in the proposed Unit 4 cooling system from wet

cooling towers to dry cooling towers will reduce its consumptive water use from 35 cfs to

approximately 0.002 cfs. The change of the proposed Unit 4 cooling system to a dry cooling

system eliminates the need for any significant quantity of alternative cooling water. The

applicant has revised its application to commit to a dry cooling system for the proposed Unit 4.

This is a satisfactory response to RAI 2.4.1-2.

Subsequently, the staff based its water budget analysis and interpretation of its results on the

assumption that the proposed Unit 4 would use a negligible amount of water (on the order of

1 gpm) from Lake Anna for its normal cooling. In order to ensure the safety of any proposed

nuclear power plant or plants that may be built on the ESP site, the NRC staff proposes to

include a condition in any ESP that might be issued for this site requiring that an applicant for a

fourth proposed unit use a dry cooling tower system during normal operation. This is Permit

Condition 3. In addition, any COL or CP applicant should develop a plant shutdown protocol

for proposed Unit 3 when water surface elevation in Lake Anna falls to 242 ft MSL. This is COL

Action Item 2.4-2.

The staff independently obtained estimates of the stage-storage relationship for Lake Anna.

The staff obtained USGS 1:24,000 digital raster graph maps for Lake Anna and mosaicked

them to create a georeferenced topographic map using the geographical information system

software, ArcMap, Version 9.0. The bathymetry contours on this topographic map have

elevations from 180 to 250 ft MSL. The staff manually digitized the lake boundary and the

bathymetry contour lines and corrected them for errors. The staff created a digital surface

using these digitized contours. The staff created horizontal sections, or isosurfaces, of this

digital surface from 180 to 250 ft MSL at 10 ft intervals. The staff digitally determined areas of

these isosurfaces and then calculated the enclosed volume between two successive

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isosurfaces to independently estimate the'stage-storage relationship for Lake Anna. The staff's

independent estimates closely match the applicant's stage-storage curve. Therefore, the staff

considers the applicant's curve to be satisfactory.

SSAR Section 2.4:1.1 reports an'estimated withdrawal of 2540 cfs for Unit 3 and 44 cfs for the

proposed Unit 4. A subsequent letter from the applicant to the NRC dated March 31, 2004,

stated that the proposed Unit 4 would use a dry cooling tower. In RAI 2.4.1-4,the staff

requested the applicant to clarify whether the cooling water flow values are annual averages or

maximums. The staff indicated that if they were annual averages, estimates for daily

maximums were needed. In its response, the applicant stated that the cooling water flow rate

of 2540 cfs for the proposed Unit 3 is a nominal value and that the daily maximum flow rate

would be within a few percent of this nominal value. In addition, proposed Unit 4 secondary

cooling loop evaporative issues will consume a small amount of water, on the order of 1 gpm.

Based on information provided in the SSAR and the applicant's response to the RAls discussed

in this section'of the SER, the staff concludes that the additional water budget available for use

by the new units is 2540 cfs. The staff intended to identify this maximum water use as DSER

Permit Condition 2.4-2. Since the available water flow is at least equal to the controlling PPE

value of 2540 cfs, and Appendix A of this SER identifies the controlling PPE values, it is not

necessary to add this permit condition. The future review process will ensure that a new plant's

cooling water use is safely limited to the amount of water flow not to exceed 2540 cfs. The PPE

Table 3.1-1 of the application states that the bounding Unit 3 discharge water temperature is

113 OF, and the cooling water temperature rise is 18 OF, which results in a maximum inlet,

temperature limit of 95 *F. Since the available water flow rate depends upon these conditions, -

the staff proposes to include these controlling PPE values in any ESP that the NRC might issue

for the site. Pursuant to 10 CFR 52.24, the staff proposes the cooling water flow rate of 2540

cfs, the cooling water temperature rise of 18 OF, and the maximum inlet temperature of 95 "F as

controlling PPE values when the lake level is less than or equal to 244 ft MSL: Appendix A of

this SER lists the controlling PPE values. Any COL or CP applicant referencing an ESP issued

for the North Anna site'should show that the combined cooling water flow rate for the new units

does not exceed 2540 cfs.' This is COL Action Item 2.4-3.

2.4.1.4 Conclusions

As set forth above, the'applicant has provided information pertaining to the general hydrologic

characteristics of the site, including descriptions of rivers, streams,-and lakes; water-control

structures; and users of waters. -Theref ore,"the staff concludes that, with the noted conditions,

the applicant has met the requirements regarding general hydrologic descriptions with respect

to 10 CFR 52.17(a) and 10 CFR 100.20(c); '

2.4.2 Floods -:

2.4.2.1 Technical Information in the Application

Lake Anna was created to provide a reliable supply of cooling water for NAPS. The watershed

that drains into Lake Anna is approximately 323 mi2. The area of Lake Anna, including the

WHTF, is approximately 20 mi2. The North Anna Dam is located about 4 miles north of

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Bumpass, Virginia, and about 5 miles downstream from the ESP site. Lake Anna is about

17 miles long, with an irregular shoreline approximately 272 miles in length.

The applicant presented peak flood discharges and peak reservoir levels for Lake Anna (since

1979) in SSAR Section 2.4.2.1. The largest flood recorded on the North Anna River at the

Doswell, Virginia, gauge station occurred in 1969, with a peak discharge of 24,800 cfs. The

applicant reported that the flood of 1972 that resulted from Hurricane Agnes was 24,000 cfs

and nearly matched the historical peak discharge. However, it was attenuated at the time by

the recently completed, but only partially filled, Lake Anna.

In SSAR Section 2.4.2.2, the applicant considered several possibilities for determining its

design-basis flood, including the probable maximum flood (PMF) on streams and rivers,

potential dam failures, the probable maximum surge and seiche2 flood, and ice-effect flooding.

The applicant selected the highest water level from among these flooding possibilities as the

maximum flooding level. The highest water level in Lake Anna results from the PMF produced

by the probable maximum precipitation (PMP) over the lake's watershed. The applicant's

analysis estimates a design-basis flood elevation of 267.39 ft at the ESP site.

The staff requested, in RAI 2.4.2-1, that the applicant provide a description of likely upstream

land-use changes and changes in downstream water demand that would alter both flood risk

and the intensity and frequency of low-flow conditions. The staff indicated that factors affecting

potential runoff (such as urbanization, forest fire, or change in agricultural use), erosion, and

sediment deposition needed to be considered for determining flood elevation at the ESP site.

In addressing RAI 2.4.2-1, the applicant stated that its response to environmental RAI E4.2.2-2

describes likely upstream land-use changes and downstream water demand. The applicant

identified three counties located upstream of Lake Anna that may undergo growth. New

development could lead to an increase in impervious surface area and, consequently, an

increase in runoff to Lake Anna. The applicant stated that all three counties plan to implement

stormwater management measures to reduce downstream impacts. The projected

development in these counties is low, and the applicant expects such development to result in

only a small impact to Lake Anna. The applicant also described the potential effect of forest

fires and consequent sediment deposition in Lake Anna and concluded that these effects will

not affect flood-level determination. The applicant stated that an increase in water demand

resulting from the proposed Unit 3 would lead to longer periods when the lake level will be

below 250 ft MSL, as compared to existing conditions. The applicant proposed that the

presence and operation of the proposed Unit 3 may increase the likelihood that the lake level

will be below 250 ft MSL when a flood event occurred. Since more storage will be available

under such circumstances, the applicant concluded that the flood-water level at the ESP site

would be reduced. The applicant revised the SSAR to be consistent with its RAI response.

The staff requested, in RAI 2.4.2-2, that the applicant provide its methodology for documenting

hillslope failures in the watershed of Lake Anna. The staff indicated that any documented

hillslope failures should include both the failure mechanism and the hillslope properties (e.g.,

terrain grade, drainage, and soil type). In response to RAI 2.4.2-2, the applicant stated that it

2 A seiche is a standing wave oscillation of an enclosed water body that continues,

pendulum fashion, after the cessation of the originating force, which may have been either

seismic or atmospheric (USACE 2003).

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had investigated landslide hazards in the North Anna site area. The applicant used field

reconnaissance, air photo interpretation, literature search, and discussions with researchers

familiar with the region. Th'e applicant determined that large, deep-seated landslides do not

occur in the North Anna site area or along the shores of Lake Anna. The topography in the

Piedmont region is not susceitible to landslides and extensive debris flows. The applicant

found no published maps of landslides in the Lake Anna area. The applicant concluded that no

potential exists for large, deep-seated landslides or debris flows that may produce a seiche in

Lake Anna.

The staff requested, in RAI 2.4.2-3, that the applicant provide its methodology for documenting

seismically induced seiches in Lake Anna. The staff indicated that any evidence of a historical

seismically induced seiche in the area should include a description of the seismic event, land

damage, date of occurrence, and other information. In response to RAI 2.4.2-3, the applicant

stated that it performed a literature search to determine if any seismically induced seiches had

occurred in Lake Anna or other lakes in the area. In its response, the applicant referred to a

paper published in the Science of Tsunami Hazards, the international journal of the Tsunami

Society. This paper lists all known reports of tsunami and tsunami-like waves, including

seiches, that have occurred in the eastern United States since 1600. The applicant found no

listings of seiche activity in Virginia in the paper. The applicant also stated that the plant

personnel at North Anna have not reported any seiches on Lake Anna.

The staff requested, in RAI 2.4.2-4, that the applicant demonstrate that drainage capacity at the

existing grade is sufficient to 'accommodate local,' intense precipitation. If this capacity is not

sufficient, the staff asked the applicant to describe any active,- safety-related drainage systems

that will be installed for the ESP units. In addition, the staff requested the applicant to indicate

whether drainage from the proposed site would use a drainage canal under the existing railroad

spur. In its response, the applicant stated that the final grade at the ESP site would slope

gently from south to north toward Lake Anna. The applicant stated that it would determine the

final grade of the site after completing a detailed analysis for drainage of local intense

precipitation (i.e., the local PMP defined in SSAR Section 2.4.2.3). The applicant proposed to

drain local intense precipitation using surface ditches and swales. The applicant described two

scenarios related to the existing railroad spur. If the spur is left in place, drainage culverts

would be needed.- Flood analysis for local intense precipitation would assume that all culverts

are blocked, and grading near the railroad spur would be provided to allow floodwater to flow

over the railroad spur and the road located north of it. Grading north of the road would be

provided to direct floodwater to a surface ditch that would discharge to Lake Anna. If the

railroad spur is removed, the road north of it would be provided with a low-water crossing

consisting of a wide drainage canal at an elevation lower than the existing elevation of the road.

The applicant also proposed to provide a storm drain beneath this drainage canal to discharge

flow generated by' less severe storms." For either of these scenarios, the-applicant stated that

slab and entrance curb 'elevations for safety-related facilities would be placed above the flood

elevations determined from a detailed analysis of flooding caused by local intense precipitation.

2.4.2.2 Regulatory Evaluation -

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to the

NRC regulationsard regulatory guidance. The applicant identified the applicable regulations

as Appendix S. Earthquake Engineering for Nuclear Power Plants," to 10 CFR Part 50, 10 CFR

52.17(a), and 10 CFR 100.20(c) and the applicable regulatory guidance, RGs 1.29, "Seismic

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Design Classification"; 1.59, "Design Basis Floods for Nuclear Power Plants"; 1.70; and 1.102,

"Flood Protection for Nuclear Power Plants"; as well as RS-002. The staff reviewed this portion

of the application for conformance with the applicable regulations, and considered the

corresponding regulatory guidance, as identified above.

Section 2.4.2 of RS-002 provides the following review guidance the staff used in evaluating this

SSAR section.

Acceptance criteria for this section address 10 CFR Parts 52 and 100, as they relate to

identifying and evaluating hydrologic features of the site. The regulations at 10 CFR 52.17(a)

and 10 CFR 100.20(c) require that the site's physical characteristics (including seismology, .

meteorology, geology, and hydrology) be taken into account when determining its acceptability

to host a nuclear reactor or reactors.

To satisfy the hydrologic requirements of 10 CFR Parts 52 and 100, the SSAR should contain a

description of the surface and subsurface hydrologic characteristics of the site and region and

an analysis of the PMF. This description should be sufficient to assess the acceptability of the

site and the potential for those characteristics to influence the design of plant SSCs important to

safety. Meeting this guidance provides reasonable assurance that the hydrologic

characteristics of the site and potential hydrologic phenomena would pose no undue risk to the

type of facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic -

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting the relevant limiting parameters.

To determine whether the applicant met the requirements of the hydrologic aspects of 10 CFR

Parts 52 and 100, the staff used the following specific criteria:

For SSAR Section 2.4.2.1, the staff compares the potential flood sources and flood

response characteristics of the region and site identified by its review (as described in

the review procedures) to those identified by the applicant. If similar, the staff accepts

the applicant's conclusions. If, in the staff's opinion, significant discrepancies exist, the

staff will ask the applicant to provide additional data, reestimate the effects on a nuclear

power plant or plants of a specified type (or falling within a PPE) that might be

constructed on the proposed site, or revise the applicable flood design bases, as

appropriate.

* For the SSAR Section 2.4.2.2, the applicant's estimate of controlling flood levels is

acceptable if it is no more than 5 percent less conservative than the staff's

independently determined (or verified) estimate. If the applicant's SSAR estimate is

more than 5 percent less conservative, the applicant should fully document and justify

its estimate of the controlling level. Alternatively, the applicant may accept the staff's

estimate.

* For SSAR Section 2.4.2.3, the applicant's estimates of the local PMP and the capacity

of site drainage facilities (including drainage from the roofs of buildings and siteponding) are acceptable if the estimates are no more than 5 percent less conservative

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than the corresponding staff assessment. Similarly, conclusions relating to the potential

for any adverse effects of blockage of site drainage facilities by debris, ice, or snow

should be based upon conservative assumptions of the storm and vegetation conditions

likely to exist during storm periods.- If a potential hazard does exist (e.g., the elevation of

ponding exceeds the elevation of plant access openings), the applicant should

document and justify the local PMP basis.

The staff used the appropriate sections of the following documents to determine the

acceptability of the applicant's data and analyses in meeting the requirements of 10 CFR

Parts 52 and 100. RG 1.59 provides guidance for estimating the design-basis flooding

considering the worst single phenomenon, as well as combinations of less severe phenomena.

The staff used the publications of USGS, NOAA, SCS, USACE, applicable State and river basin

authorities, and other similar agencies to verify the applicant's data relating to the hydrologic

characteristics and extreme events in the region.;

2.4.2.3 Technical Evaluation

The staff obtained historical flows from USGS streamflow records for the Doswell and Partlow

gauges. The peak discharge at Doswell ("Peak Streamflow for the Nation, USGS 01671000

North Anna River Near Doswell, Virginia") during the 1972 flood was 23,300 cfs, and the

corresponding peak discharge at Partlow ("Peak Streamflow for the Nation, USGS 01670400

North Anna River near Partlow, Virginia") was 22,000 cfs.

Hydrometeorological Report (HMR) 52 ("Application of Probable Maximum Precipitation

Estimates-United States East of the 105th Meridian," National Weather Service, August 1982)

states that local intense precipitation at a given site should be based on the short-duration

(1 hour), 1-mi2 PMP. The staff used the HMR 52 guidelines to estimate the 1-hour, 1-mi2-PMP

depth for the ESP site. Column 2 of Table 2.4-1 lists the multiplication factors recommended in

HMR 52 that are applied to 1-hour, 1-mi2 PMP depth to estimate the PMP depths for other

durations. Column 3 of Table 2.4.2-1 includes the staff's estimated PMP depths corresponding

to these durations.

Table 2.4.2-1 Local Intense Precipitation (1-mi 2 PMP) at the North Anna ESP Site

Duration Multiplier to 1-hr PMP depth PMP depth (in.)

5 min 0.331 6.1

15 min 0.522 9.58

30 min 0.748 13.73

1 hr. 1.000 18.3

6 hr1.527 28.02

The estimation of onsite drainage capacity and the availability of cooling water during critical

low-flow periods call for margins sufficient to account for future urbanization of the watershed.

These margins should be based upon available county and/or State growth management plans.

In RAI 2.4.2-1, the staff indicated that a description of likely upstream land-use changes and

changes in downstream water demand that could alter both flood risk and the intensity and

frequency of low-flow conditions was needed. The staff also indicated that factors affecting

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,11 11

potential runoff (e.g., urbanization, forest fire, or change in agricultural use), erosion, and sediment deposition should be considered in the determination of flood elevation at the site.

In response to RAI 2.4.2-1, the applicant described the effects of upstream land-use changes and an increase in downstream water demand. Using this information, and assuming very conservative infiltration loss terms (i.e., low water losses) during computation of flood-water elevations at the ESP site, the staff has verified (as documented in Section 2.4.3 of this SER) that there is reasonable assurance that flooding caused by a PMF occurring in the Lake Anna watershed will not pose an undue risk to a facility falling within the PPE that might be located on

the ESP site.

In response to RAI 2.4.2-2, the applicant performed field reconnaissance, literature searches, and consultations with researchers familiar with the region. The applicant found no evidence of large landslides or debris flows in the region that could produce a seiche in Lake Anna. The staff has determined that the applicant has adequately addressed these concerns and that it has provided sufficient information to conclude that hillslope failure leading to a seiche in Lake

Anna is not credible.

In response to RAI 2.4.2-3, the applicant performed a literature survey and referred to a paper published in Science of Tsunami Hazards that lists all known tsunami and tsunami-like waves, including seiches, which have occurred in the eastern United States since 1600. The applicant did not find any listed event that occurred in Virginia. The applicant stated that plant personnel at North Anna have not reported any such event. Accordingly, the staff concludes that the applicant has adequately addressed the possibility that seismically induced seiches could occur in Lake Anna. The staff's independent estimate, discussed in Section 2.4.5 of this SER, also indicates that seismically induced seiches in Lake Anna are unlikely.

In response to RAI 2.4.2-4, the applicant stated that drainage facilities at the ESP site will be determined after a detailed analysis of flooding resulting from local intense precipitation. I.The applicant described two possible scenarios, one for the case in which the existing railroad spur is left in place and the other for the case in which the railroad spur is removed. Both scenarios would possibly call for suitable grading at the site, near the railroad spur and near the road located north of the railroad spur, to direct any flood produced by local intense precipitation at

the ESP site to Lake Anna.

Drainage systems, such as storm drains or culverts, may become blocked during a flooding event. To preclude the possibility of a safety concern for this reason, the staff intended to specify in DSER Permit Condition 2.4-3 that any COL or OP applicant would be required to design the ESP site grade in such a way as to ensure that any flooding caused by local intense precipitation on the ESP site will be discharged to Lake Anna without relying on such systems. Since detailed design of the plants, including the site grade, are beyond the scope of an ESP review, the staff has determined that it is not necessary to impose DSER Permit

Condition 2.4-3.

The staff will review the detailed design of the site grade based on applicable NRC regulations and regulatory guidance if an application is submitted referencing any ESP that might be issued. Any COL or CP applicant should show that the ESP site is graded such that any flooding caused by local intense precipitation will be discharged to Lake Anna even in the event

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that any and all active drainage systems may be blocked and unable to function. This is COL -

Action Item 2.4-4. Appendix A of this SER identifies the minimum site grade at 271 ft MSL as

a controlling PPE value. In addition, the staff intended to specify in DSER Permit

Condition 2.4-4 that the COL or CP applicant will be required to locate any safety-related facility

at an elevation above the maxiriidm water surface elevation produced by local intense

precipitation (PMP) expected on the ESP site. Since the plant grade has not yet been

determined, and its detailed design is beyond the scope of an ESP reviewthe staff has

determined that it is not necessary to impose DSER Permit Condition 2.4-4. The staff will

review flooding protection measures based on applicable NRC regulations and regulatory

guidance if an application is submitted referencing any ESP that might be issued. Any COL or

CP applicant should show that all safety-related structures are located at elevations-above the

maximum water surface elevation produced by local intense precipitation, or that adequate

flood protection measures are in place to ensure their safety. This is COL Action Item 2.4-5.

2.4.2.4 Conclusions

As set forth above, the applicant has provided sufficient information pertaining to floods.

Therefore, the staff concludes that the applicant has met the requirements relating to floods

with re6pect to 10 CFR 52.17(a) and 10 CFR 100.20(c).

2.4.3 PMF on Streams and Rivers

2.4.3.1 Technical Inforrnation in the Application

According to the applicant, the watershed draining into Lake Anna is approximately 323 mi2 in

area. The area of Lake Anna, including the WHTF, is approximately 20 mi2. Flooding in the

watershed would lead to increased water surface level in Lake Anna.

The applicant adhered to the six-subsection format outlined in RG 1.70. Accordingly, the staff's

summary of the applicant's methods and findings, discussed below, will also follow this format.

Probable Maximum Precipitation

The applicant stated in SSAR Section 2.4.3.1-that the watershed drainage is 343 mi2, including

the surface area of Lake Anna and the WHTF. The applicant estimated PMP according to

procedures outlined in Hydrometeorological Reports (HMRs) 51 ("Probable Maximum

Precipitation Estimates. United States East of the 105th Meridian," NOAA; June 1978); 52, and

53 ("Seasonal Variation of 10-Square-Mile Probable Maximum Precipitations Estimates; United

States East of the 105t Meridian," NOAA, April 1980). The applicant temporally distributed the

72-hour PMP storm according to guidelines in HMR 52 and ANS/ANSI-2.8-1992, "American

National Standard for Determining Design Basis Flooding at Power Reactor Sites," issued

1992. To analyze the PMF runoff,' the ap'plicant used an antecedent 72-hour storm equivalent

to 40 percent of the PMP, followed by 3 drydays,f6llowed by the full 72-hour PMP storm.. . . . .: _y .. . :- - . ...

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PreciDitation Losses

The applicant stated in SSAR Section 2.4.3.2 that it calibrated the precipitation loss parameters

in the Hydrologic Engineering Center (HEC) watershed modeling code, HEC-1, using historical

storms. The applicant adjusted these losses to minimize differences between observed and

simulated rainfall runoff relationships for the basin. The applicant investigated the historical

storms used in a 1976 study and three additional storms that occurred in February 1979,

March 1994, and June 1995. The applicant selected these additional storms because they

produced high.water levels in Lake Anna.-

Runoff and Stream Course Models

The applicant stated in SSAR Section 2.4.3.3 that it used HEC-1 to estimate runoff and to route

the resulting flood through Lake Anna. The applicant then compared the HEC-1 computed

discharge and reservoir stages to observed values. The applicant adjusted both base flow and

precipitation losses to minimize differences between observed and simulated values, and it

used HEC-1 to route the flood through the reservoir with a level pool routing procedure. The

analysis treated Lake Anna, including the WHTF, as a single reservoir when the water surface

was above 253.5 ft MSL, corresponding to the top of the dikes separating the WHTF from Lake

Anna. The analysis neglected any potential storage in the WHTF when the reservoir water

surface was below 253.5 ft MSL.

PMF Flow

The applicant estimated peak PMF inflow to Lake Anna in SSAR Section 2.4.3.4 as

302,100 cfs. It estimated the peak discharge over the North Anna Dam to be 141,000 cfs. The

applicant also stated that no other dams exist upstream of the North Anna Dam, except two

small reservoirs in the drainage area. The applicant did not include the effects of releases from

these two small reservoirs in the PMF flow estimation.

Water Level Determinations

The applicant routed the PMF through the reservoir using an HEC-1 level pool routing

procedure. The applicant stated in SSAR Section 2.4.3.5 that the maximum water level

estimated at the dam is 264.07 ft MSL. The applicant also stated that the resulting backwater

profile at the ESP site would be approximately 0.2 ft higher than the water level at the dam.

Therefore, the applicant's maximum estimated PMF water surface elevation at the ESP site is

264.27 ft MSL.

Coincident Wind Wave Activity

The applicant stated in SSAR Section 2.4.3.5 that it based the wave setup, added to the PMFestimated water surface elevation at the ESP site, on a 2-year wind, and that it used a wind

speed over ground of 56.0 mVhr. The applicant estimated maximum and effective fetch

lengths3 to be 10,600 ft and 4,700 ft. respectively. Based upon the values of these parameters,

3 Fetch length is the horizontal distance (in the direction of the wind) over which a wind

generates seas or creates a wind setup. On reservoirs and smaller bodies of water, wind setup

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the applicant estimated a significant wave height4 of 2.15 ft, a maximum wave height of 3.60 ft,

a wind setup value of 0.09 ft, and a wave runup5 value of 3.03 ft. The applicant reported the

maximum PMF water surface elevation at the ESP site, including wind setup and wave runup,

to be 267.39 ft MSL.

The staff requested, in RAI 2.4.3-1, that the applicant provide a calibrated unit hydrograph,

expressed in terms of input parameters for, HEC-1, from an adjacent unregulated basin of a size

similar to the Lake Annawatershed or explain why such a hydrograph is not necessary. In its

response, the applicant stated that it based the unit hydrograph it developed for Lake Anna on

actual rainfall data and observed water. level and discharge data measured at the North Anna

Dam. The applicant stated that because this unit hydrograph is based on actual observed

responses in the basin, it is more representative of the Lake Anna rainfall-runoff response than

that of an adjacent unregulated basin. The applicant also provided definitions of the

parameters of the Clark Synthetic Unit Hydrograph and described how the presence of Lake

Anna in the drainage area affects these parameters.

The staff requested, in RAI 2.4.3-2, that the applicant provide the supporting input files and the

software version information that it used to generate the results discussed in this section. In its

response,-the applicant provided four HEC-1 input files that it used to determine the watershed

runoff hydrograph, perform flood routing, and determine lake water levels. The applicant stated

that it used Version 4.0.1 E of the HEC-1 computer program for these analyses.

2.4.3.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

10 CFR 52.17(a)(1)(vi) and 10 CFR 100.20(c) and the applicable regulatory guidance as

RGs 1.29, 1.59, 1.70, and 1.102, as well as RS-002. The staff reviewed this portion of the

application for conformance with the applicable regulations, and considered the corresponding

regulatory guidance, as identified above.

Section 2.4.3 of RS-002 provides the following review guidance used by the staff in evaluating

this SSAR section.

Acceptance criteria for this section address 10 CFR Parts 52 and 100, as they relate to

identifying and evaluating the hydrologic features of the site. The regulations at 10 CFR

is the vertical rise in the still water level on the leeward side of a body of water caused by wind

stresses on the surface of the water. Wind setdown is a similar effect, resulting in lowering of

the water level. (USACE 2003). - -

Significant wave height is a statistical term relating to the highest one-third of waves of

a given wave group and defined by the average of their heights and periods. The composition

of the highest waves depends upon the extent to which the lower waves are considered.

- Wave runup is the upper level reached by a wave on a beach or coastal structure,

relative to the still water level.

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Parts 52 and 100 require that a site's physical characteristics (including seismology,

meteorology, geology, and hydrology) be taken into account when determining the acceptability

of a site for a nuclear reactor or reactors.

To satisfy the hydrologic requirements of 10 CFR Parts 52 and 100, the SSAR should contain a

description of the hydrologic characteristics of the site and region and an analysis of the PMF.

This description should be sufficient to assess the acceptability of the site and the potential for

those characteristics to influence the design of SSCs important to safety for a nuclear power

plant or plants of a specified type (or falling within a PPE) that might be constructed on the

proposed site. Meeting this guidance provides reasonable assurance that any hydrologic

phenomena of severity up to and including the PMF would pose no undue risk to the type of

facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

To determine whether the applicant met the requirements of the hydrologic aspects of 10 CFR

Parts 52 and 100, the staff used the following specific criteria.

The PMF, as defined in RG 1.59, has been adopted as one of the conditions to be evaluated in

establishing the applicable maximum stream and river flooding level. PMF estimates are

needed for all adjacent streams or rivers and site drainage (including the consideration of PMP

on the roofs of safety-related structures). The criteria for accepting the applicant's PMF-related

design basis depend on one of the following three conditions:

(1) The elevation attained by the PMF (with coincident wind waves) establishes a minimum

protection level for use in the design of the facility.

(2) The elevation attained by the PMF (with coincident wind waves) is not controlling; the

minimum flood protection level is established by another flood phenomenon (e.g., the

probable maximum hurricane (PMH)).

(3) The site is "dry"; that is, the site is well above the elevation attained by a PMF (with

coincident wind waves).

When condition 1 is applicable, the staff will assess the flood level. The assessment may be

made independently from basic data, by detailed review and checking of the applicant's

analyses, or by comparison with estimates made by others that have been reviewed in detail.

The applicant's estimates of the PMF level and the coincident wave action are acceptable if the

estimates are no more than 5 percent less conservative than the staff estimates. If the

applicant's estimates of discharge are more than 5 percent less conservative than the staff's,

the applicant should fully document and justify its estimates or accept the staff estimates.

When condition 2 or 3 applies, the staff analyses may be less rigorous. For condition 2,

acceptance is based on the protection level estimated for another flood-producing phenomenon

exceeding the staff estimate of PMF water levels. For condition 3, the site grade should be well

above the staff assessment of PMF water levels. The evaluation of the adequacy of the margin

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(difference in flood and site elevations) is generally a matter of engineering judgment. The

judgment is based on the confidence in the flood-level estimate and the degree of conservatism

in each parameter used in the estimate.

The staff used the appropriate sections of several documents to determine the acceptability of

the applicant's data and analyses. RG 1.59 provides guidance for estimating the PMF.

Publications of NOAA and USACE may be used to estimate PMF discharge and water level

condition at the site, as well as coincident wind-generated wave activity.

2.4.3.3 Technical Evaluation

The staff's evaluation consisted of the following independent analysis to verify the applicant's

PMF analysis. The staff completed this evaluation in accordance with RS-002.

Probable Maximum Precipitation

The staff determined the PMP using HMRs 51 and 52 and ANSI/ANS-2.8-1992. HMR 51 gives

a set of charts of PMP depths for durations of 6, 12, 24, 48, and 72 hours, corresponding to

drainage areas of 10, 200, 1,000, 5,000, 10,000, and 20,000 mi2. Using these charts, the staff

determined PMP depths (in inches) for drainage areas of 10, 200, 1000, and 5000 mF2 for all of

the above-stated durations (Table 2.4.3-1).

Using the values in Table 2.4.3-1, the staff prepared depth-area-duration curves following the

guidelines of HMR 51 to bracket the drainage area of Lake Anna. Figure 2.4.3-1 illustrates

these depth-area-duration curves. The staff determined PMP depth values corresponding to

the North Anna Dam drainage area of 343 mi2 from Figure 2.4-1 to construct Table 2.4.3-2.

Table 2.4.3-1 Probable Maximum Precipitation Values for the North

-Anna Dam Drainage Area

Duration (hr)

Area (mi 2) 6 12. 24 48 72

10 28.6 33.4 37.0 41.0 42.8

200 19.8 23.6 28.0 31.7 33.5

1000 I -14.6 ' -18.5 - 23.8 26.0 1 27.0

5000 1 8.8 - 12.1 1 15.5 - 19.3 I 20.3 I

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Depth-Area-Duration Curves

10000____ ;_ i_; tIf r. - ; i

1000

dJ -.- 6-hour

4. 1 -*-12-hour

Ei _.*dsrimSt t a', 'D;*eX t X X 243 hour

100 -'

0.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0

PWP Depth (in.)

Figure 2.4.3-1 Depth-area-duration curves prepared for bracketing North Anna drainage

area. The dotted horizontal line corresponds to a drainage area of 343 mi2, equal to that

of the North Anna Dam.

Table 2.4.3-2 PMP Depth-Duration Values for the North Anna

Dam Drainage Area

HMR 52 and ANSI/ANS-2.8-1992 provide guidelines for distributing the PMP depths in time to

create a storm sequence during the PMP event. Following these guidelines, the staff computed

incremental PMP depths corresponding to all 6-hour durations during the 72-hour PMP

(column 2 of Table 2.4.3-3). The incremental depths were grouped into three 24-hour periods

in descending order (column 3). The staff rearranged the PMP depths within each 24-hour

group according to the guidelines of ANSI/ANS-2.8-1992. (column 4). Finally, the staff

rearranged column 4 following the guidelines of ANSI/ANS-2.8-1992 to create the time

distribution of the PMP storm over the North Anna Dam drainage area (column 5).

2-78
Table 2.4.3-3. Time Distribution of PMP forthe North Anna

Dam Drainage

6-hr Depth Group ANSI/ANS-2.8-1992 Time Distribution for Time

period (in.) No. Rearrange PMP (in.) (hr)

1 18.20 2.30 0.85 6

2 3.80 1 3.80 0.85 12

3 2.30 18.20 0.85 -18

4 2.30 2.30 0.85 24

5 0.85 0.85 2.30 30

6 0.85 0.85 3.80 36

7 0.85 0.85 18.20 42

8 0.85 0.85 2.30 48

9 0.30 0.30 0.30 54

10 0.30 0.30 0.30 60

11 - 0.30 3 0.30 0.30 66

12 0.30 0.30 0.30 72

Precipitation Losses

The staff assumed that no precipitation losses occurred in order to maximize the flood

generated by the PMP storm over the North Anna Dam drainage area.

Runoff and Stream Course Models

The staff conservatively estimated runoff by assuming that the drainage instantaneously

discharged to Lake Anna. Under this assumption, the staff estimated the runoff corresponding

to all 6-hour durations by multiplying the PMP depth corresponding to that 6-hour duration by

the area of the North Anna Dam drainage, and converting the volume of runoff into discharge.

Table 2.4.3-4 depicts the PMF thus obtained for the North Anna Dam drainage.

Table 2.4.3-4 PMF into Lake Anna

Time (hr) Runoff (in.) Runoff (cfs)

6 0.85 -31,358

12 0.85 31,358

18 0.85 31,358

24 - 0.85 31,358

30 2.3 84,851

-36 .3.8 140,188

42 . 18.2 K671,426

48 2.3 84,851

-54 0.3 11,067-

60 0.3 11,067

66 0.3 11,067

72 0.3 11,067-

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I I _rrm

PMF Flow

Table 2.4.3-4, above, presents the staff's estimates of the PMF for the North Anna Dam

drainage.

Preliminary Water Level Determinations

The staff followed two approaches to independently and conservatively bracket water levels at

the ESP site during the PMF. The first approach was to compute reservoir levels under a

steady inflow equal to the applicant's peak PMF discharge (302,100 cfs). The staff

conservatively assumed a discharge capacity for each of three spillways of the North Anna

Dam as 40,000 cfs. Under the steady inflow scenario, once the spillways reach their discharge

capacity, the reservoir would fill and then overtop.

The staff estimated the overtopping flow that must pass over the crest of the dam to be

182,100 cfs. Under these conditions, the staff assumed the full width of the North Anna Dam to

act like a weir and estimated the height of flow passing over it using the following wide

rectangular weir equation (Chow, Open Channel Hydraulics, 1959)-discharge per unit width is

q = CHI, where C is a coefficient ranging from 2.67 to 3.05, and H is the height of flow passing

over the weir. The staff obtained values of H corresponding to the two extreme values of C,

assuming the dam width is equal to 5,000 ft. Hence, the staff-estimated conservative value of

H is 5.71 ft.

The staff estimated the corresponding water level to be 270.71 ft MSL. This value is close to

the plant grade. A further increase of water level caused by wind wave runup, surges, and

seiche would result in flooding of the ESP site. However, the staff determined that the

assumption of steady inflow equal to the applicant's peak PMF discharge was overly

conservative because the lake attenuates the time between the steady inflow and the peak

PMF discharge.

The next approach the staff used was to route the staff-estimated PMF (column 3 of

Table 2.4.3-4), assuming no precipitation loss and instantaneous translation, through Lake

Anna using level pool routing (Linsley, et al., Hydrology for Engineers, 1982, p. 272). This

second approach resulted in the reservoir inflow-oufflow sequence shown in Figure 2.4.3-2.

Figure 2.4.3-3 depicts the corresponding reservoir elevations. The staff used the following

reservoir operation rules during the PMF event-(1) operate the spillway gates, if reservoir

elevation is at 250 ft MSL, to let all inflow pass through, and (2) raise reservoir gates gradually

when reservoir elevation exceeds 250 ft MSL to allow more discharge, depending on the

reservoir elevation, until water is freely discharged over the spillways.

The staff estimated the maximum reservoir elevation during the PMF event to be 269.13 ft MSL.

A further increase of water elevation caused by wind wave runup, surges, and seiche would

result in flooding of the ESP site. However, as previously stated, the staff determined that the

level pool routing of the staff-estimated North Anna Dam drainage PMF was too conservative

because the lake attenuates the time between the steady inflow and the peak PMF discharge.

Because the preliminary analysis did not take into account the delaying effect of Lake Anna for

the arrival of the peak PMF flow at the ESP site, the staff used the input data for the HEC-1

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analysis from the applicant to independently estimate floodwater level at the ESP site, as

discussed below.

Reservoir Elevation

a..-- ~ -. ~

2

0

0

.0

tv

Cu

0

'LiLr

265.00- . k ./ \

260.00 -- '

A n / ..

* . ... 5 .JR

250.00

..5, 0

245<00 15 200 30 ;-_ .;*

0 50 100 150

Tirne (hour)

200 250 '300 -

Figure 2.4.3-2 Inflow and outflow hydrographs for North Anna reservoir

during the PMF event

North Anna Reservoir Level Pool Routing

700000.i0

600000.00

_ 500000.00

0...-,. . -,.Xi5j!a--;V)W.S,-

400000.00

200000.0M ~ ~ ~ ~ ... * ---

100000.00.

0.00

0 50 100 150 200 2o50 3i

Time (hour)

Figure 2.4.3-3 Reservoir elevation during the PMF event

2-81
Coincident Wind Wave Activity

The staff estimated wave heights based upon wave height nomographs (see USACE, "Coastal

Engineering Manual," EM 1110-2-1100, Revision 1, 2003). These nomographs estimate wave

height based upon fetch length and wind speed. The staff used a fetch length of 10,560 ft.

ANSI/ANS-2.8-1992 (p. 17) states, "A probable maximum hurricane (PMH) shall be considered

for U.S. coastline areas and areas within 100 to 200 miles bordering...the Atlantic Ocean...."

Guidance from ANSI/ANS-2.8-1992 suggests that, for the Great Lakes Region, the maximum

over-water wind speed is 100 mi/hr. The staff used this conservative value to estimate a wave

height of 4.3 ft. This shallow-water wave height is based upon an average of the highest onethird of representative waves.

Section 2.4.5 of this SER discusses wind setup. Based upon a wind speed of 100 mi/hr, the

staff estimated the wind setup for the ESP site to be 0.46 ft.

The applicant did not specify in the SSAR the location of the lowest (and/or closest to Lake

Anna) safety-related facility of the ESP site. The staff requested this information in RAI 2.4.1-1.

The applicant responded by providing a revised site layout plan with coordinate grids. In order

to meet the PPE constraints on ground water level and the site ground water level, the staff

intended to constrain the locations of the proposed units toward the northeast corner of the

proposed footprint in DSER Permit Condition 2.4-12. The staff determined that it is

unnecessary to impose DSER Permit Condition 2.4-12 since it will review and evaluate any

future plant design in accordance the NRC regulations to ensure adequate safety during

design, construction, or inspection activities for a new plant. Refer to Section 2.4.12 of this

SER for additional details.

In response to RAI 2.4.3-1, the applicant provided the details of its input for the HEC-1 analysis.

The staff conducted its HEC-1 runs using the applicant's data for routing. the PMF through Lake

Anna. As described below, the staff determined that the maximum water surface elevation

caused by PMF, wind setup, and wave runup is 1.5 ft below the plant grade, which is 271 ft

MSL.

The staff's preliminary, highly simplified bounding estimate of water level exceeded the

proposed ESP site grade. Therefore, the staff needed to review the applicant's HEC-1

calculations. The applicant provided the staff the HEC-1 input file it used in the calculations.

The staff repeated the HEC-1 run using the applicant's input file and the newer Version 4.1 of

the HEC-1 software, issued June 1998. The staff determined that the maximum inflow into the

lake was 302,953 cfs. The peak outflow from the dam was 141,246 cfs, and the corresponding

water surface elevation in the lake was 264.1 ft MSL.

The staff also determined that, for computing floods from PMP, unit hydrograph flood peaks

should be increased from 5 to 20 percent, and the time to peak should be reduced by

33 percent (Linsley, et al., Hydrology for Engineers, 31 Edition, 1982; Pilgrim and Cordery,

"Flood Runoff," Chapter 9 in Handbook of Hydrology, 1992). The staff adjusted the applicant's

unit hydrograph according to these guidelines to provide a more conservative estimate of the

unit hydrograph than that used by the applicant. Figure 2.4.3-4 illustrates the staff's

conservative and the applicant's original unit hydrographs. The peak discharge in staff's

conservative unit hydrograph is 20 percent greater than that in applicant's unit hydrograph, and

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the time to peak in staff's conservative unit hydrograph is reduced by 50 percent compared to

that in applicant's unit hydrograph.

0

0)

CD0) c',

0)

0)

0 - LO,.

- Applicant's UH - ~Staffs conservative UH

(Jn

,-c)

0)

in

0

uJ2

0

0

0)

0

0 -

U.)

0 -

I I I i I I I I I I I

0 3 6 9 12 15 .18 21 24 27 30

Time (hr)

Figure 2.4.3-4 Applicant's original (black line) and staff's conservative (red line) -

unit hydrographs

The staff also conservatively assumed that no infiltration losses occurred during the PMP event.

The staff modified the applicant's HEC-1 input file and carried out another HEC-1 run using the

conservative unit hydrograph and no infiltration loss., This run resulted in a peak inflow of

342,502 cfs and a corresponding peak discharge of 143,775 cfs. The maximum'calculated

water surface elevation at the dam was 264.6 ft MSL.

The staff estimated the maximum water surface elevation at the ESP site by adding wave

height (4.3 ft) and wind setup (0.46 ft) to the maximum water surface elevation at the dam-

(264.6 ft MSL). The staff estimated the maximum water surface elevation at the ESP site to be

269.5 ft MSL. This conservatively estimated maximum water surface'elevatidn at the ESP site

is 1.5 ft below the plant grade.

Two small lakes exist upstream from Lake Anna. Lake Louisa was formed by the construction

of Louisa Dam on Hickory Creek in 1960, and Lake Orange was formed by the construction of

Lake Orange Dam on Clear Creek in 1964. The combined capacity of these two lakes is

7671 ac-ft, approximately equal to 3 percent of Lake Anna's storage capacity between the

normal pool and the top of the North Anna Dam. In Section 2.4.4 of this SER, the staff

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I[ IM

estimates that an increase in inflow volume of 7671 ac-ft to Lake Anna would result in an

increase of 0.9 ft in water surface elevation, if the starting elevation were 250 ft MSL. The

water surface elevation would increase 0.5 ft, if the starting water surface elevation were 265 ft

MSL. Therefore, the staff estimated the water surface-elevation corresponding to the PMF,

coincident wind wave action, and breach of Lakes Louisa and Orange to be 270 ft MSL. The

staff concluded from this information that the maximum water surface elevation caused by the

PMF and the coincident wind effects will not result in flooding of the ESP site. The staff's

estimate of the PMF level is slightly higher than the applicant's (270 ft MSL vs 267.39 ft MSL).

Pursuant to 10 CFR 52.24, the staff is proposing the maximum elevation of ground Water at

270 ft MSL or 1 ft below the free surface, whichever is higher, the flood elevation at 270 ft MSL,

and the minimum lake water level at 242 ft MLS as site characteristics for inclusion in any ESP

that might be issued for the North Anna site. Appendix A of this SER lists the site

characteristics.

2.4.3.4 Conclusions

As set forth above, the applicant has provided information pertaining to the PMF on streams

and rivers showing that the PMF is below the proposed grade of the ESP PPE (site footprint).

Therefore, the staff concludes that the applicant has met the requirements relating to the

effects of PMF on streams and rivers, with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c).

Further, for the reasons set forth above, the staff concludes that the applicant has considered,

in establishing the minimum stream and river flood level acceptable for design purposes, the

most severe natural phenomena that have been historically reported for the site and

surrounding area with sufficient margin for the limited accuracy, quantity, and period of time in

which the historical data have been accumulated.

2.4.4 Potential Dam Failures

2.4.4.1 Technical Information in the Application

The ESP site is located adjacent to Lake Anna and is approximately 5 miles upstream of the

North Anna Dam. Lake Anna was created to supply water to the existing NAPS and would be

the cooling water and primary service water source for the proposed North Anna Unit 3. The

applicant intends to use a dry, closed-cycle cooling system for the proposed Unit 4 which would

not withdraw significant amounts of water from the lake for cooling. The UHS for the proposed

units would consist of a mechanical draft cooling tower over a buried water storage basin or

other passive water storage facility, as called for by the reactor design. The UHS would also

provide water for the service water system in the event that the primary source becomes

unavailable.

The applicant stated that no other significant dams exist on the North Anna River, either

upstream or downstream of the ESP site. The only impoundments in the area are small farm

ponds and two small recreational lakes (Lake Louisa and Lake Orange). The applicant

concluded that failure of either of these lakes would not produce any measurable effect on Lake

Anna, the North Anna Dam, or any safety-related system.

The applicant concluded that the UHS design ensures adequate water for emergency cooling,

even if Lake Anna were to be drained as a result of a dam failure. The applicant also

2-84
concluded that no safety-related structures or systems would be adversely affected by the loss

of water caused by a dam failure.

The staff requested, in RAI 2.4.4-1, that the applicant document impounded volumes and the

locations of Lake Louisa and Lake Orange'relative to Lake Anna. The staff also requested that

the applicant providelits methodology for documenting failure of dams on these lakes. In its

response, the applicant stated that Lake Louisa is located on Hickory Creek, a tributary to the

North Anna River, and Lake Orange' is located on Clear Creek, a tributary to Pamunkey Creek,

which is a tributary to Lake Anna. Lake Louisa is located approximately 3.4 miles upstrea~m of -

Lake Anna.I It has a surface area of 280 ac, land a storage volume of 4713 ac-ft.; Lake Orange

is located approximately 8.8 miles upstream of Lake Anna. It has a surface area of 120 ac, and

a storage volume of 2958 ac-ft. The applicant stated that the storage capacity of Lake Anna

between the normal water surface elevation 'of 250 ft MSL and the top of the dam elevation of

265 ft MSL is 245,000 ac-ft.' Thisistorage capacity of Lake Anna is sufficient to accommodate

the combined storage capacity of the two recreational lakes, which is equal to 7671 ac-ft. The

applicant also considered the scenario in which dams on both Lake Louisa and Lake Orange

fail during a PMP event, such that the discharge from these dam breaches arrives at Lake Anna

at the same time as the peak discharge of the PMF generated by the PMP event on Lake

Anna's watershed. The applicant estimated that the additional increase in PMF peak water.

surface elevatiori'caused by these dam breaches w6uld be 0.4 ft. The applicant concluded that

the resulting water surface elevation would be 264.67 ft MSL, which is below the proposed site

grade of 271 ft MSL. (The staff considers such an effect in Section 2.4.3.3 of this SER.)

The staff requested, in RAI 2.4.4-2, that the applicant provide details regarding storage capacity

and design parameters'for this underground basin. In its response,:the applicant stated that a

mechanical draft cooling tower over an underground basin would be used as the UHS, if the

selected plant design includes a UHS. A separate cooling tower and basin would be provided

for each proposed unit. The storage volume for each basin would be 4,090,625 ft3, and each

basin would be approximately 235 ft wide, 350 ft long, and 50 ft deep. The applicant stated that

additional basin depth will be provided for freeboard and to accommodate a possibly frozen

surface layer.

2.4.4.2 Regulatory Evaluation

Section 1.8 of the SSAR presents'a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

10 CFR 52.17(a)(1)(vi), 10 CFR 100.20(c), and 10 CFR 100.23(c), and the applicable ' -

regulatory guidance as RGs 1.29, 1.59,1.70, and 1.102, as well as RS-002. The staff reviewed

this portion of the application for conformance with the applicable regulations, and considered -

the corresponding regulatory guidance, as identified above.

Section 2.4.4 of RS-002 provides the review guidance discussed below and used by the staff in

evaluating this SSAR section.

Acceptance criteria 'for this section are-based on meeting the requirements of the following

regulations: ' -

10 CFR Parts '52 and 100, as they relate to evaluating hydrologic features of the site

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I I - -1 1

10 CFR 100.23, 'Geologic and Seismic Siting Criteria," as it relates to establishing the

design-basis flood resulting from seismic dam failure

The regulations at 10 CFR 52.17(a) and 10 CFR 100.20(c) require that the site's physical

characteristics (including seismology, meteorology, geology, and hydrology) be taken into

account when determining its acceptability to host a nuclear reactor or reactors.

The regulations at 10 CFR Parts 52 and 100 are applicable to SSAR Section 2.4.4 because

they address the physical characteristics, including hydrology, considered by. the Commission

when determining the acceptability of a site for a power reactor. To satisfy the hydrologic

requirements of 10 CFR Parts 52 and 100, the SSAR should contain a description of the

hydrologic characteristics of the region and an analysis of potential dam failures. The

description should be sufficient to assess the acceptability of the site and the potential for those

characteristics to influence the design of SSCs important to safety. Meeting this criterion

provides reasonable assurance that the effects of high water levels resulting from failure of

upstream dams, as well as those of low water levels resulting from failure of a downstream

dam, would pose no undue risk to the type of facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of relevant parameters.

The regulation at 10 CFR 100.23 requires consideration of geologic and seismic factors in

determining site suitability. Specifically, 10 CFR 100.23(c) requires an investigation of the

geologic and seismic site characteristics to permit evaluation of seismic effects on the site.

Such an evaluation will consider seismically induced floods, including failure of an upstream

dam during an earthquake.

The regulation at 10 CFR 100.23 is applicable to SSAR Section 2.4.4 because it requires

investigation of seismic effects on the site. Such effects include seismically induced floods or

low water levels, which constitute one element in the Commission's consideration of the

suitability of proposed sites for nuclear power plants. RG 1.70 provides more detailed guidance

on the investigation of seismically induced floods, including results for seismically induced dam

failures and antecedent flood flows coincident with the flood peak. Meeting this guidance

provides reasonable assurance that, given the geologic and seismic characteristics of the

proposed site, a nuclear power plant or plants of a specified type (or falling within a PPE) could

be constructed and operated on the proposed site without undue risk to the health and safety of

the public, with respect to those characteristics.

The staff used the following criteria to determine whether the applicant met the requirements of

10 CFR Parts 52 and 100 and 10 CFR 100.23, as they relate to dam failures:

* The staff will review the applicant's analyses and independently assess the coincident

river flows at the site and at the dams being analyzed. ANSI/ANS-2.8-1992 provides

guidance on acceptable river flow conditions to be assumed coincident with the dam

failure event. To be acceptable, the applicant's estimates (which may include landslideinduced failures) of the flood discharge resulting from the coincident events should be

no more than 5 percent less conservative than the staff estimates. If the applicant's

2-86
estimates differ by more than 5 percent, the applicant should fully document and justify

its estimates or accept the staff estimates.

The applicant should identify the location of dams and potentially "likely" or severe

modes'of failure. Driis'or embankments for the purpose of impounding water for a

nuclear power plant(s) or plants that might be constructed on the proposed site should

also be identified.' The potential for multiple, seismically induced dam failures and the

domino failure of a series of dams should be discussed. Approved models of the

USACE and the Tennessee Valley Authority should be used to predict the downstream

water levels resulting from a dam breach. First-time use of other models will necessitate

complete model description and documentation. The staff will determine the

acceptance of the model (and subsequent analyses) based on its'review of model

theory, available verification, and application. For cases which assume something other

than instantaneous failure, the applicant should thoroughly document the conservatism

of the rate of failure and shape of the breach. A determination-of the peak flow rate and

water level at the site for the worst possible combination of dam failures,' as well as a

summary analysis (that substantiates the condition as the critical permutation) should be

presented, along with a description (and the bases) of all coefficients and methods'

used. In addition, the effects of other concurrent events on plant safety, such-as

blockage of the river and waterborne missiles, should be considered.

* The effects of coincident and antecedent flood flows (or low flows for downstream

structures) on initial pool levels should be considered.- Depending upon estimated

failure modes and the elevation difference between plant grade and normal river levels,

it may be acceptable to use conservative, simplified procedures to estimate flood levels

at the site. Where calculated flood levels using simplified methods are at or above plant

grade and include assumptions which cannot be demonstrated as conservative, it will be

necessary to use unsteady flow methods to develop flood levels at the site.

Referernces 7, 13, and 14 of RS-002 are acceptable methods;.however, other programs

could be acceptable with proper documentation and justification. Computations,

coefficients, and methods used to establish the water level at the site for the most

critical dam failures should be summarized. Coincident wind-generated wave activity

should be considered in a manner similar to that discussed in Section 2.4.3 of RS-002:

RG 1.59 provides guidance for estimating the maximum flooding level, corisidering the worst.-

single phenomenon and a combination of less severe phenomena;:

2.4.4.3 Technical Evaluation

The staff consulted USGS maps to independently verify the applicant's information and

concluded that no dams of significant storage, the failure of which could endanger the North

Anna Dam,-exist upstream. -

Using the National Inventory of Dams, the staff independently found that Lake Louisa was

formed by the construction of Louisa Dam on Hickory Creek in 1960, and Lake Orange was

formed by the construction of Lake Orange Dam' on Clear Creek in l1964. The storage capacity

of Lake Louisa is 4173 ac-ft and Lake Orange is 2958 ac-ft. The combined capacity'of these

two lakes is 7671 ac-ft, approximately 3 percent of Lake Anna's storage capacity between the

normal pool and the top of the North Anna Dam. The staff estimated that an increase in inflow

2-87
I [ A

volume of 7671 ac-ft to Lake Anna would result in an increase of 0.9 ft in water surface

elevation, if the starting elevation were 250 ft MSL. The water surface elevation would increase

0.5 ft if the starting water surface elevation were 265 ft MSL. The staff estimated the water

surface elevation corresponding to the PMF, coincident wind wave action, and breach of Lakes

Louisa and Orange to be 270 ft MSL. The staff concludes that simultaneous arrival of all water

stored in these two lakes coincident with the PMF would not result in flooding of the ESP site,

which is at an elevation of 271 ft MSL.

In the event of failure of the North Anna'Dam, the proposed new nuclear power plants would

rely on the UHS for essential cooling, if the selected plant design includes a UHS. The

applicant intends to use underground reservoirs for the UHS, which would be approximately

50 ft deep. The maximum elevation of ground water at the proposed site is 270 ft MSL. It is

essential for ensuring the integrity of the UHS reservoirs that any uplift of the reservoirs caused

by buoyancy, either during construction or during the life of the proposed plants, is precluded.

Therefore, the free surface elevation of the UHS may not fall below 270 ft MSL. The staff

identified this as DSER Permit Condition 2.4-5.

The applicant in its letter dated March 3, 2005, in response to Open Item 2.4-6, stated that

details of the location and construction of the UHS have not been established. If the chosen

reactor design calls for a conventional UHS, the design, location, and construction details of the

UHS would be determined as part of detailed engineering and described in the COL or CP

application. The applicant's response includes a detailed discussion of the engineering

feasibility of ensuring that an underground UHS reservoir would be able to rely on the friction

resistance from the foundation on the embedded side walls of the reservoir without any vertical

uplift of the UHS reservoir because of hydrostatic upward pressure from ground water. The

applicant also discussed the potential for use of rock anchors to prevent uplift of the UHS

reservoir.

The staff does not endorse any reliance on skin friction between backfill and a structure critical

to safety. The foundation is likely to encounter fissured rock and, over a period of 40 to

60 years, could experience considerable shrinkage and cracking, all of which can render side

friction ineffective. Uplift resistance has been estimated using a nonnuclear standard (U.S.

Department of Transportation, Federal Highway Administration, "Drilled Shafts," Publication No.

FHWA-HI-88-042, July 1988) for anchors in fissured rock. The staff does not endorse or

accept the applicant's conceptual approach for establishing UHS reservoir stability under

buoyancy. However, the staff accepts that a combination of water height limit in the reservoir

and an engineered and monitored posttensioned anchorage system can reliably prevent any

uplift of the UHS reservoir, should one be needed. A detailed engineering design of the UHS

reservoir is not within the scope of the ESP review. Based on the above, the staff has

determined that NRC regulations and regulatory guidance will ensure the safety of any future

UHS design and construction; therefore the proposed permit condition is not needed for the

ESP. Instead, any COL or CP applicant should demonstrate that the UHS reservoirs are

designed so as to satisfy the NRC's regulations. A COL or CP applicant may demonstrate

compliance by following applicable NRC guidance. This is COL Action Item 2.4-6.

In response to RAI 2.4.4-2, the applicant provided details of the UHS, if the selected plant

design includes a UHS, for the proposed units and the storage capacity of the associated

underground UHS basins. Based on the applicant's dimensions of the underground UHS basin,

2-88
- .

the staff estimated the storage capacity of the UHS basins to be 4.1 million ft3

. Based on its

review of site water availability, the staff intended to specify in DSER Permit Condition 2.4-6

that this estimated UHS basin storage capacity, should the selected plant design include a

UHS, as the minimum acceptable storage capacity. Since the selection and detailed design of

the plants, including their emergency cooling systems, that may be constructed on the ESP site

are beyond the scope of an ESP review, the staff determined that it is not necessary to impose

DSER Permit Condition 2.4-6. The stafftwill perform its review of the design of the plants,

including their emergency cooling systems, according to NRC regulations and regulatory

guidance. If the selected plant designs include,-a UHS, any COL or CP applicant should

demonstrate that the UHS storage basins provide storage sufficient to meet 30-day'emergency

cooling water needs accounting for any and all losses including but 'not limited to seepage,

evaporation, -and icing for the selected plants. 'Programmatic provisions should be provided for

plant shut down when the liquid water volume in the UHS storage basin is inadequate. This is

COL Action Item 2.4-7.

2.4.4.4 Conclusions

As set forth above, the applicant has provided sufficient information pertaining to dam failures.

Therefore, the staff concludes that the applicant has met the requirements relating to dam

failures, with respect to 10 CFR 52.17(a), 10 CFR 100.20(c), and 1 0 CFR 100.23(c).' The

applicant has considered the most severe natural phenomena that have been historically

reported for the site and surrounding area, with sufficient margin for the limited accuracy,

quantity, and period of time in which the historical data have been accumulated in establishing

the minimum consequences of dam failure acceptable for design purposes.

2.4.5 Probable Maximum Surge and Seiche Flooding

The ESP site is located on the shores of Lake Anna, approximately 50 miles inland frorm the

Chesapeake Bay at an elevation of 271 ft MSL. Lake Anna is a 17-mi-long reservoir formed

when the dam was constructed on the North Anna River. The ESP site is located at the

approximate longitudinal midpoint of the reservoir, 5 miles upstream of the North Anna Darn.

2.4.5.1 Technical Information in the Application

The applicant stated that the ESP site is not located on an estuary or an open coast and

concluded that both surge and seiche flooding would not produce critical water levels at the

site. The applicant estimated a maximum fetch length of 10,600 ft. The applicant concluded

that, given the relatively short fetch length, surges and waves produced from winds or.

oscillatory waves alone would not produce' water heights greater than the still water level

resulting from the PMF.

2.4.5.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

Appendix S to 10 CFR Part 50,10 CFR 52.17(a), 10 CFR Part 100, and 10 CFR 100.20(c) and

the applicable regulatory guidance as RGs'1.29, 1.59, 1.70, 1.102, and 1.125, "Physical Models

for Design and Operation of Hydraulic Structures and Systems for Nuclear Power Plants,"

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Revision 1 dated October 1978 as well as RS-002. The staff reviewed the probable maximum

surge and seiche flooding portion of the application for conformance with the applicable

regulations, and considered the corresponding regulatory guidance, as identified above, except

that consideration of Appendix, S to 10 CFR Part 50 is limited to the determination of seismically

induced floods and water waves pursuant to Section IV(c) of Appendix S.

Section 2.4.5 of RS-002 provides guidance for the staff's evaluation of this SSAR section. This

section states that the staff's review is based on determining whether the applicant has met the

requirements of 10 CFR Parts 52 and 100, as they relate to evaluating the hydrologic

characteristics of the site. Specific criteria necessary to meet the relevant hydrologic

requirements of 10 CFR Parts 52 and 100 include the regulations-at 10 CFR 52.17(a) and

10 CFR 100.20(c), which require that the site's physical characteristics (including seismology,

meteorology, geology, and hydrology) be taken into account when determining its acceptability

for a nuclear reactor or reactors.

To satisfy the hydrologic requirements of 10 CFR Parts 52 and 100, the SSAR should contain a

description of the surface and subsurface hydrologic characteristics of the region and an

analysis of the potential for flooding caused by surges or seiches. This description should be

sufficient to assess the acceptability of the site and the potential for a surge or seiche to

influence the design of SSCs important to safety for a nuclear power plant or plants of a

specified type that might be constructed on the proposed site. Meeting this guidance provides

reasonable assurance that the most severe flooding likely to occur as a result of storm surges6

or seiches would not pose an undue risk to the type of facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

If it has been determined that surge and seiche flooding estimates are necessary to identify

flood design bases, the applicant's analysis will be considered complete and acceptable if the

following areas are addressed and can be independently evaluated from the applicant's

submission:

* All reasonable combinations of PMH, moving squall line, or other cyclonic wind storm

parameters are investigated, and the most critical combination is selected for use in

estimating a water level.

* Models used in the evaluation are verified or have been previously approved by the

staff.

* Detailed descriptions of bottom profiles are provided (or are readily obtainable) to enable

an independent staff estimate of surge levels.

6A storm surge is a rise above normal water level on the open coast caused by the

action of wind stress on the water surface. A storm surge resulting from a hurricane also

includes that rise in level caused by atmospheric pressure reduction, as well as that resulting

from wind stress (USACE 2003).

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* Detailed descriptions of shoreline protection and safety-related facilities are provided to

enable an independent staff estimate of wind-generated waves, runup, and potential

erosion and sedimentation.

* Ambient water levels, including tides and sea-level anomalies, are estimated using

NOAA and USACE publications as described below.

* Combinations of surge levels and waves that may be critical to the design of a nuclear

power plant or plants of a specified type (or falling within a PPE) that might be -

constructed on the proposed site are considered, and adequate information is supplied

to allow a determination that no adverse combinations have been omitted. --

This section of the SSAR may also state with justification that surge and seiche flooding

estimates are not necessary to identify the flood design basis (e.g., the site is not near a large

body of water).

The staff uses hydrometeorological estimates and criteria issued by USACE and NOAA for

developing PMHs for east and Gulf Coast sites, squall lines for the Great Lakes, and severe

cyclonic wind storms for all lake sites to evaluate the conservatism of the applicant's estimates

of severe windstorm conditions, as discussed in RG 1.59. The USACE and NOAA criteria call

for variation of the basic meteorological parameters within given limits to determine the most

severe combination that could result. The applicant's hydrometeorological analysis should be

based on the most critical combination of these parameters.

The staff uses data from the publications of NOAA, USACE, and other sources (such as tide

tables, tide records, and historical lake level records) to substantiate antecedent water levels.

These antecedent water levels should be as high as the "1 0% exceedance" monthly spring high

tide, in addition to a sea-level anomaly based on the maximum difference between recorded

and predicted average water levels for durations of 2 weeks or longer for coastal locations, or

the 100-year recurrence interval high water for the Great Lakes. In a similar manner, the staff

independently evaluates storm track, wind fields, effective fetch lengths, direction of approach,

timing, and frictional surface and bottom effects to ensure that the applicant has selected the

most critical values. The staff verifies models used to estimate surge hydrographs that it has

not previously reviewed and approved by modeling historical events, with any discrepancies in

the model being on the conservative (i.e., high) side.

The staff uses USACE criteria and methods, as generally summarized in Reference 9 of

RS-002, as a standard to evaluate the applicant's estimate of coincident wind-generated wave

action and runup. In addition, the staff uses the criteria and methods of the USACE and other

standard techniques to evaluate the potential for oscillation of waves at natural periodicity.

2.4.5.3 Technical Evaluation

The staff conducted its review in accordance with Section 2.4.5 of RS-002 and RG 1.59. The

ESP site is located 50 miles inland from the nearest body of open water (i.e., the Chesapeake

Bay) subject to a storm surge. The ESP site is at an elevation of 271 ft MSL. Therefore, the

staff concludes that the ESP site is not subject to a storm surge.

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The following describes the staff's independent evaluation to estimate seiche effects. Fetch

length is one of the key parameters for determining wind setup, and it is generally based upon

the longest straight-line distance to the opposing shore. Although the ESP site is 5 miles from

the North Anna Dam and more than 10 miles from the upstream end of the reservoir, the

longest straight-line distance to the opposing shore is approximately 2 miles (see

Figure 2.4.5-1).

Irregular lake bathymetry and strong thermal stratification that exists during various parts of the

year affect wind setup near the ESP site. An accurate estimate of the wind setup that

considers all of these complicating factors would require use of a multidimensional

hydrodynamic and water quality model.

A simplifying and conservative approach to estimating wind setup is to assume that the lake is

not thermally stratified and is represented as a uniform rectangular basin with one side equal to

the fetch length. The staff assumed a uniformly distributed wind stress along the water surface,

so that the hydrodynamic equations of motion can be simplified and an analytic solution for the

surface setup can be obtained. The following is the resulting solution:

CU2L

h

where 4 is the wind setup in ft. U is the wind speed in mi/hr, h is the average depth of the lake

in ft. L is the fetch length in ft, and C is an empirical coefficient equal to 1.5x10 ' (Heaps,

'Vertical Structure of Current in Homogeneous and Stratified Waters," in Hydrodynamics of

Lakes, 1984, pp. 153-207). The staff used a value of 10,560 ft for L. Bathymetry contours

(see Figure 2.4.5-1) indicate that the original river level was at an approximate elevation of

200 ft MSL. Since the water depth, h, is in the denominator, a smaller depth would produce a

larger (i.e., more conservative) wind setup. However, since wind setup is a relatively minor

effect (no more than a few feet), a low initial lake surface elevation would indicate that the wind

setup would be unlikely to reach the ESP site elevation and is not reasonable, so a deeper

average water depth was chosen based upon the ESP site elevation. Accordingly, the staff

used an average water depth of 35 ft.

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,. 11

0,_ 1 ._ 2 - 3 4K 4. Kilometers m 

I

S

Figure 2.4.5-1 North Anna Power Station site and fetch length

Another parameter in the wind setup equation is wind speed over the water surface. One of the

derivation assumptions for the wind setup equation is that the wind speed is steady and

uniformly blowing in the direction of maximum fetch. ANSI/ANS-2.8-1992 suggests that, for the

Great Lakes regiosn, the maximum over-water wind speed is 100 ri/hr. The staff used this

conservative value as the steady over-water wind speed in the wind setup equation.'

Using these values, the staff estimated the resulting wind setup as 0.46 ft.' The staff combined

this increase in water surface elevation at the ESP site with the estimated stage resulting from

the PMF, as discussed in Section 2.4.3 of this SER. -

The staff estimated the period of oscillati n6caused by seiche along the fetch length line shown

in Figure 2.4.5-1 based on the theory for free 6scillation of water of uniform depth in-a

rectangular basin (Wilson, uSeiches," Advances in Hydroscience, Volume 8, 1972): '

2L

. .: T.... ................ -

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where T is the period of seiche motion in seconds, g is the acceleration caused by gravity

(32.2 ft/s2), and L and h are as defined in the equation for wind setup. The staff estimated the

resulting seiche period to be approximately 10.5 minutes. This period is significantly shorter

than the meteorologically induced wave periods (e.g., synoptic storm pattern frequency and

dramatic reversals in steady wind direction necessary for wind setup). Therefore, the staff

concludes that meteorologically forced resonance on Lake Anna is not likely.

Overall, the staff concludes that seismically induced seiche is not likely in Lake Anna because

of the large difference between the period of oscillation caused by seiche and that of seismically

induced vibration.

2.4.5.4 Conclusions

As set forth above, the applicant has provided sufficient information pertaining to surge and

seiche. Therefore, the staff concludes that the applicant has met the requirements relating to

surge and seiche with respect to 10 CFR 52.17(a), 10 CFR 100.20(c), and Section IV(c) of

Appendix S to 10 CFR Part 50. In addition, the seismically induced flooding analysis reflects

the most severe seismic event historically reported for the site and surrounding area (with

sufficient margin for the limited accuracy, quantity, and period of time in which the historical

data have been accumulated). The staff concludes that the applicant partially conforms to

GDC 2 in Appendix A to 10 CFR Part 50, insofar as that analysis defines the minimum flood

level acceptable for design for seismically induced surge and seiche.

2.4.6 Probable Maximum Tsunami Flooding

The ESP site is located approximately 50 miles inland from the Chesapeake Bay (Potomac

River) at an elevation of 271 ft MSL on the shores of Lake Anna, a 17-mi-long reservoir that

was formed when the dam was constructed on the North Anna River. The ESP site is

approximately 5 miles upstream of the North Anna Dam.

2.4.6.1 Technical Information in the Application

The applicant stated in SSAR Section 2.4.6 that, because the site is at an inland location and

not located on an estuary or open coast, tsunami flooding is not a design consideration. The'

applicant only considered tsunami flooding associated with seismically generated waves in

open water that affect coastal areas.

2.4.6.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

10 CFR 52.17(a), 10 CFR Part 100, 10 CFR 100.20(c), and 10 CFR 100.23(c) and the

applicable regulatory guidance as RGs 1.29,1.59, 1.70, 1.102, and 1.125, as well as RS-002.

The staff reviewed this portion of the application for conformance with the applicable

regulations, and considered the corresponding regulatory guidance, as identified above.

Section 2.4.6 of RS-002 provides the guidance the staff used in evaluating this SSAR section,

which is based on meeting the requirements of the following regulations:

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* 10 CFR Parts 52 and 100, as they relate to identifying and evaluating hydrologic

features of the site

* 10 CFR 100.23, as it relates to investigating the tsunami potential at the site

The regulations at 10 CFR 52.17(a) and 10 CFR 100.20(c) require that the site's physical

characteristics (including seismology, meteorology, geology, and hydrology) be taken into

account when determining its acceptability to host a nuclear reactor or reactors. The

regulations at 10 CFR Parts 52 and 100 are applicable to SSAR Section 2.4.6 because they

address the physical characteristics, including hydrology, considered by the Commission when

determining the acceptability of the proposed site. To satisfy the hydrologic requirements of

10 CFR Parts 52 and 100, the SSAR should contain a description of the hydrologic

characteristics of the coastal region in which the proposed site is located and an analysis of

severe seismically induced waves. The description should be sufficient to assess the

acceptability of the site and the potential for a tsunami to influence the design of SSCs

important to safety for a nuclear power plant or plants of a specified type that might be

constructed on the proposed site. Meeting this guidance provides reasonable assurance that

the most severe flooding likely to occur as a result of a tsunami would pose no undue risk to the

type of facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

The regulation at 10 CFR 100.23(c) requires that geologic and seismic factors be considered

when determining the suitability of the site. As required by 10 CFR 100.23(c), an investigation

of the geologic and seismic site characteristics is conducted to permit adequate evaluation of

seismic effects on the site. Such an evaluation will consider seismically induced floods and

water waves. This regulation is applicable to SSAR Section 2.4.6 because it requires -

investigation of seismic effects on the site. Such effects include distantly and locally generated

waves or tsunami that have affected or could affect a proposed site, including the runup or

drawdown associated with historic tsunami in the same coastal region, as well as local features

of coastal topography that might modify runup or drawdown. RG 1.70 provides more detailed

guidance on the investigation of seismically induced flooding.

To determine whether the applicant met the requirements of 10 CFR Part 52, 10 CFR Part 100,

and 10 CFR 100.23 with respect to tsunami and the analysis thereof, the staff used the

following specific criteria:

* If it has been determined that tsunami estimates are necessary to identify flood or lowwater design information, the analysis will be considered complete if the following areas

are addressed and can be independently evaluated from the applicant's submission:

- All potential distant and local tsunami generators, including volcanoes and areas

of potential landslides, are investigated and the most critical ones are selected.

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- The analysis uses conservative values of seismic characteristics (source

dimensions, fault orientation, and vertical displacement) for the tsunami

generators selected.

- All models used in the analysis are verified or have been previously approved by

the staff. RG 1.125 provides guidance on the use of physical models of wave

protection structures.

- Bathymetric data are provided (or are readily obtainable).

- Detailed descriptions of shoreline protection and safety-related facilities are

provided for wave runup and drawdown estimates. RG 1.102 provides guidance

on flood protection for nuclear power plants.

- Ambient water levels, including tides, sea level anomalies, and wind waves, are

estimated using NOAA and USACE publications, as described below.

- If the applicant adopts RG 1.59, Regulatory Position 2, the design basis for

tsunami protection of all safety-related facilities identified in RG 1.29 should be

shown at the COL or CP stage to be adequate in terms of the time necessary for

implementing any emergency procedures.

* The applicant's estimates of tsunami runup and drawdown levels are acceptable if the

estimates are no more than 5 percent less conservative than the staff estimates. If the

applicant's estimates are more than 5 percent less conservative (based on the

difference between normal water levels and the maximum runup or drawdown levels)

than the staff's, the applicant should fully document and justify its estimates or accept

the staff estimates.

* This section of the SSAR will also be acceptable if it states the criteria that the applicant

used to determine that tsunami flooding estimates are not necessary to identify the

minimum flood level used for design (e.g., the site is not near a large body of water).

2.4.6.3 Technical Evaluation

The staff found during its independent review that, according to NOAA (NOAA, 2004: What

was the highest tsunami? Frequently asked questions, Tsunami Research Program website,

httD://www.Dmel.noaa.pov/tsunamVFaq/x005 highest, accessed November 1, 2004), the

10 most destructive tsunami in the Pacific Ocean since 1990 produced maximum wave heights

of 9.8 to 49 ft. A wave height of 100 ft was recorded on the coast of Japan during the 1993

Okushiri tsunami. The ESP site is located at an elevation of 271 ft MSL. The staff therefore

concluded that the effects of even the largest tsunami in open water would not be high enough

to exceed the elevation of the ESP site.

The staff also considered the potential of flooding on the shores of Lake Anna near the ESP

site as a result of wave runup caused by a seismically induced hillslope failure. A hypothetical

landslide was modeled to examine the potential for the ESP site to be exposed to a seismically

induced water wave. The staff's calculation assumed a landslide created by the surrounding

hillsides, which are at an approximate elevation of 300 ft MSL. Assuming normal water surface

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level in Lake Anna, a landslide could therefore fall 50 ft before hitting the water. If drag is -

neglected, an object falling from the hilltop could reach a vertical speed of approximately 55 ft/s.

The staff conservatively assumed that such a hillslope failure might result in a horizontal water

wave of the same speed. In addition, the staff conservatively assumed that this landslide would

displace water from the existing shoreline to the deepest portion of the lake approximately 70 ft

offshore (see Figure 2.4.6-1).

!iiii mwn

S

Figure 2.4.6-1 Landslide diagram resulting in wave traveling towards the ESP site. The

70 ft segment indicated in blue is the distance from the shore to the thalweg and

represents that part of the water column displaced by~the landslide.-

The staff performed a numerical hydrodynamic modeling of Lake Anna using the threedimensional transient-free surface model, Flow-3D.. This model is a commercial software

package that is supported though Flow Science, Inc. (Flow Science, Inc., "Flow-3D User's

Manual," 2003). The model has a large user base and has been previously tested under a wide

range of applications. Both the "Flow-3D User's Manual" and Hirt and Nichols, "Volume of Fluid

(VOF) Method for the Dynamics of Free Boundaries," issued 1981, provide details of the

model's theoretical background. A report by Bradford, "Numerical Simulation of Surf Zone

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Dynamics," issued 2000, provides a recent and relevant application of the model for breaking

waves, including free-surface breakup.

Flow-3D uses the finite volume method to solve the three-dimensional Reynolds-averaged

Navier-Stokes equations. The physical domain simulated by the model can be divided into

variable-sized hexahedral cells. This application used the Renormalized Group Model (Yakhot

and Smith, "The Renormalization Group, the e-Expansion and Derivation of Turbulence

Models," 1972) as the turbulence model. The staff divided the domain into uniform cells 1 ft in

all directions. The staff simplified the model to two dimensions (the model domain was one cell

wide), and the domain totaled approximately 500,000 computational cells. Bathymetry near the

ESP site was approximated using a preimpoundment contour map, which was further simplified

into two sloping regions (Figure 2.4.6-2). The first region extended approximately 3200 ft from

the line following the lowest part of the lake bed (thalweg) towards the ESP site. Over this

distance, the bottom rose 30 ft from an elevation of 200 to 230 ft MSL. The second region

continued horizontally for approximately 900 ft. until intersecting the normal water surface level

near the ESP site. Over this latter distance, the bottom rose 40 ft from an elevation of 230 to

270 ft MSL. The staff conservatively estimated bottom roughness to be equivalent to that of a

smooth wall.

The staff initialized the numerical model with a 70-ft horizontal zone with a horizontal velocity of

55 ft/s, while the remainder of the lake was quiescent (see Figure 2.4.6-2). The staff assumed

the boundary condition at midlake to be a wall that caused outgoing waves to reflect back

towards the ESP site. The boundary condition on top of the domain was gauge (atmospheric)

pressure.

10 x vertical exageration

thalweg 3200 ft

Figure 2.4.6-2 Initial conditions for the numerical model. The red zone at the left of the

figure is the 70-ft-wide zone initialized at 55 ft/s.

The highest extent of the wave runup was reached after approximately 118 seconds and

resembled a thin jet traveling up the smooth beach slope (see Figure 2.4.6-3). The highest

extent of wave runup on the bank was just below an elevation of 270 ft MSL, and the water did

not reach the elevation of the ESP site. At an elevation of 270 ft MSL, the wave was less than

1 ft thick. The wave reached 2 ft in thickness at an elevation of 260 ft MSL, which was 11 ft

lower than the elevation of the ESP site.

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10 x vertical exageratin.->

Figure 2.4.6-3 Highest extent of wave runup on shore

Therefore, the staff concluded that, even undef conservative conditions of flooding generated'

by severe landslide,' the ESP site would remain dry.

2.4.6.4 Conclusions

As set forth above, the applicant has provided information pertaining to probable maximum

tsunami flooding showing that the elevation of such a flood is below the-proposed grade of the

ESP PPE (site footprint), and no flood protection measures are needed.' Therefore, the staff

concludes that the applicant has met the requirements relating to probable maximum tsunami

flooding, with respect to 10 CFR 52.17(a), 10'CFR 100.20(c), and 10 CFR 100.23(c).

2.4.7 Ice Effects

The ESP site is located approximately 50 miles inland from the Chesapeake Bay (Potomac

River) at an elevation of 271 ft MSL- The Chesapeake Bay climate influences the climate at the

site throughout the year. The site is located on the shores of Lake Anna, a 17-mi-long reservoir

that was formed when the North Anna Dam was constructed on the North Anna River. The site

is located at the approximate longitudinal midpoint of the reservoir, 5 miles upstream of the

North Anna Dam.'

2.4. . 1 Technical Information in the Application

In SSAR Section 2.4.7.3, the applicant discussed historical ice formation in the region. The

applicant reported that, after the construction of the dam and before the start of the operation of

the existing NAPS units, an ice sheet formed on the lake. However, since the beginning of

operation of those units, ice sheets have formed only on the upper reaches of Lake Anna. The

staff requested, in RAI 2.4.7-1, that the'applicaint provide details, including location, duration,

and height, of the occurrence of ice dams and subsequent downstream flood waves in the

region. In its response, theapplicant stated that no historical records indicate the formation of

ice dams in the North Anna River, and therefore no records show any subsequent downstream

flooding resulting from breaking of ice dams.

SSAR Section 2.4.7.4 states that, during the design of the intake structures, any COL applicant

should assess the formation of anchor ice on'the trash -racks and'screens.' The staff requested,

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in RAI 2.4.7-2, that the applicant provide site characteristics relevant to such an assessment, including constraints on intake design based on a propensity for anchor ice and potential ice depth. In its response, the applicant stated that the site characteristics presented in SSAR Section 2.4.7.5 are not conducive to the formation of anchor ice on the trash racks and screens

at the intake structure. The applicant indicated that no historical record shows the formation of ice crystals or granules in turbulent water (resembling slush, and referred to as frazil ice) in the

existing intake structure. The applicant further stated that ice formation in the intake structure

is an extremely rare event, such as when all units do not operate for prolonged periods during very severe wintry conditions. The applicant stated that, when any unit is in operation, heat

loads dissipated in Lake Anna would preclude the formation of any frazil ice and thus the possibility of anchor ice. The applicant stated that an assessment would be made, at the COL

stage, during the detailed design review regarding whether anchor ice could form on intake

structures, and that the design would address any such icing issues identified.

SSAR Section 2.4.7.5 states that, during the period the existing units have operated at NAPS, surface ice has not formed in the area of the lake between the discharge and the intake of the

plant. Ice sheets formed upstream of Route 208 during this period. The applicant stated that, because the area where ice sheets formed is located far from the main circulation path of cooling water, ice sheet formation will not affect operation of the intake for the ESP units. The

applicant also stated that ice sheet formation is possible in the lake when all units may be offline during a sustained cold period. Based on daily mean air temperature data for 1961 to

1995, the applicant stated that, during several years, the mean daily air temperature was below

freezing for 1 to 3 weeks in January and February. The applicant estimated the maximum ice thickness that could have formed under historically observed low air temperature conditions, assuming no units were in operation. The applicant estimated 200 degree-days below freezing during January and February 1977. The applicant used Assur's method (described by Chow, uHandbook of Applied Hydrology," 1964) to estimate an ice thickness of 13.5 in. The applicant concluded that this surface ice thickness would not impact water flow to intakes during restart of

the units because of a water depth of at least 24 ft at the ESP intake.

SSAR Section 2.4.7.5 states that a separate UHS, if the selected plant design includes one, would supply the emergency cooling and service water needed to maintain the proposed units

in a safe mode. The staff requested in RAI 2.4.7-3 that the applicant describe the source of cooling water needed for this purpose. In response to RAI 2.4.7-3, the applicant stated that

initial filling and continued makeup water for UHS cooling tower basins would be obtained from

Lake Anna.

The applicant stated that the UHS would provide both emergency and service water, and that

ice-flow accumulation will not affect safety-related facilities. The staff requested, in RAI 2.4.7-4, that the applicant identify the constraints on the design of the UHS with regard to ice formation

and that it indicate the maximum depth of ice formation in the water stored in the UHS to

ensure the availability of sufficient water in the UHS during freezing. In its response, the

applicant stated that the minimum water storage capacity of the UHS would be 4,090,625 ft3

. The UHS basins would be designed with sufficient depths to store the minimum water volume

below the ice sheet, or measures would be taken to preclude the possibility of ice formation on

the surface of the UHS basin.

SSAR Section 2.4.7.6 states that the PPE snow load is 50 lb/ft 2 . The staff requested, in

RAI 2.4.7-5, that the applicant confirm whether it calculated local snow load (a site

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I 1 1E 1I
characteristic) using the meteorological attributes discussed in SSAR Section 2.3.1.3.4. In its

response, the applicant stated that the snow load for design of structures is determined using

the equivalent depth of a 48-h6tdr PMP on a 100-year return period snowpack. The 100-year

snowpack is equivalent to 30.5 lb/ft2, and the 48-hour PMP is equivalent to 107.9 lb/ft2 or

20.75 in. of water.

2.4.7.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

10 CFR 52.17(a), 10 CFR Part 100, 10 CFR 100.20(c), and 10 CFR 100.23(c) and the

applicable regulatory guidance as RGs '1.27, 1.29, 1.59, 1.70, and 1.102, as well as RS-002.

The staff reviewed this portion of the application for conformance with the applicable

regulations, and considered the corresponding regulatory guidance, as identified above, with

the exception of 10 CFR 100.23(c) which does not apply.

Section 2.4.7 of RS-002 provides review guidance used by the staff in evaluating this SSAR

section. Acceptance criteria for this section are based on meeting the requirements of 10 CFR

Parts 52 and 100, as they relate to identifyin g and evaluating hydrologic features of the site.

The regulations in 10 CFR 52.17(a) and 10 CFR 100.20(c) require that the site's physical

characteristics (including seismology, meteorology, geology, and hydrology) be taken into

account when determining its acceptability for a nuclear power reactor. To satisfy the

hydrologic requirements of 10 CFR Parts 52 and 100, the SSAR should contain a description of

any icing phenomena with the potential to result in adverse effects to the intake structure or

other safety-related facilities for a nuclear power plant or plants of a specified type (or falling

within a PPE) that might be constructed on the proposed site. -Ice-related characteristics

historically associated with the site and region should be described, and an analysis should be

performed to determine the potential for flooding, low water, or ice damage to safety-related

SSCs. The analysis should be sufficient to evaluate'the site's acceptability and to assess the

potential for'those characteristics to influence the design of SSCs important to safety for a

nuclear power plant or plants of a specified type (or falling within a -PPE) that might be -

constructed on the proposed site.' Meeting this guidance provides reasonable assurance that

the effects of potentially severe icing conditions would pose no undue risk to the type of facility

proposed for the site.

For those cases in which a reactor design is' not specified, the ESP applicant may instead -

provide a PPE to characterize a facility or facilities for' comparison with th6 hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of relevant parameters.

RG 1.59 provides guidance for developing the hydrometeorologic design basis.

To determine whether the applicant met the requirements of 10 CFR Parts 52 and 100, as they

relate to ice effects, the staff used the following specific criteria'-

Publications of NOAA, USGS, USACE,' and other sources are used to identify the

history and potential for ice formation in the region. Historical maximum depths of icing

should be noted, as well as mass and velocity of any large, floating ice bodies. The

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phrase, "historical low water ice affected," or similar phrases in streamflow records

(USGS and State publications) will alert the reviewer to the potential for ice effects. The

following items should be considered and evaluated, if found necessary:

- The regional ice and ice jam formation history should be described to enable an

independent determination of the need for including ice effects in the design

basis.

- If the potential for icing is severe, based on regional icing history, it should be

shown that water supplies capable of meeting safety-related needs are available

from under the ice formations postulated, and that safety-related equipment

could be protected from icing as in the second item above. If this cannot be

shown, it should be demonstrated that alternate sources of water are available

that could be protected from freezing, and that the alternate source would be

capable of meeting safety-related requirements in such situations.

- If floating ice is prevalent, based on regional icing history, potential impact forces

on safety-related intakes should be considered. The structural design basis

should include the dynamic loading caused by floating ice. (This item is to be

addressed at the COL or CP stage.)

- If ice blockage of the river or estuary is possible, it should be demonstrated that

the resulting water level in the vicinity of the site has been considered. If this

water level would adversely affect the intake structure or other safety-related

facilities of a nuclear power plant or plants of a specified type (or falling within a

PPE) that might be constructed on the proposed site, it should be demonstrated

that an alternate safety-related water supply would not also be adversely

affected.

* The applicant's estimates of potential ice flooding or low flows are acceptable if the

estimates are no more than 5 percent less conservative than the staff estimates. If the

applicant's estimates are more than 5 percent less conservative than the staff's, the

applicant should fully document and justify its estimates or accept the staff estimates.

2.4.7.3 Technical Evaluation

In SSAR Section 2.4.7.3, the applicant discussed historical ice formation in the region. The

applicant reported that, after the construction of the dam and before the start of the operation of

the existing NAPS units, an ice sheet formed on the lake during the winter of 1977. Since

NAPS began operating, ice sheets have formed only on the upper reaches of Lake Anna

(upstream of the Route 208 bridge). The staff accessed the USACE historical database of ice

jams on August 2, 2004. One ice jam was reported over the past.70 years for the North Anna

River, on March 4, 1934, near the Doswell USGS gauge located approximately 16 miles

downstream of the ESP site. This observation suggests that ice jam formation upstream of the

ESP site is possible. The breakup of an upstream ice dam may result in flood waves at the

ESP site. SSAR Section 2.4.7 does not provide regional characteristics of the location,

duration, height of ice dams, and ice-induced high flows.

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Because there is a historical record of ice jams on the North Anna River, the staff determined

that the applicant should address the possibility of an ice jam or an ice dam formation upstream

of the ESP site and should estimate the effect of a flood wave generated from the breakup of

such an ice formation. This was Open Item 2.4-4. In response to Open Item 2.4-4 (Dominion,

"Responses to Draft Safety'EV&luation'Report Open Items," March 3, 2005), the applicant

evaluated the effect of a flood wave generated from the' breakup' of an ice jam or an ice'dam

formation upstream of the ESP site. Since the North Anna River is the largest tributary to Lake

Anna, the applicant postulated the ice dam to occur on the North Anna River close to where it

enters Lake Anna. The applicant selected this location to estimate the greatest volume of water

that could be impounded by an ice dam, and the effect of the'breaching of such a postulated ice

dam on downstream flooding of the ESP site. Using topographic maps, the applicant estimated

that the surface area of water impounded behind this ice dam would be 150 ac. The applicant

estimated the volume of impounded water behind the ice dam as 1500 ac-ft by conservatively

assuming a dam height of 10 ft and the depth of impoundment equal to 10 ft.

The applicant stated that the volume of impounded water behind the postulated ice dam

(1500 ac-ft) on North Anna River is significantly smaller than the combined storage volume of

Lakes Louisa and Orange (7671 ac-ft). As described in Section 2.4.4 of this SER, a

simultaneous and complete failure of Lakes Louisa and Orange coincident with a PMF on Lake

Anna's watershed is not sufficiently severe to flood the ESP site grade. Consequently, the

applicant concluded that any flood produced by breakage of an ice dam on the North Anna

River would also not result in flooding of the ESP site grade.

The staff reviewed the applicant's submission and determined that the applicant's approach

(trying to bound a flood produced by breakage of an ice dam using the combined flood

produced by simultaneous breakage of dams on Lakes Louisa and Orange) is satisfactory,

based on the following rationale: The staff determined that, according to the USACE National

Inventory of Dams, the height of the Lake Orange Dam is 44 ft and that of the Lake Louisa Dam

is 25 ft. The staff also determined that no historical report exists of the formation of an ice dam

on the North Anna River that exceeded 10 ft in height. Therefore, the staff concluded that no

ice dam on North Anna River can create an impoundment of volume equal to the combined

storage of Lakes Louisa and Orange. Consequently, any flood produced by breakage of an ice

dam on the North Anna River will be smaller than the flood produced by simultaneous breakage

of dams on Lakes Louisa and Orange. The staff determined in Section 2.4.4 of this SER that a

flood produced by simultaneous breakage of dams on Lakes Louisa and Orange, coincident

with the PMF in Lake Anna's watershed, would not flood the ESP site. Consequently, the staff

concludes that any flood produced by breakage of the largest ice dams on North Anna River

would also not flood the ESP site. Based on this review, the staff considers Open Item 2.4-4 to

be resolved.

Based on the information provided in the SSAR regarding the applicant's UHS design proposed

as part of the PPE, ice formation in the lake would not directly affect the UHS because its

operation would be independent of the normal cooling water intake. However, ice formation in

the lake could lead to increased reliance on the UHS. The staff's technical evaluation

considered the safety implications of ice formation characteristics (i.e., sheet, anchor, and frazil

ice) when all, some, or none of the four units (two existing and two future) would be in

operation. The critical condition associated with freezing of the lake involves startup after all

units have been shut down. For this condition, it is necessary to quantify ice characteristics to

be used by the COL or CP applicant for design of the intake structures.

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The staff independently verified the following hydrological characteristics provided by the

applicant:

* The lowest monthly minimum air temperature at the Richmond Airport for any month

was 15 OF in January 1977. The long-term average minimum air temperature for station

VA7201 is 27.5 0F in January and 29.5 OF in February (NCDC, "Local Climatological

Data Annual Summary and Comparative Data," temperature records through December

2001 for stations VA 7201, VA 6712, VA 6533, VA 5050, 2001).

* Three other NCDC weather stations surrounding the site recorded the following

minimum temperatures. The lowest monthly minimum air temperature at Piedmont

Research Station (station VA 6712, period of record August 1948 to December 2001)

was 13 OF) in January 1977. The long-term average minimum air temperature is 24.0 OF

in the month of January and 26.2 OF in February. The lowest monthly minimum air

temperature at Partlow 3 WNW Station (station VA 6533, period of record June 1952 to

December 1976) was 11 OF in January 1970. The long-term average minimum air

temperature is 20.8 0F in the month of January and 23.8 OF in February. The lowest

monthly minimum air temperature at Louisa Station (station VA 5050, period of record

August 1948 to December 2001) was 15 'F in January 1977. The long-term average

minimum air temperature is 24.8 OF in January and 26.8 OF in February.

The staff independently estimated the likely thickness of surface ice that may form near the

intake structures. During this estimation, the staff used mean daily air temperatures recorded

at the Piedmont Research Station (Station VA 6712 as discussed in the previous paragraph)

located on the northwest ridge of the watershed draining into Lake Anna. The mean air

temperatures at this station are available for water years 1949 to 2001. The staff estimated

cumulative degree-days starting December 1 through March 31 for each water year. The most

severe cumulative degree-days below freezing occurred in 1977 (Figure 2.4.7-1).

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Water Year 1977

CD 0

o CD

0 CD

CN

0 04 6 0/0 2

0.. Days since 12/01/1976

Figure 2.4.7-1 Accumulated degriee-days since December 1, 1976, at the Piedmont'

Research Station meteorologic station'

The maximum accumulated degree-days below freezing during the period of December 1,

1976, to March 31, 1977, was'321.8 OF, as shown in Figure 2.4.7-1. The staff used Assur's

method to estimate a maximum ice thickness of 17.1 in. The staff's estimate is higher than the

applicant's estimate of 13.5 in. However,'this difference does not have any safety impact

because, as explained below, the increase in ice thickness does not affebt the intake for the

proposed additional units. The ice sheet could be in place for several weeks. The'staff

determined, based on Figure 3.4-4 of the application and the minimum Lake Anna water level of

242 ft MSL, that the intake for the proposed additional units would be at least 20 ft below the

minimum low-water level. The staff therefore concluded that the staff-calculated -maximum

estimated ice thickness of 17.1 in'. would not hamper operation of the proposed additional units.

However, the staff also determined that extended periods of water temperatures at freezing are

possible near the intake structure. In Appendix A to this SER, the staff proposes the' minimum

lake water level of 242 ft MSL and the maximum ice thickness of 17.1 in. as'site characteristics.

In response to RAI 2.4.7-2, the applicant stated that formation of frazil and anchor ice is an

extremely rare condition that can only happen when all units are shut down and prolonged,'

wintry conditions prevail. The applicart stated that this issue would be'addressed during design

of the intake structures. However, the staff determined that minimurri lake' temperature is a site

characteristic important as a design basis for a nuclear power plant or 'plarits that might be

constructed on the site. Therefore,'this was Open Item 2.4-5. -

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In response to Open Item 2.4-5, the applicant stated in its submittal dated March 3, 2005, that the only scenario in which frazil and anchor ice could form is when all units have been shut down for a prolonged period in the winter, allowing the lake to cool to ambient temperature while conditions suitable for formation of frazil ice exist. The applicant stated that frazil ice can form in open water (i.e., no ice cover is present) with air and water temperatures near freezing, strong winds, and clear nights. The applicant stated that no safety-related facilities would be impacted if frazil ice were to form near the intake. The applicant also stated that the possibility of anchor ice accumulation on the trash racks and screens of the intake structure was remote and would be addressed during detailed engineering. In case the detailed engineering review concluded that anchor ice could form, the applicant proposed to use measures in the design of the intake structure to preclude formation of anchor ice. These measures may include heating the intake components subject to anchor ice formation, circulating warm water to the intake, and using coatings to reduce ice adhesion strength.

The staff determined that the ESP site supports conditions that may lead to formation of frazil and anchor ice near cooling water intake structures. The staff also determined that minimum lake temperature is not a suitable site characteristic to describe the potential for formation of frazil ice. According to the USACE Ice Engineering Manual, frazil ice forms in turbulent, supercooled water. Supercooled water is at a temperature below its equilibrium freezing point, which, for pure water, is 32 IF at atmospheric pressure. Supercooling can occur in lakes and rivers in turbulent, open-water areas when the air temperature is significantly less than 32 'F,

usually 18 OF or lower.

In response to Open Item 2.4-5, the applicant identified the potential for frazil and anchor ice formation, in lieu of a minimum lake temperature, as a site characteristic for the cooling water intake structure. The potential for formation of frazil and anchor ice at the ESP site was included as a site characteristic in SSAR Table 1.9-1. The staff has determined that the applicant's proposed site characteristic reflects the conditions necessary for the formation of frazil ice, which are discussed above, and the staff considers Open Item 2.4-5 to be resolved.

SSAR Section 2.4.7.5 states that a separate UHS would supply the emergency cooling and service water needed to maintain the proposed units in a safe mode. The SSAR did not identify the source of the cooling water needed for this purpose. In'response to RAI 2.4.7-5, the applicant stated that Lake Anna would be the source of initial filling and continued makeup water for the UHS basins. The staff finds this to be acceptable based on the large quantity of water available for makeup and the relatively small demand represented by the UHS.

SSAR Section 2.4.7.5 states that the UHS will provide both emergency and service water and that ice-flow accumulation will not affect safety-related facilities. The SSAR does not identify constraints on the design of the UHS with regard to ice formation, nor does it indicate the maximum depth of ice formation in the water stored in the UHS to ensure the availability of

sufficient water in the UHS during freezing.

In response to RAI 2.4.7-4, the applicant stated that the minimum storage capacity of the UHS basins, if the selected plant design includes a UHS, would be maintained by either providing sufficient depth, such that the minimum water volume would be available below the ice sheet, or by adopting measures that would preclude the formation of an ice sheet on the surface of the UHS basins. In order to obviate the need for any limits on the operation of the proposed units, the UHS storage capacity should be large enough to accommodate ice formation. Through

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DSER Permit Condition 2.4-7, the staff intended to ensure that the storage volume of the UHS

basins would be sufficient to p'r-'Vide emergency cooling water'to the respective ESP plants for

30 days, accounting for any and all losses from the UHS basins. This issue is addressed by

COL Action Item 2.4-7. Pursuaiht to this item, given in Section 2;4.4.3 of this SER, a COL or

CP applicant referencing the ESP will need to address whether 30-day cooling water supply will

be available in the UHS storage basins to account for all potential losses. The issue raised by

DSER Permit Condition 2.4-7 is thus resolved, and a permit condition is not necessary.

With respect to ice in a UHS, the staff requested that the applicant identify an additional UHS

design-basis site characteristic. Section 2.3 of this -SER discusses this issue in the resolution of

Open Item 2.3-3. In its letter of March 3, 2005, responding to the staff's Open Items, the

applicant agreed to use the staff's proposed characteristic of cumulative degree-days below

freezing during winter estimated using measured air temperature at the Piedmont Research -

Station meteorologic station as the site characteristic appropriate for the estimation of thickness

of an ice layer that may form in the UHS storage basins. Section 2.3.1 .3 of this SER provides

additional details on this issue.

SSAR Table 1.9-1 states that the PPE snow load is 30.5 b/ft2 based on the 100-year return

period snowpack at the site; In response to RAI 2.4.7-3, the applicant stated that the 48-hour

winter PMP is 20.75 in. and the weight of the-100-year return period snowpack is 30.5 b/ft2. In

accordance with the criteria in RG 1.70, the snow load is obtained by using a 48-hour PMP

event combined with a 100-year snowpack. The staff estimate of this combined load (using the

applicant's 48-hour winter PMP value) is 138.4 Vb/ft2. The staff determined that this calculated

site-specific snow load is overly conservative. Section 2.3.1 of this SER provides additional

information regarding this issue.

Upon resolution of the open item related to snow load discussed in Section 2.3.1, the staff

intended to establish the snow load for the site and to include the value determined in any ESP

that the' NRC might issue for the proposed ESP site. 'In response to Open Item 2.3-2, in its

letter dated March 3, 2005, the applicant addressed the snow load issue. Section 2.3.1.3 of this

report provides a detailed discussion on this issue and resolution to Open Item 2.3-2.

Table 2.3.1-5 of this report provides the snow load to be considered for a future design.

RG 1.70 specifies both the weight of the 100-year return period snowpack and the weight of the

48-hour PMWP to assess the potential snow loads on the roofs of safety-related structures.

The staff's interim position on winter precipitation loads (see memorandum dated March 24,

1975, from H.R. Denton to R.R. Maccary) is summarized in the following paragraph as it applies

to any future COL'or CP applicant,'and provides clarification as to the load combinations to beused in evaluating the roofs of safety-related structures.

As set forth in the staff's interim position on winter precipitation loads, the winter precipitation

loads to be included in the'combination of normal live loads for the design of a nuclear power

plant or plants that might be constructed on a proposed ESP site should be based on the

weight of the 100-year snowpack or snowfall, whichever is greater, recorded at ground level.

Likewise, the winter precipitation loads to be included in the combination of extreme live loads

to be considered in the design of a nuclear power plant or plants that might be constructed on a

proposed ESP site should be based on the weight of the 100-year snowpack at ground level

plus the weight of the 48-hour PMWP at ground level for the month corresponding to the

selected snowpack. ANCOL or CP applicant may choose and justify its alternative method for

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defining the extreme load combination of maximum snow load and winter precipitation load by

demonstrating that the 48-hour PMWP could neither fall nor remain on the top of the snowpack

and/or building roofs because of the specific design of the roof. The future design of roofs for

safety-related structures will be reviewed and approved based on NRC regulations and

regulatory guidance.

2.4.7.4 Conclusions

As set forth above, the applicant has provided sufficient information pertaining to ice effects.

Therefore, the staff concludes that the applicant has met the requirements concerning ice

effects with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c). Further, the applicant has

considered the most severe natural phenomena that have been historically reported for the site

and surrounding area with sufficient margin for the limited accuracy, quantity, and period of time

in which the historical data have been accumulated, in establishing site characteristics

pertaining to ice effects that are acceptable for design purposes.

2.4.8 Cooling Water Canals and Reservoirs

Lake Anna was constructed to provide a reliable supply of cooling water for NAPS. The North

Anna Dam is located about 4 miles north of Bumpass, Virginia, and about 5 miles downriver

from the ESP site. Lake Anna is about 17 miles long, with an irregular shoreline approximately

272 miles in length.

A series of dikes and canals separates Lake Anna into two segments. The larger segment,

approximately 9600 ac, is named the North Anna Reservoir and serves as the storage

impoundment. The smaller segment, approximately 3400 ac, is the WHTF and functions to

dissipate the heat of the cooling water discharged from the existing units to the atmosphere.

The North Anna Dam is the only significant water control structure on the North Anna River.

The dam is an earth-filled structure, approximately 5000 ft long with a 30-ft-wide crest at an

elevation of 265 ft MSL. The dam has a 200-ft-long concrete spillway founded on bedrock.

The spillway has three radial crest gates, each 40 ft wide and 35 ft high. Two skimmer gates,

each 8.5 ft square, allow for the regulation of small discharges.

2.4.8.1 Technical Information in the Application

The applicant stated in SSAR Section 2.4.8 that the proposed Unit 3 would use a once-through

cooling system for normal plant cooling. This cooling system would withdraw cooling water at a

rate of 2540 cfs from a new intake structure located west of the intake structures for the existing

Units 1 and 2. The cooling water would be pumped through the proposed Unit 3 condensers

and auxiliary heat exchangers and then discharged into the WHTF for heat dissipation. A new

outfall would be constructed adjacent to the existing units' outfall at the head of the discharge

channel that leads into the WHTF.

The applicant informed the NRC of a revised approach to cooling the proposed Unit 4 in a letter

dated March 31, 2004, and subsequently revised the SSAR to reflect this approach. The

revised application states that the proposed Unit 4 would use a closed-cycle cooling system

with dry cooling towers. This approach eliminates the use of Lake Anna as a source of makeup

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water for Unit 4, as well as the potential need for Unit 4 to rely on external water sources during

drought conditions.

The applicant stated in SSAR Section 2.4.8 that the UHS for the proposed units would consist

of a mechanical draft cooling tower over a buried water storage basin or other passive water

storage facility, if the selected plant design includes a UHS. This facility would have its own

water storage basins, independent of Lake Anna, for safety-related cooling and would contain

water sufficient to maintain the plant in a safe shutdown mode for 30 days. -

The applicant stated that a series of canals and dikes divides Lake Anna into two parts. The

smaller part is the WHTF, and the larger part is the North Anna Reservoir. Circulating cooling

water for the existing units is withdrawn from the North Anna Reservoir at the existing screen

well, pumped through the condenser, and discharged through the circulating water discharge

canal into the WHTF. The WHTF consists of three ponds that are interconnected by two

canals. The discharge canal and the interconnecting canals are each designed to carry

8000 cfs. The applicant estimated a maximum discharge capacity of 6795 cfs when all four

units are operating and concluded that the design water surface elevation of 251.5 ft MSL in the

WHTF would not be affected because the canals were designed for a discharge of 8000 cfs.

The canals are constructed through bedrock and are unpaved. Vegetation on all banks

provides erosion protection, except near the discharge structure at Dike 3, where rip rap isprovided.

The circulating water flows through these ponds and is discharged through six submerged

skimmer gates located on Dike 3 into the North Anna Reservoir. The dikes are constructed of

compacted earth material, except for a 700-ft section of Dike 3, which is constructed of dumped

rock fill. -The submerged skimmer gates are constructed within the rock fill section, and the -

rock fill section itself acts as an emergency overflow spillway. The crest of the rock fill section

is at an elevation of 253.5 ft MSL, while the rest of the crest of the dike is at an elevation of

260 ft MSL. When water surface elevation in the WHTF exceeds 253.5 ft MSL, the rock fill

section overtops, while ensuring the difference in water surface elevations between the WHTF

and the North Anna Reservoir does not exceed 2 ft. The applicant estimated that the rock fill is

likely to overtop once every 100 years.

2.4.8.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

10 CFR 50.55a, "Codes and Standards"; GDC 2; GDC 44, "Cooling Water"; and 10 CFR

Part 100 and the applicable regulatory guidance as RGs 1.27, 1.29,1.59,1.70,-1.102, and

1.125. The staff reviewed this portion of the application for conformance with the applicable

regulations, and considered the corresponding regulatory guidance, as identified above, with

the exception that an ESP applicant need not demonstrate compliance with the GDC or with

10 CFR 50.55a. - - - -

Acceptance criteria for this section are based on meeting the requirements of 10 dFR Parts 52

and 100; as they relate to identifying and evaluating the hydrologic features of the site.

The regulations in 10 CFR 52.17(a) and 10 CFR 100.20(c) require that the site's physical

characteristics (including seismology, meteorology, geology, and hydrology) be taken into

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account when determining its acceptability for a nuclear power reactor. To satisfy the

hydrologic requirements of 10 CFR Parts 52 and 100, the SSAR should contain a description of

cooling water canals and reservoirs for a nuclear power plant or plants of a specified type (or

falling within a PPE) that might be constructed on the proposed site. The analysis related to

cooling water canals and reservoirs should be sufficient to evaluate the site's acceptability and

to assess the potential for those characteristics to influence the'design of SSCs important to

safety for a nuclear power plant or plants of a specified type (or falling within a PPE) that might

be constructed on the proposed site. Meeting this guidance provides reasonable assurance

that the capacities of cooling water canals and reservoirs are adequate.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

2.4.8.3 Technical Evaluation

The staff visually inspected the site on February 23 and 24, 2004. The staff determined that the

application accurately describes the cooling canals, outfalls, and levees near the ESP site.

Section 2.4.3 of this SER presents the staff's evaluation of the ability of Lake Anna (including

the WHTF) to survive a PMF. The staff did not consider Lake Anna to be a safety-related

reservoir since it is not a part of the proposed UHS for the proposed units.

The applicant stated that the UHS for the ESP units would consist of a mechanical draft cooling

tower over a buried water storage basin, if the selected plant design includes a UHS. This UHS

would have its own water storage basins that would be independent of the lake. In addition, the

applicant stated that since the cooling tower basin for the UHS would contain its own 30-day

water supply, water levels in Lake Anna would not affect the ability of the UHS to provide

emergency cooling for safe shutdown.

The applicant suggested that the proposed Unit 3 would use a once-through cooling system

during normal plant operation. The applicant also suggested that the proposed Unit 4 would

use a closed-cycle cooling system with dry towers during normal plant operation. The limitation

on the quantity of cooling water and other attributes of the cooling system design for the

proposed Units 3 and 4 form part of the bases for site constraints. Consequently, the staff

proposes the Unit 3 cooling water flow rate as a controlling PPE value, and the use of dry

towers for Unit 4 as a permit condition in any ESP that the NRC might issue for the proposed

ESP site. Appendix A to this SER contains a list of the permit conditions and controlling PPE

values for this site.

The applicant did not provide details of the location and construction of the UHS buried water

storage basin. Therefore, the staff could not review these details. The staff indicated that

these details were needed because they relate to the reliability and stability of the UHS under

the pressure head of ground water, which is at the grade level at certain locations of the ESP

site. These data were the subject of RAls 2.4.1-1 and 2.4.4-2. The need for location and

construction details to determine differential head between ground water and the UHS was

Open Item 2.4-6. Section 2.4.4.3 of this report addresses the feasibility of preventing UHS

reservoir uplift because of buoyancy. Section 2.4.4.3 notes that the staff does not accept the

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applicant's conceptual approach (see March 3, 2005, letter from the applicant in response to

open items) for preventing the UHS reservoir uplift; nonetheless, the staff accepts that a

combination of water height limit in the reservoir and an engineered and monitored

posttensioned anchorage system can reliably prevent any uplift of the UHS reservoir, should

one be needed. A detailed engineering design of the UHS reservoir is not within the scope of

the ESP review. Based on the above, the staff has determined that NRC regulations and

regulatory guidance will ensure the safety of any future design and construction; therefore,

information related to the location of the UHS reservoir is not needed for the ESP.

Section 2.4.3.3 of this SER describes the maximum elevation of ground water at 270 ft MSL or

1 ft below the free surface, whichever is higher, as a site characteristic that would need to be

considered by the COL or CP applicant in the detailed engineering design of the UHS to resist

the potential for. hydrostatic uplift, should the selected design include a UHS. Therefore, Open

Item 2.4-6 is resolved.

Lake Anna and the WHTF are not safety-related facilities, as described in the application.

Consequently, any future design at the ESP site that relies on the WHTF or on the North Anna

Reservoir for any safety-related water use will be subject to further staff evaluation of such use.

Through DSER Permit Condition 2.4-8, the staff intended to ensure that Lake Anna and the

WHTF will not be used for safety-related water use. Instead, dedicated underground UHS

water storage basins that are independent of Lake Anna and the WHTF will supply emergency

cooling water supply for the ESP plants' UHS, if the selected plant designs includes a UHS.

Further, the applicant has considered the design capacity of the cooling water canals and

discharge structure in establishing that the addition of Units 3 and 4 would not affect the normal

design-water level for WHTF. While the acceptability of the design of cooling water canals and

discharge structure is beyond the scope of an ESP review, the staff determined that the NRC's

existing regulatory process will ensure that any application proposing the use of Lake Anna for -

safety-related water will be appropriately evaluated, and therefore it is not necessary to impose.

DSER Permit Condition 2.4-8. The COL or CP applicant should address whether Lake Anna or

the WHTF will be used for safety-related water withdrawals. This is COL Action Item 2.4-8.

The details provided in SSAR Section 2.4.8 associated with cooling water canals and reservoirs

specific to the proposed Units 3 and 4 are identified by the applicant as PPE values in

Table 1.3-1 of the application. The staff has determined that the once-through cooling water

flow rate of 2540 cfs for Unit 3 is a controlling PPE value and the use of a dry cooling tower for

Unit 4 is controlled by Permit Condition 3.

2.4.8.4 Conclusions

As set forth above, the applicant has provided sufficient information pertaining to cooling water

canals -and reservoirs. Therefore, the staff concludes that the applicant has met the

requirements related to cooling water canals and reservoirs,- with respect to 10 CFR 52.17(a)

and 10 CFR 100.20(c).

2.4.9 Channel Diversions -- . , --

The watershed upstream of the North Anna Dam lies in the Piedmont Physiographic Province,

a rolling to hilly area, underlain mostly by metamorphosed sedimentary and crystalline rocks.

These rocks are relatively resistant to erosion.

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2.4.9.1 Technical Information in the Application

The applicant stated in SSAR Section 2.4.9 that there has been no major channel diversion of

the North Anna River. The applicant also stated that localized ice jams would not create a lowflow period of sufficient duration to affect the cooling water supply.

The staff requested, in RAI 2.4.9-1, that the applicant document historical or geological

evidence of possible diversions and meandering of the North Anna River upstream of the ESP

site. In its response, the applicant stated that the possibility of upstream diversion of the North

Anna River is extremely remote. The applicant used interpretations of USGS topographic maps

and pre-dam aerial photographs to conclude that historical channel diversions have been minor

and have occurred only in ancient geologic periods. These diversions are confined to valley

bottoms of the existing drainage pattern.

The applicant also stated, in response to RAI 2.4.9-1, that the underground storage basins for

the UHS, if the selected plant design includes a UHS, will be filled before plant startup and

subsequently isolated from Lake Anna, thus eliminating Lake Anna as a backup water source

for emergency cooling.

2.4.9.2 Regulatory Review

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

Appendix A to 10 CFR Part 50, GDC 44, 10 CFR 52.17(a), 10 CFR Part 100, and

10 CFR 100.20(c) and applicable regulatory guidance as RGs 1.27 and 1.70, as well as

RS-002. The staff reviewed this portion of the application for conformance with the applicable

regulations, and considered the corresponding regulatory guidance, as identified above.

Section 2.4.9 of RS-002 provides the review guidance used by the staff in evaluating this SSAR

section. Acceptance criteria for this section relate to 10 CFR Parts 52 and 100, insofar as they

require that hydrological characteristics be considered in the evaluation of the site. The

regulations at 10 CFR 52.17(a), 10 CFR 100.20(c), and 10 CFR 100.21(d) require that physical

characteristics of the site (including seismology, meteorology, geology, and hydrology) be taken

into account to determine the acceptability of a site for a nuclear reactor.

Channel diversion or realignment, which poses the potential for flooding or adversely affecting

the supply of cooling water for a nuclear power plant or plants of a specified type (or falling

within a PPE) that might be constructed on the proposed site, is one physical characteristic that

must be evaluated pursuant to 10 CFR 100.21 (d). Consideration of criteria under 10 CFR

100.21 (d) in view of this evaluation provides reasonable assurance that the effects of flooding

caused by channel diversion resulting from severe natural phenomena would pose no undue

risk to the type of facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

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I I I l
To meet the requirements of 10 CFR Parts 52 and 100, as they relate to channel diversion, the

staff use the following specific criteria:

* A description of the applicability (potential adverse effects) of stream channel diversions

is necessary.

* Historical diversions and realignments should be discussed.

* :The topography and geology of the basin and its applicability to natural stream channel

diversions should be addressed. -

* If applicable, the safety consequences of diversion and the potential for high or low

water levels, caused by upstream or downstream diversion, to adversely affect safetyrelated facilities,-water supply, or the UHS should be addressed. RG 1.27 providesguidance on acceptable UHS criteria.

2.4.9.3 Technical Evaluation

The staff developed a basic understanding of the geomorphology of the region during its sitevisit. The staff's search did not produce any evidence of major channel diversion of the North

Anna River. Channel diversions usually occur in relatively flat, deep alluvial plains where the

river channel meanders greatly. The North Anna watershed upstream of the dam lies in the

Piedmont Physiographic Province, a rolling to hilly area, underlain mostly, by metamorphosed

sedimentary and crystalline rocks. These rocks are relatively resistant to erosion. Because of

these physiographic features, the staff concludes that channel diversion above Lake Anna is

not likely.

Section 2.4.7 of this SER evaluates channel diversion caused by ice effects, and Section 2.4.11

of this SER evaluates the resulting low-water conditions.

In response to RAI 2.4.9-1, the applicant provided details of topographic and geomorphologic

interpretations carried out using USGS topographic maps and pre-dam aerial photographs.

The applicant concluded that diversion of North Anna River from its present drainage pattern is

extremely remote. The staff concluded that the applicant has provided sufficient information to

address this issue, and this information supports the above staff conclusion.

2.4.9.4 Conclusions-.

As set forth above, the applicant has provided information pertaining to channel diversions

showing that channel diversion above Lake Anna is not likely. Therefore, the staff concludes

that the'applicant has met the requirements regarding channel diversions, with respect to

10 CFR Part 50, 10 CFR 52.17(a), 10 CFR 100.20(c), and 10 CFR 100.21(d). Further, the

applicant has considered the most severe natural phenomena that have been historically

reported for the site and surrounding area with sufficient margin for-the limited accuracy,

quantity, and period of time in which the historical data have been accumulated in establishing

that channel diversion -is not likely at this site.

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I - IDI

2.4.10 Flooding Protection Requirements

The proposed ESP site grade is at an elevation of 271 ft MSL.

2.4.10.1 Technical Infornation in the Application

In SSAR Sections 2.4.2 and 2.4.3, the applicant estimated the design-basis flood elevation at

the ESP site to be 267.39 ft MSL. This elevation includes the effects of flooding caused by a

PMF resulting from a PMP over the North Anna Dam's drainage area, wind setup, and wave

runup. The applicant stated that all safety-related SSCs for the proposed additional units would

be placed at or above the existing site grade of 271 ft MSL. The applicant therefore concluded

that the ESP site does not require any safety-related flood-protection facilities.

In SSAR Sections 2.4.2 and 2.4.10, the applicant stated that the drainage design for the ESP

site would consider the effects of intense local precipitation. Safety-related facilities associated

with the ESP units would be designed to withstand the peak discharge resulting from local

intense precipitation. In addition, the applicant'stated that new facilities would incorporate

measures to ensure that flooding as a result of either construction or operation of the proposed

additional units would not compromise the existing units' safety-related facilities.

2.4.10.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

10 CFR 50.55a, GDC 2, 10 CFR 52.17(a), and 10 CFR 100.20(c) and the applicable regulatory

guidance as RGs 1.29, 1.59, 1.70, 1.102, and 1.125. The staff reviewed this portion of the

application for conformance with the applicable regulations, and considered the corresponding

regulatory guidance, as identified above, with the exception that an ESP applicant need not

demonstrate compliance with the GDC or with 10 CFR 50.55a. Acceptance criteria for this

section relate to 10 CFR Parts 52 and 100, insofar as they require that hydrological

characteristics be considered in the evaluation of the site. Specifically, the regulations at

10 CFR 52.17(a) and 10 CFR 100.20(c) require that physical characteristics of the site

(including seismology, meteorology, geology, and hydrology) be taken into account to

determine the acceptability of a site for a nuclear reactor.

The regulation in 10 CFR 100.20(c) requires that the PMF be estimated using historical data.

Meeting this requirement provides reasonable assurance that the effects of flooding or a loss of

flooding protection resulting from severe natural phenomena would pose no undue risk to the

type of facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

To determine whether the applicant met the requirements of 10 CFR Parts 52 and 100, as they

relate to flooding protection, the staff used the following specific criteria:

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* The applicability (potential adverse effe6ts) of a loss of flooding protection should be

described.

* Historical incidents of shore erosion and flooding damage should be discussed.

* The topography and geology of the basin and its applicability to damage as a' result of

flooding should be addressed.

* If applicable, the safety consequences of a loss of flooding protection'and the potential

to' adversely affect safety-related facilities, water supply, or th6'UHS should be

addressed. RG 1.27 provides guidance on acceptable UHS criteria.

2.4.10.3 Technical Evaluation

During its review of SSAR Sections 2.4.2 and 2.4.3, the staff estimated the design-basis flood

elevation to be 270 ft MSL. The staff estimated local, intense precipitation for the ESP site to

be 18.3 in./hr. Table 2.4.2-1 in Section 2.4.2 of this SER provides the complete hyetograph (a

chart or graphic representation of the average distribution of rain over the site surface area) for

the 6-hour local, intense precipitation.

Since the ESP site grade (at an elevation of 271 ft above MSL) is higher than the design-basis

flood elevation (270 ft MSL), flood protection requirements do not apply. In the DSER,

however, the staff indicated that safety-related SSCs that may be constructed on the proposed

site should be constructed with ingress and egress openings located above the elevation of

271 ft MSL to ensure they are protected from flooding. The staff intended to ensure protection

of safety-related SSCs from flooding by specifying minimum ingress and egress elevation in

DSER Permit Condition 2.4-9 and to include the grade elevation as a site characteristic in any

ESP that might be issued for the proposed site. -However, the staff determined that DSER -

Permit Condition 2.4-9 is'unnecessary since any ESP that might be issued will include a site

characteristic specifying the maximum water surface elevation and any application referencing

such an ESP should demonstrate that the proposed design bounds this site characteristic. This

will ensure that all SSCs will be protected from flooding. Accordingly, COL Action Item 2.4-4

and COL Action Item 2.4-5, as described in Section 2.4.2.3 of this SER, provide for the review

of specific design and engineering details of SSCs for flooding protection according to NRC

regulations and regulatory guidance atthe'COL or CP stage.:

The need to protect the slope embankment at the intake location is based on the potential for

degradation resulting from water and wave action. Through DSER Permit Condition 2.4-10, the

staff intended to provide erosion protection to protect the slope embankment. However, the

staff determined that it is sufficient for any'COL or CP applicant to address the issue of slope

embankment protection during design of the intake structure. This is COL Action Item 2.4-9.

In its review of a CCL or CP application that-references any' ESP that might be issued, the staff

will evaluate the design of the intake structure in accordance with NRC regulations and

regulatory guidance.

Any COL or CP. applicant will ensure'that the flood control measures protecting the safety-'

related facilities of the existing units will not be compromised during construction or operation of

the proposed units. The staff intended to ensure flood protection of the existing units' SSCs

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I[n

during construction and operation of the ESP unit by imposing DSER Permit Condition 2.4-11.

However, the staff determined that 10 CFR 50.59 requires the licensee of the existing units to

evaluate changes to flood protection provisions, which are described in the existing units' final

safety analysis reports. Since the current licensee controls access to the exclusion area, as

described in Section 2.1.2 of this SER, the holder of any ESP issued for the North Anna site,

and any COL or CP applicant referencing such an ESP will be able to construct and operate a

new unit only in accordance with the terms of an agreement with the licensee of the existing

units. The licensee of the existing units is obligated to satisfy the provisions of 10 CFR 10.59,

and it will ensure that such an agreement reflects the results of the evaluations performed

pursuant to 10 CFR 50.59. Accordingly, the requirements of Part 50 will ensure that any

changes to the existing units' flood protection measures resulting from construction on the ESP

site will be adequately controlled. Therefore, DSER Permit Condition 2.4-11 is unnecessary.

2.4.10.4 Conclusions

As set forth above, the applicant has provided information pertaining to flooding protection

requirements showing that the design-basis flood elevation is below the proposed grade of the

ESP PPE (site footprint), and no flood protection measures are needed. Therefore, the staff

concludes that the applicant has met the flood protection requirements with respect to

10 CFR 52.17(a) and 10 CFR 100.20(c). Further, in making this demonstration, the applicant

has considered the most severe natural phenomena that have been historically reported for the

site and surrounding with sufficient margin for the limited accuracy, quantity, and period of time

in which the historical data have been accumulated.

2.4.11 Low-Water Considerations

The site is adjacent to Lake Anna, which provides the cooling water for the current and

proposed units. Events that may potentially reduce or limit the availability of cooling water at

this site include low lake level, seiches, wind-induced set down, and intake blockages from

sediment or from ice.

The normal cooling water supply for non-safety-related needs of the proposed units would be

obtained from Lake Anna, created by the North Anna Dam. The UHS underground storage

basins, if the selected plant design includes a UHS, would provide a 30-day supply of

emergency cooling water. The applicant stated that the UHS storage basins would be

maintained full and are not dependent upon the water level in Lake Anna for their safety

function.

The applicant stated in SSAR Section 2.4.11.1 that for the new units, the anticipated minimum

lake level for operation would be the same as the existing units, at elevation 242.0 ft MSL. A

lake water level below 242.0 ft MSL could warrant a shutdown of the new and exiting units,

however, it would not impact safety-related systems since the water supply from the lake is

used only for normal cooling of non-safety-related systems.

Normal operation for the proposed Unit 3 would use a once-through cooling system, operated

with water drawn from Lake Anna. The applicant's March 31, 2004, letter to the NRC states

that the normal operation cooling system for proposed Unit 4 would use dry cooling towers.

Underground water storage basins would supply the proposed UHS for both proposed units, if

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the selected plant design includes a UHS. The applicant subsequently revised the SSAR to be

consistent with the statements made in this letter.

2.4.11.1 Technical Infornation in the Application

To determine the impact of new units on Lake Anna water levels, the applicant considered, in

SSAR Section 2.4.11, constraints on water availability resulting from low flow in streams,

seiches, drought, and from future controls.: In SSAR Section 2.4.11.4, the applicant cited its

water budget calculation that estimates the lake elevation changes associated with the addition

and operation of the proposed Unit 3, which are included in the environmental report,

Section 5.2.2. This water budget analysis considers the impact of induced evaporation

associated with the proposed Unit 3 cooling system, and it provides information on the

frequency and magnitude of low-water conditions in the lake. . -

In RAI 2.4.11-1, the staff requested information regarding critical ambient conditions, such as

air temperature and relative humidity; which might limit operation of a UHS if included in the

design. The staff also requested information regarding the meteorological conditions that might

constrain the safety-related cooling tower design of the new units. In its response, the applicant

referred to its response to the same question in RAI 2.3.1-1. In its response to RAI 2.3.1-1, the

applicant identified the controlling parameters as the wet-bulb temperature and coincident drybulb temperature for the type of UHS being considered for Unit 3, which could be a mechanical

draft cooling tower over a buried water storage basin or other passive water storage-facility,

depending on the design selected at the COL or CP stage. The applicant also stated that the

meteorological conditions that would result in the maximum evaporation and drift loss of water

from an engine6red UHS and the corresponding minimum cooling from such a UHS are the

critical wet and dry-bulb conditions for the UHS cooling tower design.

In Section 2.4.11.3 of the SSAR, the applicant stated that the minimum'observed Lake Anna

water surface elevation was 245.1 ft MSL on October 10,- 2002:. This low-water level followed

the driest September to August period and the third driest October to September period in the

108-year record for Virginia's statewide precipitation.

In SSAR Section 2.4.11.4, the applicant provided the results of a water budget analysis to

estimate the lake levels, which is described in further detail in Section 5.2.2 of Part 3 of the

applicant's environmental report. With all four units operating, the applicant estimated the

minimum lake level to be 242.6 ft MSL. In SSAR Section 2.4.11.1, the applicant stated that the

shutdown threshold level for the existing Uinits is an elevation of 244.0 ft MSL. The shutdown

threshold level for the'new units would be-an elevation of 242.0 ft MSL.' Section 2.4.11.3 of this

SER further discusses these two different shutdown threshold levels and the related minimum

lake elevations.

In RAI 2.4.11-2, the staff requested the applicant to describe likely upstream land-use changes

and changes in downstream water demand that could alter the frequency of low-flow conditions

and related minimum water elevation in Lake Anna. This RAI also asked the applicant to:

calculate the availability of cooling water during critical low-flow periods, including sufficient

margins to account for future urbanization of the watershed. In addressing this issue, the

applicant stated that its response to the staff's environmental RAI E4.2.2-2 describes the -

projected upstream development based on growth plans for the counties in the drainage area.

All three upstream counties (Louisa, Orange, and Spotsylvania) anticipate future growth in

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areas near existing towns. Increased development would impact low-flow conditions because

of increased ground water withdrawals and increased impervious areas. Decreased ground

water levels may lead to reduced baseflow to Lake Anna. The applicant stated that the

anticipated development is small compared to the size of the watershed and concluded that its

impact on low-flow conditions will be small. The applicant also concluded that the water

balance model presented in Section 5.2.2 of Part 3 of the environmental report would be

accurate, even after consideration of the impact resulting from upstream land-use changes.

The applicant described the margins available in the cooling water supply in its response to

RAI 2.4.1-1.

2.4.11.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

GDC 2 and 44, as well as 10 CFR 100.23(c), and identified the applicable regulatory guidance

as RGs 1.27 and 1.70, as well as RS-002. The staff reviewed this portion of the application for

conformance with the applicable regulations, and considered the corresponding regulatory

guidance, as identified above.

Acceptance criteria for this section relate to the following regulations and criteria:

* 10 CFR Parts 52 and 100 require that hydrologic characteristics be considered in the

evaluation of the site.

* 10 CFR 100.23 requires, in part, that siting factors to be evaluated must include cooling

water supply.

The regulations in 10 CFR Parts 52 and 100 require, in part, that hydrologic characteristics be

considered in the evaluation of a nuclear power plant site. In order to satisfy 10 CFR Parts 52

and 100, the applicant should describe in the SSAR the surface and subsurface hydrological

characteristics of the site and region. In particular, the UHS for the cooling water system may

consist of water sources affected by, among other things, site hydrological characteristics that

may reduce or limit the available supply of cooling water for safety-related SSCs. Site

hydrological characteristics that may reduce or limit the flow of cooling water include those

resulting from river blockage or diversion, tsunami runup and drawdown, and dam failure.

Meeting the requirements of 10 CFR Parts 52 and 100 provides assurance that severe

hydrologic phenomena, including low-water conditions, would pose no undue risk to the type of

facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

The regulation in 10 CFR 100.23 requires the evaluation of siting factors, including cooling

water supply. The evaluation of the emergency cooling water supply for a nuclear power plant

or plants of a specified type (or falling within a PPE) that might be constructed on the proposed

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site should consider river blockages, diversion, or other failures that may block the flow of

cooling water, tsunami runup and drawdown, and dam failures.

The regulation at 10 CFR 100.23'applies to this section because the UHS for the cooling water

system consists of water sources that are subject to natural events that may reduce or limit the A

available'supply of cooling water '(i.e., the heat sink).- Natural events, such as river blockages or

diversion or other failures that may block the flow of cooling water, tsunami runup and

drawdown, and dam failures, should be conservatively estimated to assess the potential for

these characteristics to influence the design of SSCs important to safety for a nuclear power

plant or plants of a type specified by the applicant (or falling within a PPE) that might be

constructed on the proposed site. The available water supply should be sufficient to meet the

needs of the plant or plants to be located at the site; those needs may fall within a PPE (e.g.,

the stored water volume of the cooling water ponds), if an applicant uses that approach.

Specifically, those needs include the maximum design essential cooling water flow; as well as --

the maximum design flow for normal plant needs at power and at shutdown. -

To meet the requirements of the hydrologic aspects of the above regulations, the specific

criteria discussed in the paragraphs below are used. Acceptance is based principally on the

adequacy of the UHS to supply cooling water for normal operation, anticipated operational

occurrences, safe shutdown, cooldown (first 30 days), and long-term cooling (periods in excess

of 30 days)'during adverse natural conditions.-,

Low Flow in Rivers and Streams

For essential water supplies, the low-flow/low-level design for the primary water supply source

is based on the probable minimum low flow and level resulting from the most severe drought

that can reasonably be considered for the region. The low flow and level site parameters for

operation should be such that shutdowns caused by inadequate water supply will not trigger

frequent use of emergency systems.

Low Water Resulting from Surges. Seiches. or Tsunami

For coastal sites, the appropriate PMH wind fields should be postulated at the ESP stage to

provide maximum'winds blowing offshore, thus creating a probable minimum surge level. Lowwater levels on inland ponds, lakes, and rivers caused by surges should be estimated from

probable maximum winds oriented away from the plant site. The same general analysis

methods discussed in Sections 2.4.3, 2.4.5,' and 2.4.6 of RS-002 are applicable to low-water

estimates resulting from the various phenomena discussed. If the site is susceptible to such

phenomena, minimum water levels resulting'from setdown (sometimes called runout or,

rundown) from hurricane surges,- seiches, and tsunami should be verified at the COL or CP

stage to be higher than'the-intake design basis for essential water supplies.

Historical Low Water

If historical flows and levels are used to estimate design values by inference from frequency

distribution plots, the data used should be presented so that an independent determination can

be made.' The data and methods of NOAA, USGS, SCS, USBR, and USACE are acceptable.

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[Mu

Future Controls

This section is acceptable if water use and discharge limitations (both physical and legal),

already in effect or under discussion by responsible Federal, regional, State, or local authorities,

that may affect water supply for a nuclear power plant or plants of a type specified by the

applicant that might be constructed on the proposed site have been considered and are

substantiated by reference to reports of the appropriate agencies. The design basis should

identify and take into account the most adverse possible effects of these controls to ensure that

essential water supplies are not likely to be negatively affected in the future.

2.4.11.3 Technical Evaluation

The applicant has stated that the proposed additional units will not rely on Lake Anna for safetyrelated water needs. Further, the applicant has proposed engineered subsurface water

reservoirs and mechanical cooling towers to fulfill UHS requirements, should the selected plant

design need a conventional UHS.

The staff has performed its review in accordance with the guidance in RS-002 regarding the

frequency of shutdown of operating units. Low upstream tributary inflow and minimum lake

elevations for the operation of all four units should be such that shutdowns caused by

inadequate water supply do not cause frequent use of emergency systems. Hydrologic

conditions that could lead to low lake elevations can be characterized as follows:

* gradual, such as a sustained drought

* abrupt and prolonged, such as failure of the North Anna Dam

* abrupt but temporary, such as hillslope failure

The technical evaluation in this section focuses on the gradual decrease in water elevation

associated with drought; Section 2.4.4 of this SER discusses abrupt and prolonged low-flow

conditions resulting from a failure of the North Anna dam. Section 2.4.6 addresses the abrupt

but temporary low-flow condition caused by a hillslope failure. Wave runup results in high water

level from a baseline pool level as the wave approaches the shore and a low water level as the

wave recedes from the shore. Declines in the lake elevation will be sufficiently gradual to

provide advance warning to properly respond to low-water conditions during which the UHS

would be used, except in the case of failure of the North Anna Dam.

The staff performed an independent analysis of the Lake Anna water budget under critical

conditions to estimate the extreme low-water elevation. The staff constructed a coupled water

budget and temperature model consistent with the limited available data. The water-budget

component of the model was based on a lumped representation of the conservation of mass.

The water temperature component of the model was a lumped, two-compartment

representation of the lake based on the conservation of energy. The water budget and

temperature components are linked through the evaporation process.

In this water-budget model, changes in lake storage over time were equal to the differences

between the inflows and the outflows. Inflows consist of runoff from drainage upstream of the

lake and precipitation occurring directly on the lake. Outflows consist of the natural and

induced evaporations and releases from the dam.

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The staff estimated inflows from the drainage upstream of the lake using data from an adjacent

drainage basin, the Little River drainage basin, adjusted for the difference in drainage areas:

The Little River drainage area comprises 107 mi2 adjacent to the North Anna drainage basin.

Based on a review of streamfiow records from USGS gauge 01671100 (Little River near

Doswell, Virginia), the staff selected the period from October 2001 to September 2002 as the

critical water year. The staff used precipitation records from the meteorological station at the

Richmond, Virginia, airport to estimate direct precipitation on the lake. -

The staff estimated outflows from the lake based on the current operating rules for the Lake

Anna Dam. The staff's analysis assumed that the current units and the additional unit 3

continue to operate until the lake water level falls below 242 ft MSL.

The staff estimated the evaporative loss from the ambient compartment of the lake from the

Massachusetts In'stitute of Technology model -(Ho, E: and E.E. Ada ms, 'Final Calibration of the

Cooling Lake Model for Nbrth Anna Power Station," Ralph M. Parsons Laboratory, Aquatic,

Science and Environmental Engineering,'Department of Civil Engineering, Massachusetts

Institute of Technology, Report No. 295, August, 1984). This model was empirically validated

through onisite observation for the licensing of NAPS Units 1 and 2 and is acceptable. The staff

derived the evaporative'loss from the fixed temperature compartment using the applicant's PPE

values. The staff performed'sensitivity analyses to assess the impact of various evaporative

loss assumptions.

The staff determined the minimum water surface elevation to be 242.6 ft MSL when the existing

units and the proposed Unit 3 are operating.' 'The staff estimated that water surface elevation in

the lake would fall to this minimum elevation only infrequently during low-water years. The

applicant has proposed a minimum water surface elevation of 242 ft MSL in SSAR

Section 2.4.11.1.

Since the applicant's proposed minimum Water surface elevation site characteristic is lower than

the staff's estimate, the applicant's value is acceptable.

In RAI 2.4.11-1, the staff requested that the applicant estimate the frequency of low-water

conditions that could result in use of the UHS. The staff further asked the applicant to describe

in greater detail the critical ambient conditions, such as combinations of temperature and

relative humidity, that might limit operations under low-water conditions. In its response, the

applicant only discussed the issue related to-evaporation loss from the UHS. .The applicant -

identified the meteorological conditions resulting in the maximum evaporation and drift loss of

water from the engine'ered UHS as the worst 30-day average combination of controlling

atmospheric parameters. IThe itaff's assessment of meteorological site characteristics is

included in Section 2.3 of this SER. - - -

The staff notes that, in addition'to evaporation losses, icing in a UHS storage basin, if included

in the selected plant design,' ray alsb result in limits on UHS operation to ensure the.availability

of sufficient water during freezing to supply both emergency and service water. The staff

determined, in Section 2.3.1.3 of this SER, that the 7-day average of low air temperature is

19.9 "F. In order to obviate the need for limits on the operation of the proposed units, any COL

or CP applicant should design the UHS storage capacity to accommodate ice formation at the

sustained low-air temperature of 19.9 "F. As discussed in Section 2.4.7 of this SER in

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, Ira

response to the issue raised by DSER Permit Condition 2.4-7, the staff included COL Action

Item 2.4-7, in which a COL or CP applicant referencing this ESP should address whether a

30-day cooling water supply will be available in the UHS storage basins to account for all

potential losses, including ice formation. The applicant's response to RAI 2.4.11-1 is

satisfactory, based on the discussion above.

Future land-use development, such as urbanization of the upstream Lake Anna watershed, may

lead to changes in consumptive water use. As an indicator of future development, the

population of Louisa County, where the site is located, grew 25 percent from 1979 to 2000, and

residential land use grew from 1.8 to 5.5 percent during the same period. Likely upstream landuse changes and changes in downstream water demand could alter the occurrence of low-flow

conditions and related minimum lake levels.

In RAI 2.4.11-2, the staff asked the applicant to describe likely upstream land use changes and

changes in downstream water demands that would likely alter the intensity or frequency of lowflow conditions and to calculate the availability of cooling water during critical low-flow periods.

In its response to RAI 2.4.11-2, the applicant indicated that upstream development is expected

to be small compared to the size of the watershed and will have only a small effect on low-flow

conditions. The applicant noted that its response to a similar question in RAI E4.2.2-2 provides

a description of the projected upstream development based on available county growth

management plans. In its response to RAI 2.4.11-2, the applicant stated that the availability of

cooling water during low-flow conditions has been considered in the water balance model

presented in Section 5.2.2 of the application and summarized in SSAR Section 2.4.11. The,

staff reviewed the applicant's response and determined that the applicant has adequately

discussed the effects of upstream land-use change in the drainage area. The applicant

identified cooling water needs that may lead to restrictions on the operation of future plants

because of changes in the frequency of low-flow conditions and related minimum water

elevation in Lake Anna. Any COL or CP applicant should identify the most restrictive cooling

water needs to account for the frequency of low flow conditions and related minimum water

elevation in Lake Anna and propose corresponding actions to account for such conditions. This

is COL Action Item 2.4-10, previously identified as DSER COL Action Item 2.4-1. The

applicant's response to RAI 2.4.11-2 is satisfactory, based on the discussion above.

2.4.11.4 Conclusions

As set forth above, the applicant has provided information pertaining to low-water

considerations, including hydrologic conditions that could lead to low lake elevations, conditions

that could result in use of a UHS, and potential effects of upstream land-use change in the

drainage area. Therefore, the staff concludes that the applicant has met the requirements

related to low-water considerations with respect to 10 CFR 52.17(a) and 10 CFR 100.20(c).

Further, the applicant has considered the most severe natural phenomena that have been

historically reported for the site and surrounding area with sufficient margin for the limited

accuracy, quantity, and period of time in which the historical data have been accumulated in

establishing low-water conditions for use in design.

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2.4.12 Ground Water

NAPS is located in the Piedmont Physiographic Province in an area underlain by crystalline

bedrock. The' powerblock for the proposed additional units would be sited on soil that was

disturbed during construction of the now-abandoned NAPS Units 3 and 4. Further disturbance

of the subsurface environment is expected during construction of the proposed additional units.

2.4.12.1 Technical Infornation in the Application:

In SSAR Section 2.4.12, the applicant provided a description of regional hydrogeology and

ground water conditions based on reports prepared by USGS, EPA, and the Commonwealth of

Virginia. In a generalization to the Piedmont Physiographic Province, Trapp and Horn ("Ground

Water Atlas'of the United States, Segment 1 1, Delaware, Maryland, New Jersey, North

Carolina, Pennsylvania, Virginia, West Virginia," USGS, Hydrologic Investigations Atlas 730-L,

1997) characterize the bedrock as' almost impermeable" and as yielding "water primarily from

secondary porosity and permeability provided by fractures." Water occurs primarily in a regolith

(a layer of weathered, heterogeneous material overlying bedrock) of variable thickness. In -

discussing the hydrogeology of areas underlain by crystalline bedrock,- Trapp and Horn state

that the porosity of the regolith ranges between 20 and 30 percent, while the porosity of thebedrock is about 0.01 to 2 percent. Most fractures in the bedrock are steeply inclined, while

"the size, number, and interconnection of the fractures decreases with depth." Recharge to the

aquifers in the Piedmont Physiographic Province occurs primarily from infiltration. Within the

subsurface, water tends to follow the topography, moving from upland recharge areas to

discharge areas at lower elevations.

The applicant based most of its description of local hydrogeology at the North Anna site on

previous site investigations. In addition, the'applicant conducted more recent site sampling and

analysis as part of its subsurface investigation program. The applicant drilled seven boreholes

(B01 to B07) and installed nine observation wells (OW-41 to OW-49) as part of this program.

The applicant stated that the subsurface consists of five zones-the crystalline parent rock,

weathered rock, two zones of saprolite (altered and weathered bedrock caused by continual*

exposure to moisture still in place) distinguished by the amount of core stone in each zone, and

residual soils. The borehole logs identify a sixth material, the fill, which occurs in the area near

the abandoned Units 3 and 4. The applicant screened eight of the observation wells in the

unconsolidated materials (residual soil, saprolite, or weathered rock) and one in the parent rock.

Previous studies (e.g., Revision 38 of the NAPS UFSAR) predicted that maximum ground water

elevations beneath the site inthe existing plant area could reach 265 to 270 ft MSL based on a

uniformly sloping water table'from 271 ft MSL at the toe of the slope south of abandoned

Units 3 and 4 to the 250 ft MSL elevation of Lake'Anna. Figure 2.4-16 in the SSAR shows that

water levels in new wells, OW-844 and OW-841, vary from about 267 ft MSL-(at OW-844) to

250 ft MSL (at OW-841). The applicant used these measurements to support a design ground

water level of 265 to 270 ft MSL in the PPE (site footprint) of the ESP site.

The applicant conducted slug tests in the newly installed wells to provide estimates of saturated

hydraulic conductivities. Saturated hydraulic conductivities for the wells drilled into the

unconsolidated subsurface zone'range from 0.2 to 3.4 ft/d. The'slug test failed conditions set

by the Bouwer-Rice method ("A Slug Test Method for Determining Hydraulic Conductivity of

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LZ2

Unconfined Aquifers with Completely or Partially Penetrating Wells, Water Resources

Research, Vol. 12, No. 3, pp. 423-428, 1976) for the well screen into the consolidated rock

because of the short duration of stable data. This is frequently the case in consolidated rock.

The applicant estimated the hydraulic conductivity using available slug test data and presented

the results in SSAR Table 2.4-16. The saturated hydraulic conductivity values reported for this

well are 1.8 to 3.1 ft/d.

SSAR Figure 2.4-15 depicts ground water levels between December 2002 and June 2003. The

staff requested, in RAI 2.4.12-1, that the applicant update this figure with piezometer data from

June 2003 to September 2003 and piezometer data before December 2002, if they exist, or

explain how this span of data represents the seasonal variation in ground water levels. The

staff also asked the applicant to explain how the ESP subsurface investigation program is

consistent with previous ground water measurements. In its response, the applicant stated that

it would update SSAR Table 2.4-15 and Figure 2.4-15 to include ground water level

measurements taken at the North Anna site on September 29, 2003. The applicant also

concluded that the quarterly measurements recorded for the ESP application appear to

generally reflect the magnitude of ground water level fluctuation on a yearly basis. Further, the

applicant noted that maximum ground water level fluctuations are likely to occur over much

longer periods of time and may be about 60 percent greater than those measured during the

1-year ESP recording period.

2.4.12.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of the applicant's conformance to NRC

regulations and regulatory guidance. The applicant identified the applicable regulations as

10 CFR 52.17(a), 10 CFR 100.20(c), 10 CFR 100.23, and 10 CFR 100.23(c) and the applicable

regulatory guidance as RGs 1.27,11.29, and 1.70, as well as RS-002. The staff reviewed this

portion of the application for conformance with the applicable regulations, and considered the

corresponding regulatory guidance, as identified above.

Acceptance criteria for this section relate to the following regulations and criteria:

* 10 CFR Parts 52 and 100 require that hydrologic characteristics be considered in the

evaluation of the site.

* 10 CFR 100.23 sets forth the criteria to determine the suitability of design bases for a

nuclear power plant or plants of a specified type (or falling within a PPE) that might be

constructed on the proposed site with respect to seismic characteristics of the site. It

also requires that siting factors, including the cooling water supply, be evaluated, taking

into account information concerning the physical, including hydrological, properties of

the materials underlying the site.

As specified in 10 CFR 100.20(c), the site's physical characteristics (including seismology,

meteorology, geology, and hydrology) must be considered when determining its acceptability

for a nuclear power reactor.

The regulation at 10 CFR 100.20(c)(3) requires that factors important to hydrological

radionuclide transport be addressed using onsite characteristics. Pursuant to the hydrologic

requirements of 10 CFR Part 100, the SSAR should describe ground water conditions at the

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proposed site and how the construction and operation of a nuclear power plant or plants of a

specified type that might be constructed on the site will affect those conditions. Meeting this

guidance provides reasonable assurance that the release of radioactive effluents from a plant

or plants of a specified type that might be constructed on the proposed site will not significantly

affect ground water at or near a proposed site.

The regulation at 10 CFR 100.23 requires that geologic and seismic factors be considered

when determining the suitability of the site for each nuclear power plant. In particular,

10 CFR 1 00.23(d)(4) requires that such factors as the physical properties of materials

underlying the site and cooling water supply be evaluated. The regulation at 10 CFR 100.23 is

applicable to SSAR Section 2.4.12 because it addresses requirements for investigating the

hydrologic conditions at and near the site.

Meeting this guidance provides reasonable assurance that the effects of a safe-shutdown

earthquake would pose no undue risk to the type of facility proposed for the site.

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison with the hydrologic

characteristics of the site. A PPE.can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

To determine whether the applicant met the requirements of the hydrologic aspects of 10 CFR

Parts 52 and 100, the staff used the following specific criteria:

* - A full, documented description of regional and local ground water aquifers, sources, and

sinks is necessary. In addition, the type of ground water use, wells, pump; and storage

facilities, as well as the flow needed for a nuclear power plant or plants of a specified

type (or falling within a PPE) that might be constructed on the site, should be described.

If ground water is to be used as an essential source of water for safety-related

equipment, the design basis for protection from natural and accident phenomena should

be compdred with the RG 1.27 guidelines. Bases and sources of data should be

adequately described and referenced.

A description of present and projected local and regional ground water use should be

provided. Existing uses, including amounts, water levels, location, drawdown, and-

-source aquifers should be discussed and tabulated. --Flow directions, gradients,

- velocities, water levels, and effects of potential future use on these parameters,

including any possibility for reversing the direction of ground water flow, should beindicated. Any potential ground water recharge area within the influence of a nuclear

power plant or plants of a specified type (or falling within a PPE) that might be -

constructed on the site and the effects of construction, including dewatering, should be

identified. The influence of existing and potential future wells with respect to ground

water beneath the site should also be discussed. Bases and sources of data should be

described and referenced. References 6 through 12 of RS-002 discuss certain studies

concerning ground water flow problems. -:

The need for and extent of procedures and measures to protect present and projected

ground water users, including monitoring programs, should be discussed. These items

are site specific and will vary with each application.

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2.4.12.3 Technical Evaluation

As set forth below, the staff determined that the SSAR adequately describes onsite and offsite

ground water use. The site is located adjacent to Lake Anna. Lake Anna and other water

bodies exist between the ESP site and the nearest offsite ground water users. This spatial

relationship and the relatively small withdrawal rates, both onsite and offsite, contribute to the

hydrological isolation of the ESP site from offsite ground water users.

The applicant conducted slug tests in the newly installed wells to provide estimates of saturated

hydraulic conductivities. The staff determined that the method the applicant used, as set forth

in the SSAR, to estimate the saturated hydraulic conductivities (i.e., the Bouwer-Rice method)

is appropriate because this is a well-established method that is widely accepted in standard

engineering practice. While the estimate of hydraulic conductivity derived with the Bouwer-Rice

method is appropriate for shallow unconsolidated strata, the failure to satisfy the constraints of

the Bouwer-Rice method in well tests in the deeper consolidated strata is consistent with

conditions in which the movement of water is limited to flow in fractures. The hydraulic

conductivities in the shallow unconsolidated strata will bound the dominant subsurface transport

pathways, because ground water flow in deeper consolidated strata can only pass through

fractures and fissures.

Observed increases in water levels in the new wells ranged from less than 1 ft to more than 3 ft

over the period of December 17, 2002, through June 17, 2003. The applicant included

previously existing wells monitored at the same time in the analysis. The observed variation in

water levels in wells could be significant but represents only a 6-month period. The staff

evaluated additional information the applicant provided in response to RAI 2.4.12-1 but found

that it needed additional data to determine whether the new ground water level measurements

correlate with data from the long-term piezometers. Ground water measurements should

contain at least 1 full year of data to determine recent seasonal fluctuation in ground water

levels at the ESP site. The staff was also concerned that the ground water measurements

provided by the applicant may have been made too soon following the 2001-2002 drought, and

may still show some influence of the drought as the ground water elevations recovered near

their pre-drought levels. This was Open Item 2.4-7.

In response to Open Item 2.4-7, the applicant provided additional ground water measurements*

to the staff in its March 3, 2005, submittal. The applicant provided another set of ground water

elevations previously measured on September 29, 2003. This additional set, along with the

ground water elevation measurements on December 17, 2002, March 17, 2003, and June 17,

2003 represented the seasonal variation in ground water elevations at the ESP site on a

quarterly basis. The applicant also carried out a new set of ground water measurements on

February 1, 2005, in nine observation wells and ten piezometers. In addition to the ground

water measurements, the applicant also provided the water surface elevation in Lake Anna on

February 1, 2005. Based on this additional measurement, the staff concludes that ground

water elevations measured during the 2002-2003 water year did not show influences of the

2001-2002 drought, and were therefore suitable for characterization of ground water elevations

and gradients at the ESP site. The applicant estimated a horizontal hydraulic gradient of 0.029

ft/ft from the center of the ESP site footprint to Lake Anna based on February 1, 2005,

measurements. Since this estimate is slightly smaller than applicant's estimate of 0.03 ft/ft

presented previously in the SSAR, the applicant concluded that the horizontal hydraulic gradient

was not underestimated because of the 2002 drought.

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Based on the additional ground water data, the staff verified the horizontal ground water

gradient estimated by the applicant. The staff used the difference between the ground water

elevation measured at observation well OW-846 and the water surface elevation of Lake Anna

on February 1, 2005, to estimate a horizontal hydraulic gradient of 0.023 ft/ft based on an

estimated distance of 1160 ft from observation well OW-846 to Lake Anna. Since the

applicant's estimate of the horizontal hydraulic gradient is greater, and therefore'more

conservative than that estimated by the staff, it is deemed acceptable. -The staff also

determined that the additional data describing seasonal variations of well water elevations

presented in the applicant's February 1, 2005, response adequately characterize seasonal

fluctuations in ground water levels at the ESP site.

Based on the above review, the staff considers Open Item 2.4-7 to be resolved.

Ground water discharge to streams and to Lake Anna is significant, ranging from 32 to

67 percent of streamflow, according to several studies conducted in the province cited by Trapp

and Horn. The staff was unable to independently estimate the ground water flowpath from the

powerblock of the proposed additional units to Lake Anna since the applicant did not initially

provide the precise location of the powerblock. In the following assessment, the staff used

applicant-provided values for effective porosity and-distance from the powerblock to Lake Anna.

The staff used the following relationship to determine average ground water velocity:

Velocity = Hydraulic Gradient x Saturated Hydraulic Conductivity/Effective

Porosity

The applicant used the geometric mean of the measured hydraulic conductivity values (1.3 ft/d).

Use of the geometric mean is not conservative because it results in slower ground water

velocity and increased travel time to the environment. Using 3.4 ft/d (SSAR Section 2.4.12.1.2)

as the conservative value for hydraulic conductivity, 3 ft/1 00 ft as the hydraulic gradient, and

0.33 as the effective porosity, the staff estimated the ground water velocity to be 0.31 ft/d, as

opposed to 0.12 ft/d as reported by the applicant. The staff's calculated travel time from the

powerblock to the lake, using 1800 ft as the -distance to the environment, is approximately -

16 years, as opposed to the applicant's estimate of 40 years. 'In the DSER, the staff indicated

that the applicant needed to explain why it did not use a more conservative hydraulic

conductivity. This was Open Item 2.4-8. The staff 'intends to identify hydraulic conductivity as a

site characteristic in any ESP that the NRC might issue for this application.

In response to Open Item 2.4-8, the applicant agreed in its March 3, 2005, -submittal, to use the

conservative value of 3.4 ft/d for hydraulic conductivity as the site characteristic. This value is

conservative because it is the maximum hydraulic conductivity calculated for the saprolite, for

which conductivity ranges from about 0.2 to 3.4 ft/d. The generally accepted industry practice -

is to use the average hydraulic conductivity of the saprolite. Based on the applicant's response,

the staff considers Open Item 2.4-8'resolved.

The applicant's response to RAI 2.4.1 -1 includes a figure that lists the coordinates of the '

corners of the ESP PPE (site footprint). However, as discussed in Section 2.4.1.3 of this SER,

the staff indicated in the DSER that it needed additional information regarding the reference

system and the units of these coordinates to determine the distance from the powerblock to the

lake. Consequently, the staff identified the need for information on the coordinate system for

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the ESP site boundaries in Open Item 2.4-1. This open item was resolved when the applicant

provided the coordinates of the corners of the ESP PPE (ESP site footprint) which is based on

the North Anna plant site coordinate'reference system. The coordinate system units are "feet."

The applicant proposed a site characteristic of ground water elevation less than 270 ft MSL,

and it proposes an ESP plant grade (PPE value) of 271 ft MSL. The applicant identified the

general location of the proposed additional units in Figure 2.4-16. Based on the ground water

level data presented in SSAR Figure 2.4.16 and the UFSAR, the staff concludes that the

applicant's design elevations are adequate from the perspective of the location of the water

table, if the proposed additional units are constructed within the area where the ground water

levels do not exceed 270 ft MSL. The staff intended this requirement, proposed in DSER

Permit Condition 2.4-12, to constrain the location of the proposed units toward the northeast

corner of the proposed footprint. Ground surface elevations at the ESP site generally increase

from its northeast corner near Lake Anna to the southwest. As described in the SSAR, the

ground water levels also approximately follow the undulations of the ground surface, varying

from about 250 ft MSL near Lake Anna in the northeast corner of the ESP site footprint to over

300 ft MSL near the southwest'corner. The ground water levels at the ESP site footprint could

rise as high as 1 ft below the ground surface. The maximum elevation of ground water is a site

characteristic and the value is set at 270 ft MSL or 1 ft below the free surface, whichever is

higher. The staff determined that it is unnecessary to impose DSER Permit Condition 2.4-12

since it will review and evaluate any future plant design in accordance with NRC regulations and

regulatory guidance to ensure the safety of any future plant that may be constructed within the

ESP site footprint.

With respect to 10 CFR 100.23(d), the applicant is not proposing to use ground water for

cooling water. Accordingly, hydraulic conditions in groundwater are of no concern with respect

to cooling water supplies.

2.4.12.4 Conclusions

As set forth above, the applicant has provided sufficient information pertaining to ground water.

Therefore, the staff concludes that, the applicant has met the requirements related to ground

water in 10 CFR 52.17(a), 10 CFR 100.23, and 10 CFR 100.20(c)(3).

2.4.13 Accidental Releases of Liquid Effluents to Ground and Surface Waters

The North Anna site is located within the Piedmont Physiographic Province in an area underlain

by crystalline bedrock. The powerblock for the proposed additional units would be sited on soil

disturbed during construction of the now-abandoned NAPS Units 3 and 4.

2.4.13.1 Technical Infornation in the Application

In SSAR Section 2.4.13, the applicant stated that all analysis of accidental releases to ground

and surface waters would be deferred to the COL stage. However, pursuant to

10 CFR 52.17(a)(1) and 10 CFR 100.20(c)(3), the applicant is required at the ESP stage to

obtain factors for applicable hydrological radionuclide release pathways for a site-suitability

determination. The staff requested, in RAI 2.4.13-1, that the applicant provide a conceptual

model of the subsurface environment, with reference to drill logs, as-built fill, and compaction

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plans. The staff stated that the subsurface conceptual model should provide estimates, and the

basis for these estimates, for the hydraulic conductivity of the soil, surface recharge rates, soil

and ambient ground water chemical properties, and piezometric boundary conditions. In its

response, the applicant stated that it developed a conceptual model of the subsurface for the

ESP site, based primarily on data presented in the ESP application and supplemented by other

published data. The applicant obtained data included in the ESP application from site-specific

subsurface investigations and from published sources.

The applicant stated that the ground surface at the existing units and some parts of the ESP

site are located at an elevation of 271 ft MSL. The ground surface rises-to an elevation of over

300 ft MSL to the west and to the south of the ESP site. The ESP site is filled with fabricated

material, residual soil, or saprolite. The powerblock area of the abandoned Units 3 and 4 was

partially filled. The applicant stated that existing fill and residual soil would be removed from the

ESP site before any future construction.

The applicant stated that saprolite overlies bedrock at the NAPS site. Based on drilling results

at the site, saprolite ranges in thickness from 2 to 102 ft. The saprolite at the NAPS site varies

in its lithology (structure, composition, color, and texture), depending on its parent material and

its degree of weathering, and it may be classified into the categories of sand, silty-sand, clayey

sand, sandy silt, clayey silt, and clay. The bedrock beneath the ESP site, which belongs to

Cambrian (about 500-540 million years (Ma) ago) and Ordovician age (about 443-490 Ma) --

Ta River Metamorphic Suite, is at depths ranging from 8 to 49 ft and consists of mostly quartz

gneiss with variable weathering with joints and fractures. These joints and fractures have clay

filling.

The applicant stated that ground water beneath the ESP site occurs in unconfined conditions,

both in saprolite and in bedrock. Saprolite and bedrock are hydrologically connected to each

other. The applicant measured potentiometric head difference between the bedrock and the2-

saprolite at only one location (between wells OW-845 and OW-846 in Figure 5 of Dominion,

"Supplemental Response to Request for Additional Information No. 4," August 19, 2004. The

measured head difference is 0.3 ft, with an upward hydraulic gradient.

The applicant prepared a piezometric head contour map (Figure 5 of the same RAI response)

using ground water levels measured in March 2003. The applicant concluded from this contour

map that ground water flow across the ESP site is to the north and east towards Lake Anna,

-with a hydraulic gradient of about 0.03 ft/ft. -The applicant stated that this gradient is expected

to be typical of ground water flow at the ESP site, despite seasonal and long-term fluctuations

caused by the controlling influence of Lake Anna and surrounding drainages. ; -

The applicant provided a conceptual hydrogeologic model based on site investigation. The

primary system for migration of radionuclides is ground water flow in unconsolidated deposits

(i.e., the saprolite) and in the bedrock. Ground water in saprolite is stored and is transmitted

through the pore spaces. In the crystalline bedrock, ground water is stored and is transmitted

through joints and fractures. The number, extent, and opening width of joints and fractures are

expected to decrease with depth, thus limiting significant water transmission in the bedrock to

its upper few hundred feet.

The applicant stated that recharge to the aquifers at the NAPS site occurs largely as infiltration

of rainfall and snowmelt. Average annual precipitation in the NAPS area is about 44 in., and

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average annual recharge is estimated to be 8 to 10 in. A minor source of recharge to the

ground water at the NAPS site is the clay-lined service water reservoir for the existing NAPS

units. Infiltration of water from the service water reservoir locally alters ground water levels. A

series of underdrains beneath the existing pumphouse for Units 1 and 2 controls ground water

levels, as well. Some ground water discharge occurs through the five active water supply wells

and four minor wells, and some evapotranspiration occurs at the foundation area for the

abandoned Units 3 and 4.

The applicant stated that ground water underlying the ESP site is expected to be in hydrologic

connection with Lake Anna. Therefore, the water level in Lake Anna serves as a piezometric

boundary condition for ground water flow towards the lake. The ground water flow at the ESP

site discharges to Lake Anna and the WHTF. The applicant stated that a ground water divide is

expected to exist upgradient of the ESP site and to approximately coincide with the topographic

divide.

The applicant stated that no site-specific data are available to determine the chemical

characteristics of ground water at the ESP site. The applicant assumed that the water quality of

crystalline aquifers in the Piedmont Physiographic Province is representative of the water

quality at the ESP site.

The applicant stated that, in case of an accidental release of liquid radioactive material at the

ESP site, the contaminants will infiltrate to the ground water table and then flow laterally with

regional ground water flow towards Lake Anna and the WHTF. Depending upon the location of

the accidental release with respect to water supply wells, contaminants may impact some wells.

The applicant stated that no offsite ground water users would be impacted as a result of the

direction of ground water flow and the presence of ground water boundary conditions between

the ESP site and these users. Finally, the applicant stated that a detailed numerical model will

be developed as part of any COL application to be submitted for the proposed ESP site.

2.4.13.2 Regulatory Evaluation

Section 1.8 of the SSAR presents a detailed discussion of how the applicant proposes to

conform to NRC regulations and regulatory guidance. The applicant identified the applicable

regulations as Appendix B, "Annual Limits on Intakes (ALls) and Derived Air Concentrations

(DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations

for Release to Sewerage," to 10 CFR Part 20, "Standards for Protection Against Radiation," and

10 CFR Part 100 and the applicable regulatory guidance as RGs 1.27, 1.70, and 1.1 13,

"Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for

the Purpose of Implementing Appendix I," Revision 1 dated April 1977 as well as RS-002. The

staff reviewed this portion of the application for conformance with the applicable regulations,

and considered the corresponding regulatory guidance, as identified above.

Acceptance criteria for this section relate to 10 CFR Parts 52 and 100, as they require the

evaluation of the hydrologic characteristics of the site with respect to the consequences of the

escape of radioactive material from the facility.

The regulations in 10 CFR Parts 52 and 100 require that local geological and hydrological

characteristics be considered when determining the acceptability of a nuclear power plant site.

The geological and hydrological characteristics of the site may have a bearing on the potential

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consequences of radioactive materials escaping from a nuclear power plant or plants of a

specified type (or falling within a PPE) that might be constructed on the proposed site. Special

precautions should be planned if a reactor or reactors were to be located at a site where a

significant quantity of radioactive effluent could accidentally flow into nearby streams or rivers or

find ready access to underground water tables. '

These criteria apply'to SSAR Section 2.4.13 because site hydrologic characteristics are

evaluated with respect to the potential consequences of radioactive materials escaping from a

nuclear power plant or plants of a specified type (or falling within a PPE) that might be

constructed on the proposed site. The staff reviews radionuclide transport characteristics of

ground water and surface water environments with respect to accidental releases to ensure that

current and future users of ground water and surface water are not adversely affected by an

accidental release from a nuclear power plant or plaits of a specified type (or falling within a

PPE) that might be constructed on the proposed site; 'RGs 1.113 and 4.4, 'Reporting

Procedure for Mathematical Models Selected to Predict Heated Effluent Dispersion in Natural

Water Bodies," issued May 1974, provide guidance in selecting and using surface water models

for analyzing the flowfield and dispersion of contaminants in surface waters.

Meeting the requirements of 10 CFR Parts 52 and 100 provides reasonable assurance that

accidental releases of liquid effluents to ground water and surface water, and their adverse

impact on public health and safety, will be minimized.'

For those cases in which a reactor design is not specified, the ESP applicant may instead

provide a PPE to characterize a facility or facilities for comparison'with the hydrologic

characteristics of the site. A PPE can be developed for a single type of facility or a group of

candidate facilities by selecting limiting values of the relevant parameters.

To determine whether the applicant met the requirements of 10 CFR Parts 52 and 100 with

respect to accidental releases of liquid effluents, the staff used the following specific criteria:

Radionuclide transport characteristics of the ground water environment, with respect to

existing and future users, should be described. Estimates and bases for coefficients of

dispersion, adsorption, ground water velocities, travel times, gradients, permeabilities, -

porosities, and ground water or piezometric levels between the site and existing or

known future surface water and ground water users should be described and should be

consistent with site characteristics. Potential pathways'of contamination to ground water

users should also be identified. Sources of data should be 'described and referenced.

* Transport characteristics of the surface water environment, with respect to existing and

known future users, should be described for conditions that reflect worst-case release

mechanisms and'source terms, so as to postulate the most pessimistic contamination

from accidentally released liquid effluents. Estimates of the physical parameters

necessary to calculate the transport of liquid effluent from the points of release to the

site of existing or known future'users should be described' Potential pathways of

contarriination to surface water users should be identified. Sources of information anddata should be described and referenced. Acceptance is based on the staff's evaluation

of the applicant's computational methods and the apparent completeness of the set of

parameters necessary to perform th e analysis.'

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Mathematical models are acceptable to analyze the flowfield and dispersion of

contaminants in ground water and surface water, providing that the models have been

verified by field data and that conservative site-specific hydrologic parameters are used.

Furthermore, conservatism should be the guide in selecting the proper model to

represent a specific physical situation. Radioactive decay and sediment adsorption may

be considered, if applicable, providing that the adsorption factors are conservative and

site specific. RG 1.113 provides guidance in selecting and using surface water models.

References 7 through 15 of RS-002 discuss the transport of fluids through porous

media.

2.4.13.3 Technical Evaluation

As originally submitted, SSAR Section 2.4.13 did not contain an analysis of accidental releases

to ground and surface waters, which the staff needs to evaluate currently applicable

hydrological accidental radionuclide release pathways. In the DSER, the staff indicated that the

applicant should provide a conceptual model of the subsurface environment, with reference to

drill logs, as-built fill, and compaction plans. The staff indicated further that the subsurface

conceptual model should provide estimates, and the basis for these estimates, for the hydraulic

conductivity of the soil, surface recharge rates, soil and ambient ground water chemical

properties, and piezometric boundary conditions. In RAI 2.4.13-1, the staff stated that these

model attributes were necessary for the staff to conduct a site-suitability evaluation in

accordance with RG 1.113 and requested the applicant to provide this information.

In its response, the applicant provided details of the hydrogeologic characteristics at the ESP

site, including a conceptual model of ground water movement through the saprolite and the

bedrock underlying the ESP site.

The applicant reported that the only observation of piezometric head difference made between

the saprolite and the bedrock indicates an upward hydraulic gradient. The staff needed to

understand the implications of an-upward hydraulic gradient, with respect to the transport of

effluents to the environment. Therefore, it requested that the applicant provide more details

about the magnitude, frequency, and spatial location of these upward hydraulic gradients at the

ESP site. This was Open Item 2.4-9. The staff intended to identify upward hydraulic gradient

as a site characteristic in any ESP that might be issued for this application.

In its response to Open Item 2.4-9 dated March 3, 2005, the applicant characterized the

significance of the upward hydraulic gradient between the bedrock and the saprolite as they relate to transport of effluent in the environment by comparing the vertical component of ground

water velocity to its horizontal component.

The applicant estimated the vertical hydraulic conductivity assuming that the anisotropy ratio

(Kh:KV) is 3:1, where Kh and K, refer to horizontal and vertical hydraulic conductivities for the

subsurface. Based on this assumption and the geometric mean of the measured horizontal

hydraulic conductivity values (1.3 ftld) for the saprolite, the applicant used the ground water

elevation measurements at observation wells OW-845 and OW-846 to estimate a vertical

seepage velocity range between 0.006 and 0.019 ft/d. The corresponding estimate for the

horizontal seepage velocity is 0.12 ft/d. The applicant estimated that the vertical seepage

velocity is about 5 to 15 percent of the horizontal seepage velocity and argued that the vertical

2-132
hydraulic gradient between the bedrock and saprolite at the ESP'site is of minor significance

with respect to the transport of effluent in the environment.

The staff reviewed the applicant's approach for ascertaining the significance of the vertical

hydraulic gradient on the transport of effluent in the subsurface. The applicant's justification of

the 'relatively minor significance of the upward hydraulic gradient is based on the assumed

anisotropy ratio (Kh:K,) of 3:1 that was used to estimate the vertical hydraulic conductivity and,

subsequently, the vertical component of seepage velocity. Because not enough evidence

points to layering (such'as horizontal clay lenses) within the saprolite that underlies the" ESP

site, the staff could not find a justification for the applicant's assumed anisotropy ratio.,

However, the bedrock has a significantly lower hydraulic conductivity and also a significantly

lower porosity as compared to the overlying saprolite.' Therefore, the'staff concluded that, even

if the subsurface hydraulic conductivity were isotropic (i.e., a Kh:K, of 1:1, leading to a more

conservative vertical hydraulic conductivity than the applicant's estimate) at the'ESP site, the

amount of upward flow out of the bedrock into the saprolite would be small compared to the

nearly horizontal regional ground water flow in the saprolite. 'Based on this reasoning, the staff

considers Open Item 2.4-9 resolved.

The applicant stated that the typical hydraulic gradient of ground water flow across the ESP site

to Lake Anna and the WHTF is 0.03 ft/ft. The applicant based this estimate on only one

piezometric head contour map constructed using ground water level observations from

March 2003. The applicant stated that this hydraulic gradient is typical of the ESP site, despite

seasonal and long-term variation in the ground w'ater regime. However, in the DSER, the staff

indicated that the applicant should provide data to support this statement and to define the

range of seasonal and long-term variation in hydraulic'gradient from the ESP site' into Lake''-

Anna and the WHTF. This was Open Item 2.4-10. The staff stated that it intended to'identifythe hydraulic gradient from the ESP site to Lake Anna and the WHTF as a site characteristic in

any ESP that might be issued for this application.

In response to Open Item 2.4-10, in its submittal dated March 3, 2005, the applicant stated that,

in order to-determine the-'range of variation' in the horizontal hydraulic gradient, it prepared

additional piezometric head contour maps using ground water elevations recorded at four times

other than the March 2003 measurement date. The applicant stated that the configuration 'of

piezometric head contours on all of these maps is very similar and concluded that only minor'

fluctuations in ground water levels were recorded between'December 2002 and February 2005.

The'applicant estimated the horizontal hydraulic gradient from the center of theESP site '

footprint near observation well OW-846 to the Lake Anna shoreline near observation well

OW-848 using all five ground water level measurements. The applicant-estimated horizontal

hydraulic gradients-range from 0.027 to 0.029 ft/ft. ' ' -

The staff verified the horizontal ground water gradient estimated by the applicant for the

February 1, 2005,"measurement. The staff used the difference betwe6n the 'ground watei'-

elevation measured at observation well OW-846 and the'water surface elevati6n of Lake Anna

on February 1','2005, to estimate a horizontal hydraulic gradient of 0.023 ft/ft based'6n a staffestimated distance of 1160 ft from observation well OW-846 to' Lake Anna-' Since the'

applicant's estimate of the horizontal hydraulic gradient is greater and therefore more

conservative than that estimated by the'staff, the applicant's value is deemed acceptable. The

staff also determined that the additional data presented by the applicant adequately

characterize the seasonal fluctuations in ground water levels at the ESP site. '

2-133
,IS

Based on the applicant's response, the staff considers Open Item 2.4-10 resolved.

The site suitability evaluation, with respect to radionuclide transport characteristics as defined

by 10 CFR 100.20(c)(3), requires the use of observed site-specific parameters important to

hydrological radionuclide transport (such as soil, sediment, and rock characteristics; adsorption

and retention coefficients; ground water velocity; and distances to the nearest surface body of

water) obtained from onsite measurements. The applicant did not provide the onsite measured

values of adsorption and retention coefficients for radioactive materials. This was Open

Item 2.4-11. The staff intended to identify onsite measured values of adsorption and retention

coefficients for radioactive materials as a site characteristic.

In response to Open Item 2.4-11, the applicant stated in its submittal dated March 3, 2005, that

it obtained site-specific adsorption coefficients important to subsurface hydrological radionuclide

transport from onsite measurements of soil characteristics. The applicant assembled a.

radionuclide inventory from information provided in the AP100O Design Control Document,

Tier 2, Table 12.2-9 (Sheet 4), for the effluent holdup tank liquid phase and waste holdup tank,

and in the Advanced Boiling-Water Reactor Standard Safety Analysis Report, Table 12.2-1 3a,.

for the low conductivity waste collection tank. These documents list the radionuclides that are

expected to be present in the liquid radwaste systems of the respective reactors. The applicant

compiled a composite list of radionuclides and their activities using the two radwaste

inventories, using the more conservative activity from the two designs.

The applicant screened the radionuclides in the composite list to identify those radionuclides

that may migrate through the subsurface to the environment (Lake Anna) with a residual activity

in excess of the values identified in Column 2 of Table 2 in Appendix B to 10 CFR Part 20.

During this screening, the applicant assumed an instantaneous release of the radwaste

inventory to the saturated zone, ignored any adsorption or retardation of the radionuclides

during their migration from the point of release to Lake Anna, and accounted for the radioactive

decay of the individual radionuclides in the inventory during the migration. The applicant used a

travel-time of 16 years for the radwaste plume to migrate from the point of release to Lake Anna

based on the maximum measured hydraulic conductivity of 3.4 ft/d, a horizontal hydraulic

gradient of 0.03 ft/ft, an effective porosity of 0.33, and an estimated travel distance of 1800 ft

from the point of release to Lake Anna. The applicant selected all radionuclides that retained a

residual activity in excess of values identified in Column 2 after 16 years of decay during

migration to the lake. For these radionuclides, iron (Fe)-55, cobalt (Co)-60, strontium (Sr)-90,

cesium (Cs)-134, and Cs-137, the adsorption (distribution) coefficient was considered important

to subsurface hydrological transport.

The applicant stated that it obtained distribution coefficients for each of the selected

radionuclides from published values based on the measured physical and chemical soil

properties at the ESP site. The applicant obtained distribution coefficients for Co and Fe from

Sheppard and Thibault (1990) by selecting a soil type that yielded the most conservative

(lowest) value. It obtained the distribution coefficients for Cs and Sr from EPA (1999). The

applicant also included manganese (Mn), ruthenium (Ru), and zinc (Zn) in its analysis to

account for the fact that the travel time from the point of release to the lake could be less than

16 years if the release occurred near the edge of the ESP site footprint closest to Lake Anna.

The applicant obtained the distribution coefficients for Mn, Ru, and Sr from Sheppard and

Thibault (1990). The applicant presented the values of the distribution coefficient for eight

radionuclides in a table included in its submittal dated March 3, 2005.

2-134
-

The staff reviewed the applicant's response to Open Item 2.4-1 1 and identified three major

issues regarding subsurface migration of radionuclides released accidentally in the ground

water to the accessible environment (Lake Anna and the WHTF). The first issue is the

composition'of the radionulide'inventory and selection of specific radionuclides from the

inventory that may be critical to public health and safety. A description of the staff's evaluation

of the applicant's approach to the selection of specific radionuclides follows. The second issue

is the'defiriftion or delineation of potential subsurface pathways from the point 'of release to the

accessible environment. The third issue is related to the uncertainty of subsurface hydrological properties that may affect the migration of the radionuclides. e ydogc

Selection of S~ecific Radionuclides

Section 2.4.13 of RS-002 outlines the review of accidental radioactive liquid effluenit'releases as

they may affect existing and known future uses of ground water and surface water resources.

The guidance calls for evaluation of transport capabilities and potential subsurface

contamination pathways under accident conditions to determine the most adverse scenarios for

contamination of 'ground water or of surface waters via subsurface pathways.' RS-002 states

that concentrations of radionuclides in the body of water under consideration should be

estimated based on dispersion computations with initial concentrations determined for the most

critical event.' Final estimated concentrations in the radioactive effluent at the'points of intereit

should be within acceptable limits as prescribed by Column 2 of Table 2 in Appendix B to

10 CFR Part 20.

According to 10 CFR Part 20, which prescribes standards for protection against radiation; total

ionizing radiation dose to an individual, including doses resulting from licensed and unlicensed

radioactive material and from radiation sources other than background radiation, must not

exceed the standards for protection. The effluent concentration values given in Column 2 are

equivalent to the radionuclide concentrations that, if ingested continuously for a year, would'-

produce a total effective dose equivalent of 0.05 rem (50 millirem or 50 rillisieverts). The staff

concludes that, because of the presence of several radionuclides in the potential accidental

release, an individual near a contaminated point of interest would receive a cumulative ionizing

radiation dose from each radionuclide that constitutes the effluent. For this reason, the staff

has determined that the applicant's screening procedure for selecting the radionuclides of importance to subsurface hydrological transport may be inappropriate. In the staff's view, the

dose calculations must include all radionuclides that may reach Lake Anna or the WHTF via a

subsurface pathway in order to estimate the total dose to an individual bsing these 'waters.'

Subsurface Pathways to Accessible Environment' '--

The applicant used a distance of 1800 ft from the point of release to Lake Anna to estiriate the

time of travel for regional ground water flow. Since the nuclear power plant design has not

been selected at the ESP stage and no details regarding the location of an accidental -

radioactive material release are available', th6.staff concludes that it is not possible at the ESP

stage to delineate all pos~sible subsurface pathways at the ESP site and to evaliate' the

potential pathways to determine the most critical event. In the staff's view, all subsurface

pathways from the final location of the release point to Lake Anna and the WHTF should be

delineated once the plant design has been selected. More detailed hydrologic measurements

may be necessary at that point to characterize the subsurface properties along these pathways

to establish the most critical event.

2-135
,Lo

Uncertainty of Subsurface Hydrological Properties

Several subsurface hydrological properties influence the migration of the radionuclide plume in

the ground water. Some of these properties include hydraulic conductivity, hydraulic gradient,

and distance to the nearest point to a surface water body that are common to all radionuclides

that may constitute the radwaste inventory. Some other properties such as adsorption and

retention coefficients may be unique to each radionuclide. In addition, subsurface chemical

properties, such as pH, may affect different radionuclides differently (EPA 1999a, 1999b, 2004).

The radwaste itself may contain certain complexing agents that are frequently used in

decontamination processes to remove buildup of radionuclides from cooling systems, such as

one or more chelating agents including ethylenedinitrilo tetraacetic acid, picolinic acid, oxalic

acid, and citric acid. The presence of these complexing agents can enhance the mobility of

some radionuclides, especially transition metals (Davis et al., 2000; Serne et al., 2002). For

this reason, EPA (1 999b) cautions that its lookup tables do not apply to environments

containing organic chelates.

The staff concludes that, because of incomplete knowledge of subsurface hydrological and

chemical properties and the likely composition of the radwaste effluent itself, significant

uncertainty exists in characterization of radionuclide migration in the subsurface at the ESP site

at the time of ESP review. The staff has determined that, after the reactor design is selected

and additional details related to radwaste tank design and the location within the proposed site

are known, appropriate subsurface hydrological characterization can be completed. Therefore,

at the time of a COL or CP application, more reliable estimation of radionuclide migration to

surface waters via subsurface pathways can be made.

At the ESP application stage, a decision related to a specific reactor design has not been

made. Therefore, the following details are not available for the staff to fully consider the effect

of accidental release of liquid effluents in ground and surface waters: exact location of radwaste

storage facilities, location and elevation of likely point of release, and detailed characterization

of liquid pathways above and below ground from the point of release to the accessible

environment. Although the staff conceptually used siting factors such as soil, sediment, and

rock characteristics, adsorption and retention coefficients, ground water velocity, and distances

to the nearest surface body of water in its site suitability determination, it determined that this

issue could be resolved if there were no releases of radionuclides to the ground water.

Accordingly, the staff proposes to include a condition in any ESP that might be issued for the

North Anna site requiring that an applicant referencing such an ESP design any new unit's

radwaste systems with features to preclude any and all accidental releases of radio-nuclides

into any potential liquid ground water pathway. This is Permit Condition 4.

2.4.13.4 Conclusions

As set forth above, the applicant has provided sufficient information pertaining to liquid

pathways. Therefore, the staff concludes that, with the noted conditions, the applicant has met

the requirements related to liquid pathways of 10 CFR 52.17(a) and 10 CFR 100.20©)(3).

2-136

l l l
2.4.14 Site Characteristics Related to Hydrology

Based on its review of SSAR Section 2.4, the staff has determined that any ESP that might be

issued for the proposed site should include the site characteristics given in Table 2.4.14-1.

2-137
, Ima

Table 2.4.14-1 Staff's Proposed Site Characteristics Related to Hydrology

SITE CHARACTERISTIC VALUE

Proposed Facility Boundaries Figure 2.4.14-1 shows the

proposed facility boundary

using its corners numbered

1-8 and also lists the

geographical coordinates

of these points in Virginia

State Plane Coordinate

System using NAD 83

Datum. The coordinates

are expressed in feet.

Minimum Lake Water Level 242 ft MSL

Maximum Elevation of Ground Water 270 ft MSL or 1 ft below

the free surface, whichever

is higher

Flood Elevation 270 ft MSL

Local Intense Precipitation 18.3 in./hr and 6.1 in. in

5 minutes

Frazil and Anchor Ice The ESP site has the

potential for the formation

of frazil and anchor ice.

Maximum Ice Thickness 17.1 in. thick

Maximum Cumulative Degree-Days Below Freezing 322 OF

Hydraulic Conductivity 3.4 ftld

Hydraulic Gradient 0.03 ft/ft

2-138
- - I I I -------- ____________ ___ -I I I

1'2 6 . 'Notes:

*- (_1. North Anna Site and State Plane NAD 83 9' \ \ " !. .i (South Zone) coordinates are shown as ! : !noted.

;-- 2. Abandoned Unit 3 and 4 Reactor Building

: i-" < --. - Mat Foundations are to be removed.

3. The Site Boundary is the Perineter of a 5000-foot radius circle from the center of

iV."'4- / / the novLabandoned Unit 3 ContaIn3ent. ~ ~ Reference NAPS USFAR. Section 2.1.1.3.

4. The distance from the ESP Envelope to the

Exclusion Area Boundary is 2854.90 feet.

_. .. . . . 1.. ' .

.AL M- .i111"_

ILis

CwrdMs(NkS~rM State Pamr C~owdinaes

point .Pint Nomt PlntP Eastl (NIAD 83) SWMt Zont '

__ FWnf (F- Norilh (Fee3 East(FeeO U

moo5430 732000 3909904 25 1164847024 '.. .

540000 937800 391065723 1168785 58 .t

474165 949226 391086 34 1168713280 . 1 ... j

474165 853965 390973779 116824623

42870 M539.65 390931465 116864259 -'§'* . 428703 747000 39092329 11685417.08 . . I M

448803 747000 390911015 116f5343.t W1= 11' "1"Krv

448803 a732000 390055 47 11685203 94: .~- - - -_ _ _ _ _-

_ . .. .... . _ __ _ _ _ -

gu T .

Figure 2.4.14-1 The proposed facility boundary for the ESP site

2-139
MNu

2.5 Geology, Seismology, and Geotechnical Engineering

In SSAR Section 2.5, the applicant described the geological, seismological, and geotechnical

engineering properties of the ESP site. SSAR Section 2.5.1 describes the basic geologic and

seismologic data for the site and region surrounding the site. SSAR Section 2.5.2 describes

the vibratory ground motion at the site in terms of a probabilistic seismic hazard analysis

(PSHA) and develops a site SSE ground motion. SSAR Section 2.5.3 describes the potential

for surface faulting at or near the surface of the ESP site. SSAR Section 2.5.4 presents

information on the stability of the site's subsurface materials. SSAR Section 2.5.5 describes

the stability of slopes at the site. Finally, SSAR Section 2.5.6, which covers embankments and

dams, states that the applicant did not reanalyze the North Anna Dam as part of the ESP

application.

Since the ESP site is located adjacent to NAPS Units 1 and 2, abandoned Units 3 and 4, and

the independent spent fuel storage installation (ISFSI), the applicant stated in SSAR

Section 2.5 that it used the previous site investigations for these facilities as its starting point for

the characterization of the geological, seismological, and geotechnical engineering properties of

the ESP site. As such, the material in Section 2.5 of the ESP application focuses on any newly

published information since the publication of the NAPS updated safety analysis report in the

1970s as well as recent geological, seismological, geophysical, and geotechnical investigations

performed for the ESP site. The applicant stated that it conducted these investigations in

progressively greater detail closer to the ESP site. The applicant defined the following zones of

investigation around the site:

* region-within 200 miles

* vicinity-within 25 miles

* area-within 5 miles

The ESP site itself is defined as the area within 0.6 mile of the site location.

The applicant also used the seismic source and ground motion models published by the Electric

Power Research Institute (EPRI) for the central and eastern United States (CEUS), "Seismic

Hazard Methodology for the Central and Eastern United States," as the starting point for its

seismic hazard evaluation. The applicant updated the EPRI seismic source and ground motion

models in accordance with RG 1.165, "Identification and Characterization of Seismic Sources

and Determination of Safe Shutdown Earthquake Ground Motion," issued March 1997.

RG 1.165 indicates that applicants may use the seismic source interpretations developed by

Lawrence Livermore National Laboratory (LLNL) in the "Eastern Seismic Hazard

Characterization Update," published in 1993, or the EPRI models, published in 1986, as inputs

for a site-specific analysis.

2.5.1 Basic Geologic and Seismic Information

SSAR Section 2.5.1 describes the geologic and seismologic characteristics of the ESP site

region and area. SSAR Section 2.5.1.1 describes the geologic and tectonic setting of the site

region, and SSAR Section 2.5.1.2 describes the structural geology of the site area.

2-140
2.5.1.1 Technical Information in the Application

2.5.1.1.1 Regional Geology

SSAR Section 2.5.1.1 describes (1) the physiographic provinces that encompass a 200-mile

radius of the site, (2) the geologic history in terms of the major tectonic events, (3) regional

stratigraphy, (4) the regional tectonic setting, and (5) regional gravity and magnetic'data.

Phvsiographic Provinces

SSAR Section 2.5.1.1.1 describes the regional physiography and geomorphology of the ESP

site. The ESP site lies within the Piedmont physiographic province. The Piedmont province lies

between the Coastal Plain province to the east and the Blue Ridge province to the west and is

characterized by deeply weathered bedrock. Elevations in the Piedmont province range from

800 to 1500 ft in the western portion of the province to about 200 ft in the eastern portion, near

the Coastal Plain province. Figure 2.5.1-1, reproduced from SSAR Figure 2.5-1, illustrates

each of the physiographic provinces within the site region.

Regional Geologic History

SSAR Section 2.5.1.1.2 describes the geologic history of the ESP site region, which is

composed of episodes of continental collisions with intervening episodes of continental rifting.

Episodes of continental collisions have produced a series of accreted terranes that are

separated by low-angle detachment faults. In contrast, intervening episodes'of continental

rifting have produced high-angle normal faults that either extend downward into the low-angle

detachnment faults or penetrate entirely through the accreted terranes. The latest major tectonic

events in the region include the Allegheny orogeny (mountain building) and Mesozoic and

Cenozoic crustal extension (rifting) episodes. The collision of the North American and African

plates caused the Allegheny orogeny, which occurred during the late Carboniferous Period

(about 290-330 million years (Ma) ago) and extended into the Permiah Period (240-290 Ma).

Crustal extension followed the Allegheny orogeny during the early Mesozoic Era (200-240 Ma)

that began the opening of the Atlantic Ocean. This early Mesozoic extensional episode

continued with the development of the mid-Atlantic spreading center during the Cenozoic Era-

(63 Ma-present). Currently, the site region is located on the passive, divergent trailing margin

of the North American plate following this last episode of continental extension and rifting.

Regional Stratigrahv '

Section 2.5.1.1.3 of the SSAR describes the regional stratigraphy of the ESP site. Two distinct'

rock types markthe regional stratigraphy of the Piedmont province. The first and oldest type is

the crystalline rock of the late Precambrian (570-1500 Ma) and Paleozoic age (240-570 Ma).

Overlying these rocks are Mesozoic-age (63-240 Ma) sedimentary rocks deposited locally in

down-faulted basins within the crystalline rocks. Residual soils derived from weathering of the

crystalline rocks, as well as Quaternary-age (2 Ma-present) alluvium and colluvium, overlay

both the sedimentary and crystalline rocks.

2-141
D cription of Regions

ATLANIIC PLAUN

r, - "PALAC4"N mIGHgANcJE

P S I& RW90. p#WA*

* L .- yd S.A RO4P.C

APPW-di PI"--& P..w~

AIK-.Mo..mL,.db

Regional Physiographic Map

2004.41i Radius

North~ Arnn& US

Figure 2.5.1-1 Regional physilographic map (200-mile radius)

2-142

ii
Reaional Tectonic Setting

Section 2.5.1.1.4 of the SSAR describes the regional tectonic setting for the ESP site.

Figure 2.5.1-2, reproduced from SSAR Figure 2.5-5, presents a simplified tectonic and

stratigraphic map of the site region, including many of the local faults.

The ESP site lies within the central Appalachian region of Virginia, which is part of the

northeast-trending Appalachian orogenic belt that extends nearly the entire length of the

eastern United States. 'The tectonic stress in the CEUS, including the Appalachian region, is

primarily characterized by northeast-southwest-directed horizontal compression. The expert

teams that participated in the 1986 EPRI hazard evaluation con'cluded that the most likely

source of the tectonic stress in the CEUS region is a ridge-push body force associated with the

mid-Atlantic ridge, which is transmitted to the interior of the North American tectonic plate.

Studies cited in SSAR Section 2.5.1.1.4 found the magnitude of the northeast-southwestdirected stress to be about 2 to 3X1 012 N/m, which corresponds to average equivalent stresses

of about 40 to 60 MPa, distributed across a 30-mile-thick elastic plate.

SSAR Section 2.5.1.1.4 categorizes four principal tectonic structures within the 200-mile ESP

site region based on the age of formation or reactivation of the structures, including those active

during (1) the Paleozoic Era (240-570 Ma), (2) the Mesozoic Era (63-240 Ma), (3) the Tertiary

Period (2-63 Ma), and (4) the Quaternary Period (2 Ma-present).

Paleozoic Tectonic Structures

The rocks and structures within the physiographic provinces that encompass the ESP site

region are associated with thrust sheets that formed during the convergent Appalachian

orogenic events of the Paleozoic Era (240-570 Ma). The majority of these thrust sheets are

shallow and dip eastward into a low-angle, basal Appalachian decollement. Below the

decollement are rocks that form the North American basement complex. The basement rocks

contain normal faults that formed during the late Precambrian to Cambrian Period

(570-1500 Ma). 'Literature cited in the SSAR states that much of the sparse seismicity in the

Appalachian region occurs within this North American basement complex and not within the

more abundant, shallow thrust sheets mapped at the surface.

Major Paleozoic tectonic structures near the ESP site include the Hylas shear zone,

Spotsylvania thrust fault, Long Branch thrust fault, Chopawamsic thrust fault, Lake of the

Woods thrust fault, and Mountain Run fault zone. No seismic activity has been attributed to any

of the Paleozoic faults within 200 miles of the site, and, as such, the applicant considers none

to be capable tectonic sources, as defined in Appendix A to RG 1.165. Of these tectonic

structures, the Hylas shear zone, the Lake of the Woods thrust fault, and the Mountain Run

fault zone are the most prominent. In response to RAI 2.5.1-4, the applicant revised SSAR

Section 2.5.1.1.4 to state that there is no reported geomorphic expression, historical seismicity,

or Quaternary deformation along either the Hylas shear zone or the Lake of the Woods thrust

fault. Diffuse, scattered seismicity occurs throughout the Central Virginia seismic zone (CVSZ),

but it is not spatially concentrated or aligned with either of these two structures. SER

Section 2.5.1.3.1 provides a complete description of the applicant's response to RAI 2.5.1-4

and the staff's evaluation of the applicant's response.

2-143
Figure 2.5.1-2 Simplified tectonostratigraphic map

2-144

. . ------
- - u - t w { s o s - s

Since the Mountain Run fault zone is one of the most clearly recognizable faults in the region

with two pronounced scarps occurring along the fault zone, the applicant identified it as a

potential Quaternary tectonic feature. SSAR Section 2.5.1.1.4 states that these two

pronounced scarps'along the Mountain Run fault zone have led some experts to suggest that

the fault has experienced a late Cenezoic (63 Ma-present) phase,of movement. The Mountain

Run fault zone is a 75-mile-long fault zone that lies approximately 18 miles northwest of the

site. The following excerpt from SSAR Section 2.5.1.1.4 describes the applicant's investigation

of the Mountain Run fault zone:

Field and aerial reconnaissance performed for this ESP application did not reveal

any geologic or geomorphic features indicative of potential Quaternary activity

along the Mountain Run fault zone. A review of 1:24,000 scale topographic

maps revealed that the steeper portions of the Mountain Run scarp correlate with

the areas where the Mountain Run (stream) is impinging on the scarp. In

addition, the northwest side of the narrow Mountain Run valley is steepest where

the stream is impinging on that side of the valley. These observations suggest

that the scarp most likely formed due to erosion, as southeastward-migrating -

streams impinge against the more resistant rocks in the Mountain Run fault

zone.

Based on the reconnaissance described above, the applicant concluded that the Mountain Run

fault zone is not a capable tectonic source. In response to RAI 2.5.1-5, the applicant stated that

its reconnaissance field and aerial evaluations demonstrated that the Mountain Run and Kelly's

Ford scarps along the Mountain Run fault zone are associated with incised drainages that are

preferentially eroding the southeast valley walls, creating asymmetric valley profiles. As such,

the applicant determined that the scarps are most likely products of fluvial erosion. -SER

Section 2.5.1.3.1 provides a complete description of the applicant's response to RAI 2.5.1-5

and the staff's evaluation of the applicant's response.

Mesozoic Tectonic Structures

A series of elongated Mesozoic Era (63-240 Ma) rift basins are exposed in a belt extending

from Nova Scotia to South Carolina. These rift basins exhibit a high degree of parallelism with

the surrounding structural grain of the Appalachian orogenic belt. They were formed during the

extension and thinning of the Earth's crust as Africa and North America rifted apart to form the

Atlantic Ocean. Section 2.5.1.1.4 of the SSAR states that, although the Mesozoic basins have

long been considered potential sources for earthquakes along the eastern seaboard, none of

the basins in the site region is associated with a known capable tectonic source.

Tertiary Tectonic Structures

Tertiary Period (2-63 Ma) tectonic structures within 200 miles of the ESP site include the

Brandywine fault system in Maryland, the National Zoo faults in Washington, DC, the Dutch

Gap fault in Virginia, and the Stafford fault system. -The Stafford fault is a 42-mile-long fault

system that comes within 16.5 miles of the site.; Section 2.5.1.1.4 states that the NAPS

licensbe's (Virginia Power's) detailed drilling, trenching, and mapping of the Stafford fault

system in the Fredericksburg region in the early 1970s showed that the youngest identifiable

fault movement occurred before the middle Miocene Epoch (i.e., more that 10 Ma ago).

Subsequent investigations have shown some minor, later activity along the Stafford fault

2-145
[Lan

system. However, none of this activity has occurred during the Quaternary Period (i.e., the past

2 Ma). Thus, the applicant concluded that the Stafford fault system is not a capable tectonic

source. The applicant stated that the EPRI 1986 seismic source models incorporated all of the

available information on the Stafford fault system. In addition, the applicant stated that no new

significant information has been developed since 1986 regarding the potential activity of the

Stafford fault system. In response to RAI 2.5.1-6, the applicant stated that it based its

conclusion that the Stafford fault system is not a capable tectonic source on a review of existing

literature, discussions with researchers familiar with the area, areal and field reconnaissance,

and geomorphic analyses. SER Section 2.5.1.3.1 provides a complete description of the

applicant's response to RAI 2.5.1-6 and the staff's evaluation of the applicant's response.

Quaternary Tectonic Features

To define Quaternary tectonic (2 Ma-present) features, the applicant used the study of Crone

and Wheeler (Ref. 59, SSAR Section 2.5) as one of its criteria. Crone and Wheeler compiled

geologic information on Quaternary faults, liquefaction features, and possible tectonic features

in the CEUS. They evaluated and classified these features into one of four categories

(Classes A, B, C, and D) based on geologic evidence of Quaternary faulting or deformation.

Within a 200-mile radius of the ESP site, Crone and Wheeler identified 11 potential Quaternary

features. Of these 11 features, only the CVSZ showed geologic evidence that demonstrates

the existence of a Quaternary fault of tectonic origin (Class A). SSAR Section 2.5.1.1.4 states

that none of the other features compiled by Crone and Wheeler have "demonstrated evidence

of Quaternary activity that would imply recurrent activity in the past 500,000 years." The

applicant investigated many of these features, such as the Mountain Run fault zone described

above, in great detail to determine their potential for Quaternary activity. Figure 2.5.1-3,

reproduced from SSAR Figure 2.5-12, shows the Quaternary features identified by Crone and

Wheeler.

The ESP site is located near the northern boundary of the CVSZ. Because the causative faults

have not been identified, the applicant characterized the CVSZ as a seismogenic source rather

than a capable tectonic source. The largest earthquake known to have occurred in the CVSZ is

the body-wave magnitude (mb) 5.0 Goochland County event in 1875. The CVSZ is an area

defined by moderate to low historical seismic activity, as well as paleoseismicity, since

Obermeier and McNulty recently identified two paleoliquefaction features within the CVSZ

(Ref. 71, SSAR Section 2.5). However, SSAR Section 2.5.1.1.4 states that the absence of

widespread paleoliquefaction led Obermeier and McNulty to conclude that an earthquake of

magnitude 7 or larger has not occurred within the CVSZ in the last 2000-3000 years, or in the

eastern portion of the seismic zone for the. last 5000 years. In addition, the applicant stated that

"these isolated locations of paleoliquefaction may have been produced by local shallow

moderate magnitude earthquakes of [moment magnitude (Mw)] 5 to 6." In RAI 2.5.1-1, the staff

asked the applicant to describe these two paleoliquefaction features and their impact on the

seismic characterization of the CVSZ. In its response, the applicant modified SSAR

Section 2.5.1.1.4 to reaffirm its conclusion that the original 1986 EPRI study adequately

characterizes the magnitude level of the CVSZ. SER Section 2.5.1.3.1 provides a complete

description of the applicant's response to RAI 2.5.1-1 and the staff's evaluation of the

applicant's response.

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; ij}s

H # s rs

Class A Features * - .*

1 - Central VA. Seismic Zone

Class B Features A - 4 

2 - Pembroke faults -

Class C and D Features A ' e

3- Mtn. Run/Everona faultzone co

4 - LebanonChurchfault 8I94

5 - Undside fault zone * / 

6 - Old Hickory faults I

7- Stanleytown-Villa Heights faults . 0 * - , 8 8-Cacoosing Valley EQ 2 ->! y 3 9

9 - Lancaster seismic zone 4 o

10 - Upper Marlboro faults -6

11 - Hares Crossroads faults

=historical earthquakes " A

of mb 3.0 or greater j * 

A.77

Sourc

-Gulf ofexc - s'-

-0 300 600 900

Kilometers

'Fig-ure 2.5.1-3 Quaternary features map

- 147

7 m" 2-14\

TLAMTic

OCEAN

e: CroneandWheeler(2000)

. , , I ..
I ,Ila

The applicant also identified the seven fall lines across the Piedmont and Blue Ridge provinces

of North Carolina as another potential Quaternary tectonic feature. Weems identified these

seven fall lines (Ref. 70, SSAR Section 2.5), which are based on the alignment of short stream

segments with anomalously steep gradients. Because other studies of potential tectonic

features in the CEUS do not include the seven fall lines identified by Weems, the applicant

concluded that they do not represent a capable tectonic source. In RAI 2.5.1-3, the staff asked

the applicant to more strongly justify its conclusion that the seven fall lines do not represent a

capable tectonic source. In its response, the applicant revised SSAR Section 2.5.1.1.4 to

strengthen its conclusion by stating that Weems does not present direct credible evidence for a

tectonic origin of the fall lines. The applicant also stated that, based on its evaluation of the

stratigraphic, structural, and geomorphic relations across and adjacent to the fall zones,

differential erosion resulting from variable bedrock hardness is a more plausible explanation

than Quaternary tectonism. SER Section 2.5.1.3.1 provides a complete description of the

applicant's response to RAI 2.5.1-3 and the staff's evaluation of the applicant's response.

The applicant cited another potential Quaternary tectonic feature known as the East Coast fault

system (ECFS). The ECFS is a 370-mile-long fault system that consists of three 125-mile-long

segments extending from the Charleston area in South Carolina northeastward to near the

James River in Virginia. The southern segment of the ECFS (ECFS-S) is associated with the

Charleston earthquake of 1868 (with an estimated magnitude of about 7) and continues to

show microseismic activity. Only Marple and Talwani postulated the central and northern

segments of the ECFS (ECFS-C and ECFS-N) as tectonic features (Ref. 75, SSAR

Section 2.5). The closest approach of the northern segment to the site is approximately

70 miles to the southeast. Because the ECFS-N and ECFS-C have not been associated with

any seismicity and gravity or magnetic anomalies, the applicant concluded that they are not

likely to exist or, if they do exist, they have a very low probability of activity. In RAI 2.5.1-2, the

staff asked the applicant to describe the aerial reconnaissance and other sources it used to

support its conclusions regarding the ECFS-N, which is the closest segment to the ESP site.

Consistent with its response, the applicant revised SSAR Section 2.5.1.1.4 to reaffirm this

conclusion by demonstrating that other researchers and studies have determined that the

ECFS-N is not a potential source of seismic activity. SER Section 2;5.1.3.1 provides a

complete description of the applicant's response to RAI 2.5.1-2 and the staff's evaluation of the

applicant's response.

SSAR Section 2.5.1.1.4 also describes the Giles County, Virginia, seismic zone, which is

located near the border with West Virginia. The Giles County seismic zone is defined by a

concentration of small to moderate earthquakes and produced the largest historical earthquake

in Virginia. This earthquake, referred to as the Giles County earthquake, had an estimated mb

of 5.8 and occurred in 1897. The applicant stated that the shaking at the ESP site from this

earthquake would have been about an intensity level of 5, which signifies ground motion that is

felt by nearly everyone in the vicinity of the ESP site and might crack plaster or overturn

unstable objects. The applicant stated that geologists have not identified any capable tectonic

sources in the area that can be associated with the concentration of seismic activity within the

Giles County seismic zone. Geologists have identified a zone of small Quaternary-age surface

faults within the Giles County seismic zone, near Pembroke, Virginia. However, the applicant

stated that these faults do not appear to be related to the seismicity within the Giles County

seismic zone, which occurs at depths between 3 and 16 miles beneath the Appalachian basal

decollement in the North American basement. The EPRI seismic source model maximum

magnitudes (Mmax) for the Giles County seismic source zone vary from mb 6.6 to 7.2.

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Subsequent hazard studies have used similar values for the Mmax of the Giles County seismic

zone. Therefore, the.applicant decided not to revise the EPRI seismic source model for the

Giles County seismic zone. -

In addition to the principal tectonic features and seismic zones within the ESP site region, the

applicant, in SSAR Section 2.5.1.1.4, also described the major active seisomogenic source

zones located outside the site region. These sources include the Eastern Tennessee seismic

zone (ETSZ), the Charleston seismic source, and the New Madrid seismic zone (NMSZ).

These three seismic source zones are more than 300 miles from the ESP site. However, large

earthquakes from sources at this distance could contribute to the long-period ground motion

hazard at the ESP site. Figure 2.5.1-4, reproduced from SSAR Figure 2.5-14, illustrates these

three seismic source zones, as well as other regional seismic source zones.

Eastern Tennessee Seismic Zone

The ESP sit6 is located over 300 miles east of the ETSZ. The ETSZ is about 185 miles long

and 30 miles wide and is located in the Valley and Ridge Province of eastern Tennessee.

Although the ETSZ has not produced a damaging earthquake in historical time, this zone did

produce the second highest release of seismic strain energy in the CEUS during the 1980s.

Earthquakes in the ETSZ occur at depths between 3 and 16 miles, and none have exceeded an

Mw of 4.6 (Ref. 88, SSAR Section 2.5). In addition, earthquakes within the ETSZ have not been

attributed to known faults, and no capable tectonic faults have been identified within the seismic

zone. The EPRI seismic source model includes various source geometries and parameters to

represent the seismicity of the ETSZ. The Mmax values used by EPRI for the ETSZ range from"

mb 6.6 to 7.4. Subsequent hazard studies have used Mmax values of mb 6.45 and 7.25 (Refs.- 57

and 79, SSAR Section 2.5). The applicant concluded that both of these more recent estimates

of Mmax are similar to those used by EPRI for the ETSZ. Therefore, the applicant decided not to

revise the EPRI seismic source model for the ETSZ.

Charleston Seismic Source

The Charleston seismic source is located about 375 miles south of the ESP site. The

earthquake which occurred in Charleston, South' Carolina, on August 31 1886, is the largest

historical earthquake event to occur in the eastern'United States. The earthquake produced

intense shaking in the epicentral area-(Modified Mercalli Intensity (MMI) X) and was felt as far

away as Chicago (MMI V) (Ref. 90, SSAR Section 2.5). Estimates of the magnitude for the

1886 Charleston earthquake are 7.3 (Ref. 90, SSAR Section 2.5) and 6.8 (Ref. 93, SSAR

Section 2.5). The applicant stated that both of these more recent estimates of the magnitude of

the Charleston earthquake are similar to the upper bound'range of Mmax values used in the

1986 EPRI study (mb 6.8 to 7.5). Therefore, the applicant concluded that no new information

has been developed since 1986 that would warrant a significant revision to the EPRI seismic

source model in terms of earthquake magnitude. However, estimates of earthquake recurrence

for the Charleston source, based on dates of paleoliquefaction events, have been updated

since 1986. The most recent summary of paleoliquefaction data (Ref. 91, SSAR

Section 2.5) for the Charleston source indicates a mean recurrence time of 550 years. This

mean recurrence time is roughly an order of magnitude less than the seismicity-based

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Central and Eastern North American Seismicity

1568 - 1987

50

45

U

9 So

a) 40

35.

30 _

-95

MAGNITUDE

QDa(D 7

0 6

C) 5

0 4

a 3

-90 -85 -80 -75

Longitude (Deg.)

-70 -65

(fromn Einger and ehrs. 1992)

Figure 2.5.1-4 Seismic source zones and seismicity In central and eastern North America

2-150

.
-

recurrence estimates used in the 1986 EPRI study. Therefore, the applicant modified the

Charleston recurrence interval from several thousand years to 550 years, based on the

paleoseismic observations. The applicant included this reduction in recurrence interval in its

sensitivity analysis, which is described in SSAR Section 2.5.2.-

New Madrid Seismic Zone

The NMSZ extends from northeastern Arkansas to southwestern Tennessee and is over

-620 miles west of the ESP site.- The NMSZ produced three large-magnitude earthquakes

between December 1811 'and February 1812. Estimates of the magnitudes of these events'

range between 7 and 8. However, because of the considerable distance between the NMSZ

and the ESP site,' the NMSZ only contributed 1 percent of the hazard at the NAPS site'in the

1986 EPRI study. Since 1986, estimates'of the Mmax for the NMSZ have generally been-within

the range of MmaX values used by the EPRI study (mb 7.2 to 7.9). However, the recurrence

interval for the NMSZ, based on paleoseismriic observations, is now only 500 years,'which is

considerably less than the recurrence estimates used in the 1986 EPRI study. The applicant

included this reduction in recurrence interval in its sensitivity analysis, which is described in

SSAR Section 2.5.2.

Regional Gravity and Magnetic Data

The applicant reviewed regional maps of gravity and magnetic data in SSAR Section 2.5.1.1.5.

The Geological Society of America (GSA) published regional maps of gravity and magnetic

fields in North America in 1987. The maps present gravity and magnetic field data at a'

1:5,000,000 scale. The applicant stated that these maps 'are 'useful for identifying and

assessing gravity and magnetic anomalies with wavelengths on the order of tens of kilometers

or greater.

The gravity map of the eastern United States'shows that, at the latitude of Virginia, there is a

long-wavelength, east-to-west gravity gradient, referred to as the Piedmont gravity gradient.

The Piedmont gravity gradient stretches across the Blue Ridge and Piedmont provinces of

Virginia. The applicant stated the following about the Piedmont'gravity gradient:'

The presence of the Piedmont Gravity Anomaly was known at the time of the

1986 EPRI study. This anomaly is a first-order feature of the gravity field and is

- interpreted to reflect eastward thinning of the North American crust and

lithosphere.'

Magnetic data published by GSA reveal numerous northeast-southwest-trending magnetic

anomalies, generally parallel to'the structural features of the Appalachian orogenic belt.

However, in contrast to the gravity data, the magnetic anomalies do not provide information on'

crustal-scale features in the lithosphere; Rather, the applicant stated that anomalies in the

magnetic field are associated primarily with upper crustal variations in magnetic susceptibility,

such as maficaad ultramafic rocks. The magnetic data provide additional characterization of

the-geophysical properties of the upper crust and supporting evidence'for the interpretation of

the seismic reflection data. The applicant stated that the magnetic data published since 1986

do not reveal any new anomalies related to geologic'structures that had not been identified

before the 1986 EPRI study.

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-M

2.5.1.1.2 Site Geology

SSAR Section 2.5.1.2 describes the site area in terms of (1) physiography, (2) geologic history,

(3) stratigraphy, (4) geologic structure, (5) geologic hazard evaluation, (6) engineering geology,

and (7) ground water conditions.

Site Area Physiography

The ESP site is located within the Piedmont province and is bordered by Lake Anna to the north

and east. The ESP site is in an area with a topography that is gently undulating, varying in

elevation from about 200 to 500 ft. The applicant stated that the slopes in the region typically

range from 2 to 5 percent, with steeper slopes along the lower tributaries of some of the larger

streams ranging from 7 to 10 percent. Site grade for the existing units is at an approximate

elevation of 271 ft. The ground surface gently rises to the west and south to elevations of over

300 ft. Figure 2.5.1-5, reproduced from SSAR Figure 2.5-16, presents the site topographic

map.

Site Area Geologic History

The applicant stated that, since early Paleozoic time (about 500 Ma), rocks of the Piedmont

province have undergone three compressional orogenies during the Paleozoic Era and one

extensional episode during the Mesozoic Era (63-240 Ma). These orogenies produced a

complex pattern of folding and faulting in the region surrounding the site. The rocks of the

Piedmont province exhibit varying degrees of metamorphism, depending on their location in

relation to the axis of major stress, which generally trends northeast-southwest. During the

more recent Cenozoic time (63 Ma-present), the area surrounding the ESP site was subject to

erosion along the passive continental margin. Erosion continued during the Pleistocene

(0.01-2 Ma) glacial and interglacial periods. Weathering processes during the glacial and

interglacial periods include frost shattering, freeze-thaw cycles, accelerated wind erosion, and

accelerated solifluction (flowage of saturated soil). The applicant concluded that these

weathering processes, together with downcutting streams and rivers during the present,

produced the residual soils that cover the ESP site.

Site Area Stratigraphy

The applicant stated that the ESP site is underlain by rocks of the Ta River Metamorphic Suite,

which are in turn underlain by rocks of the Chopawamsic Formation and the Mine Run

Complex. Surficial sediments at the site consist of mainly residual soil and saprolite, with some

alluvium found along stream channels. The Ta River Metamorphic Suite underlying the site is

thousands of feet thick, and the rocks within the suite are dark gray to black gneisses of

Cambrian and/or Ordovician age. The applicant stated that borings completed at the ESP site

encountered rocks of the Ta River Metamorphic Suite that are gray to dark gray quartz gneiss

and hornblende gneiss. Residual soil and saprolite overlie the rocks of the Ta River

Metamorphic Suite. The residual soil is derived from the weathering of the underlying

metamorphic rocks and generally consists of clay, silt, and sand-sized particles with minor rock

fragments. The saprolite is also derived from weathering of the underlying metamorphic rock

but, unlike the residual soil, retains many of the structural and mineralogical features of the

rock. The saprolite extends down to the top of the rock from which it was derived.

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- \~ 4 . ~ ~Site Topographic Map

Z~ '~~'0.6-Mile Radius

b N North Annec Site

Figure 2.5.1-5 Site topographic map (0.6-mile radius)

2-153 ;
| [in

Site Area Structural Geology

Structural features at and within a 5-mile radius of the ESP site consist of a series of northeaststriking faults and folds within the metamorphic bedrock. The applicant identified the following

bedrock faults within a 5-mile radius of the ESP site:

(1) Spotsylvania thrust

(2) Chopawamsic thrust

(3) Long Branch thrust

(4) Sturgeon Creek fault

(5) unnamed faults "a," "b," and "c"

The applicant stated that none of the above faults are considered to be capable tectonic

sources, as defined by RG 1.165. The Spotsylvania, Chopawamsic, and Long Branch thrust

faults are northeast-striking, east-dipping Paleozoic structures that can be mapped for miles

within the Piedmont province and represent the largest surficial tectonic structures within the

site area. The Sturgeon Creek fault and the three unnamed faults ("a," "b," and "c") also strike

northeast; however, they are smaller structures than the other three thrust faults. Unnamed

fault "a," which traverses NAPS and the ESP site, was the subject of intensive study following

its exposure during the excavations for abandoned Units 3 and 4. This fault has a length of

about 3000 ft based on geologic mapping of excavations and trenches. The applicant cited the

conclusions of a Dames and Moore study (Ref. 9, SSAR Section 2.5), stating that unnamed

fault "a" is not a capable tectonic source, as well as the NRC staff's acceptance of this

conclusion found in the SER for abandoned NAPS Units 3 and 4.

The applicant stated that the most prominent folds at the site are the northerly plunging

syncline/anticline pair located in the western portion of the site. The axis of the site passes

near an area of exposed bedrock, and foliations near the axis of the fold dip steeply

(65-90 degrees).

Site Area Geologic Hazard Evaluation

SSAR Section 2.5.1.2.5 states that the only geologic hazards associated with the ESP site are

(1) vibratory ground motion from regional earthquake activity and (2) potential surface faulting

from site area earthquakes. The applicant discussed these two potential geologic hazards in

SSAR Sections 2.5.2 and 2.5.3, respectively. The corresponding sections of this SER provide

the staff's review of these two potential geologic hazards.

Site Engineering Geology

SSAR Section 2.5.1.2.6 briefly describes the engineering behavior of the soil and rock at the

ESP site, prior earthquake effects, effects of human activities, construction ground water

control, and unforseen geologic features. Section 2.5.4 of the SSAR discusses the results of

the applicant's geotechnical investigation in greater detail.

The applicant described the composition of the saprolite at the ESP site as micaceous silty,

clayey sand and sandy silt/clay with occasional to many relict rock fragments. The saprolite

more or less retains the fabric or structure of the parent bedrock, depending on the degree of

weathering. However, although the saprolite has the relict structure of the parent bedrock, its

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engineering properties typicaily tbsernble those of a soil. The applicant classified the saprolite

at the site into Zone IhA and IIB saprolite, based on' its general composition and grain size.

Zone IIA saprolite is classified as silty sand, clayey sand, and high- and low-plasticity silt and

clay. Zone IIB saprolite is classified as silty sand. Zone IIA saprolite is the more weathered of

the two saprolites and contains less than 10 percent relict rock fragments. -In contrast, Zone 111

saprolite'contains between 10 and 50 percent relict rock fragments and is more dense than,

Zone IIA saprolite. The presence of mica in the 'saprolite is likely to reduce its maximum

compacted density and increase its'compressibility. The applicant provided the following

example of this phenomenon:

The SWR [service water reservoir] pump house for the existing units was

constructed on about 65 feet of Zone' IIA saprolite, consisting mainly of sandy,

silt, with frequent layers of micaceous sandy silt. For about two years after its

construction, the pumphouse structure underwent relatively high settlement that

declined significantly thereafter. The settlement was caused by the weight of the

SWR dike fill built up around the pumphouse. The micaceous nature of the

material is considered to have played'a major role in the settlement. High

compressibilities and low maximum densities of the'saprolite, therefore, preclude

'using it as engineered fill at the ESP site. ''

The applicant stated that bedrock at the ESP site is composed of predominantly quartz gneiss

with biotite of the Ta River Metamorphic Suite. The gneiss is a hard, foliated rock, which

exhibits various degrees of weathering. The degree of weathering of the gneiss affects its

engineering behavior and properties. The applicant classified the gneiss at the site into three

categories (Zones ll, III-IV, and IV) based on its degree of weathering. Zone IlIl is.the

uppermost weathered part of the bedrock, is highly weathered and fractured,' and contains

traces of clay and iron'oxide. Regarding Zone 1ll, the applicant stated the following:

Because of the tendency for zones of severely weathered and fractured rock to

weather further upon exposure, they would be removed and replaced with

cement grout where encountered in excavations for the new units. This would

ensure the bearing capacity of the foundation rock mass.

Zones III-IV and IV are considerably less weathered, with the degree of weathering decreasing

with increasing depth. Zone III-IV is moderately weathered, and Zone IV is slightly weathered

to fresh. Based on the testing of rock borings, the -applicant concluded that Zones III-IV and IV

are suitable bea'ring surfabces for Category I plant structures. The applicant did not consider the

joints and fractures present in both zones to-be of sufficient density or extent to affect the

engineering behavior of the rock with respect to its bearing capacity or integrity:-

The applicant stated that no physical evidence of any fissuring, liquefaction, landsliding,

lurching, or caving of banks exists to indicate that past earthquake ground shaking has

disturbed either the surficial sediments or the bedrock beneath the ESP site. This result follows

from the relativeli low intensitiy of historic 'ground shaking at the site. :

The major potential effect of human activity on the ESP site is the mining in the vicinity of the

site which occurred frormnthe'1700s to'1974. Sulfide and gold deposits have been mined

predominanily in and around the town' of Mineral, Virginia, approximately 7 miles west of the

site. The closest mining deposit, the Allah Cooper deposit, is about 3 miles northwest of the

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IIrmt I 

site. The applicant stated that, based on published documentation of these mining activities

and their distance from the site, the activities have not affected, nor would they affect, the ESP

site.

The applicant stated that ground water withdrawal from the surficial sediments and bedrock

around the ESP site is not an issue because of the low withdrawal quantities and the limited

areal extent of the withdrawals. Current site ground water withdrawal is generally limited to

water supply wells for plant drinking and process water purposes.

Concerning construction ground water control issues, the applicant stated that ground water at

the ESP site generally occurs at depths ranging from about 6 to 58 ft below the present day

ground surface. The exception to this is the excavation area of the abandoned Units 3 and 4,

which was partially backfilled and where ground water is within about 2 ft of the ground surface.

The applicant further stated that ground water levels at the site would likely result in the need

for temporary dewatering of foundation excavations extending below the water table.

Concerning the potential for unforseen geologic features, the applicant stated that it would

(1) geologically map future excavations for safety-related structures and (2) evaluate any

unforseen geologic features that are encountered. In addition, the applicant stated that it would

notify the NRC "when any excavations for safety-related structures are open for their

examination and evaluation."

Site Ground Water Conditions

The applicant stated that ground water at the ESP site is present in unconfined conditions in

both the surficial sediments and underlying bedrock. Ground water movement at the site is

generally to the north and east, toward Lake Anna. Hydraulic conductivity values for the

saprolite range from about 0.2 to 3.4 ftld. SSAR Section 2.4.12 provides a detailed description

of the site ground water conditions.

2.5.1.2 Regulatory Evaluation

SSAR Section 2.5.1 presents information on the geologic and seismologic characteristics of the

ESP site region and area. In SSAR Section 1.8, the applicant stated that the information

presented in SSAR Section 2.5.1 conforms to the requirements of GDC 2 in Appendix A to

10 CFR Part 50, Subpart A of 10 CFR Part 52, and 10 CFR Part 100. The applicant also stated

in this section that it developed the geologic and seismologic information in accordance with the

guidance presented in RGs 1.70,1.165, 4.7 (Revision 2 dated 1998), 1.132, "Site Investigations

for Foundations of Nuclear Power Plants," Revision 2, dated October 2003, and RS-002. The

staff reviewed this portion of the application for conformance with the applicable regulations,

and considered the corresponding regulatory guidance, as identified above with the exception

that an ESP applicant need not demonstrate compliance with the GDC.

In reviewing the SSAR, the staff considered the regulations at 10 CFR 52.17(a)(1)(vi) and

10 CFR 100.23(c), which require that the applicant for an ESP describe the seismic and

geologic characteristics of the proposed site. In particular, 10 CFR 100.23(c) requires that an

ESP applicant investigate the geologic, seismologic, and engineering characteristics of the

proposed site and its environs with sufficient scope and detail to support evaluations to estimate

the SSE ground motion and to permit adequate engineering solutions to actual or potential

2-156
geologic and seismic effects at the site. Section 2.5.1 of NUREG-0800, RG 1.165, and

Section 2.5 of RG 1.70 provide specific guidance concerning the evaluation of information

characterizing the geology and seismology of a proposed site.

2.5.1.3 Technical Evaluation

This section of the SER provides the staff's'evaluation of the geologic and seismologic

information submitted by the applicant in SSAR Section 2.5.1. The technical information

presented in SSAR Section 2.5.1 resulted from the applicant's surface and subsurface

geological, seismological, and geotechnical investigations performed in progressively greater

detail as they moved closer to the'site. Through' its review, the staff determined whether the

applicant complied with the applicable regulations'and conducted its investigations with an

appropriate level of thoroughness within the four areas designated in RG 1.165, which are

based on various distances from the site (i.e., 200 miles, 25 miles, 5 miles; and 0.6 mile).

SSAR Section 2.5.1 contains the geologic and seismic information gathered by the applicant in

support of the vibratory ground motion analysis and site SSE spectrum provided in SSAR

Section 2.5.2. According to RG 1.165, applicants may develop the vibratory design ground

motion for a new nuclear power plant using either the EPRI or LLNL seismic source models for

the CEUS. However, RG 1.165 recommends that applicants update the geological,

seismological, and geophysical database and evaluate any new data to determine whether

revisions to the EPRI or LLNL seismic source models are necessary. As a result, the staff

focused its review on geologic and seismic data published since the late 1980s that could

indicate a need for changes to the EPRI or LLNL seismic source models.

To thoroughly evaluate the geologic and seismologic information presented by the applicant,

the staff obtained the'assistance of USGS. The staff and its USGS advisors visited the ESP

site and surrounding area to confirm the interpretations, assumptions, and conclusions

presented by the applicant concerning potential geologic and seismic hazards. The staff's

review of SSAR Section 2.5.1 focused on (1) tectonic or seismic information, (2) nontectonic

deformation information, and (3) conditions caused by human activities, with respect to both the

regional and site geology.

2.5.1.3.1 Regional Geology

The staff focused its review of SSAR Section 2.5.1.1 on the-applicant's description of the

regional tectonics, with emphasis on the Quaternary Period, structural geology, seismology,.-

paleoseismology, physiography, geomorphology, stratigraphy, and geologic history within a'

distance of 200 miles from the site. Based on its review~of SSAR Sections 2.5.1.1.1, 2.5.1.1.2,

and 2.5.1.1.3, as described below, the staff concludes that the applicant provided a thorough

and accurate description of these geologic features and characteristics in support of the ESP

application. In SSAR Section 2.5.1.1.1, the applicant described each of the physiographic

provinces within the site region, with an emphasis on the Piedmont province, where the ESP

site is located. In SSAR Section 2.5.1.1.2,the applicant described the geologic history of the

ESP site region, including each of the episodes of continental collisions and rifting. In SSAR

Section 2.5.1.1.3, the applicant'described the regional stratigraphy of the Piedmont province,

including the major rock units underlying the'site. These three SSAR sections describe welldocumented geologic information, and the staff concludes that they contain'an accurate and

thorough description of the regional geology as required by 10 CFR 52.17 and 10 CFR 100.23.

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In SSAR Section 2.5.1.1.4, the applicant described the principal tectonic structures within the

200-mile ESP site region based on the age of formation or reactivation of the structures. To

define the Quaternary tectonic (2 Ma-present) features, the applicant used the study of Crone

and Wheeler (Ref. 59, SSAR Section 2.5) as one of its criteria. This study is a compilation of

geologic information on Quaternary faults, liquefaction features, and possible tectonic features

in the CEUS. Crone and Wheeler evaluated and classified these features into one of four

categories (Classes A, B, C, and D) based on geologic evidence of Quaternary faulting or

deformation. The Crone and Wheeler classifications are based on an evaluation of the

information that is available in the published geoscience literature and not on a direct

examination of the actual geologic features. The applicant used the Crone and Wheeler

classifications as one of its criteria (SER Section 2.5.1.1.1 describes other criteria used by the

applicant) for assessing the potential Quaternary activity of the following faults:

* Hylas shear zone

* Lake of the Woods thrust fault

* Mesozoic rift basins

* Stafford fault system

* Central Virginia seismic zone

* Mountain Run fault zone

* seven fall lines

* East Coast fault system

For some of the above faults, the applicant used the Crone and Wheeler classifications as its

primary basis for assessing the potential Quaternary activity.

The staff determined that the applicant's use of the Crone and Wheeler classifications as a sole

or primary basis for assessing the potential Quaternary activity of the above features was

insufficient. Therefore, the staff asked the applicant in RAls 2.5.1-1 through 2.5.1-6 to provide

additional information to substantiate its claims for categorizing these features as noncapable.

The following sections describe the applicant's responses to RAls 2.5.1-1 through 2.5.1-6 and

the staff's evaluation of these responses.

Central Virginia Seismic Zone

Concerning the Quaternary tectonic features within the ESP site region, the applicant

concluded that only the CVSZ shows geologic evidence that demonstrates the existence of a

Quaternary fault of tectonic origin. The ESP site is located near the northern boundary of the

CVSZ (see SER Figures 2.5.1-3 and 2.5.1-4). The CVSZ is an area defined by moderate to low

historical seismic activity, as well as paleoseismicity, since Obermeier and McNulty recently

identified two paleoliquefaction features within the CVSZ (Ref. 71, SSAR Section 2.5). In its

response to RAI 2.5.1-1, the applicant stated that it interpreted the liquefaction features

identified by Obermeier and McNulty to represent at least one, and possibly two, moderate

magnitude earthquakes in the CVSZ in the middle to late Holocene epoch. However, because

of the absence of liquefaction features in otherwise susceptible middle to late Holocene

deposits elsewhere in the study area, Obermeier interprets these liquefaction features as the

result of localized, moderately sized (magnitude approximately 5.5 to 6.5) earthquakes. The

applicant stated that larger earthquakes with a magnitude of approximately 7 would have

produced a more widespread liquefaction field with more numerous, larger liquefaction

features. As a basis for its conclusion, the applicant stated that Dr. Obermeier canvassed

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thousands of meters of exposure of liquefiable deposits in his search area, and the absence of

liquefaction in these deposits and the restricted nature of the observed liquefaction features

indicate that a magnitude 7 earthquake has not occurr6d in the Holocene and that abundant

magnitude 6 to 7 earthquakes have not occurred in the Holocene within the CVSZ.

Concerning the implications of possibly two moderate-sized (magnitude 5.5 to 6.5) earthquakes

occurring in the CVSZ during the middle to late Holocene epoch (past 5,000 to 10,000 years),

the applicant stated that the occurrence of these earthquakes is consistent with the EPRI

seismic source recurrence estimates for the CVSZ. The average recurrence interval for

earthquakes with a magnitude greater than 6 within the CVSZ in the EPRI source'model is

7055 years. For somewhat smaller events (magnitude greater than 5.5), the EPRI source

model estimates about six events over a -period of 10,000 years.

Because of the absence of widespread liquefaction features in susceptible Holocene soil

deposits surveyed by geologists, the staff concurs with the applicant's conclusion that the few

liquefaction features within the CVSZ are most likely caused by a few local moderatemagnitude'earthquakes. The staff concludes that the' applicant accurately characterized the

impact of the paleoliquefaction features on the overall seismic characterization of the CVSZ. In

addition, the staff concurs with the applicant's conclusion that the occurrence of these

earthquakes is consistent with the EPRI seismic source recurrence estimates for the CVSZ.

Section 2.5.1.1.1 of this SER summarizes the applicant's revisions to SSAR Section 2.5.1 as a

result of RAI 2.5.1-1.

East Coast Fault System

The applicant cited another potential Quaternary tectonic feature known as the ECFS. The

ECFS-N is located approximately 70 miles southeast of the ESP site. Figure 2.5.1-6,

reproduced from the applicant's response to RAI 2.5.1-2, shows the postulated ECFS-S,

ECFS-C, and ECFS-N. The applicant concluded, in SSAR Section 2.5.1.1.4, that the ECFS-N

"probably does not exist or has a very low probability of activity if it does exist." The applicant

based its conclusion, in part, on an aerial reconnaissance of the ECFS-N. In its response to

RAI 2.5.1-2, the applicant stated that it primarily relied on a review of the evidence presented by

Marple and Talwani (Ref. 74, SSAR Section 2.5) to conclude that the ECFS-N probably does

not exist or, if it does exist, it has a very low probability of being active during the late Cenozoic

Era. Specifically, the applicant stated that, "In our view, Marple and Talwani did not perform a

very detailed or rigorous geomorphic analysis to conclude that an active fault is present

beneath the coastal plain of North Carolina and Virginia." The applicant stated that its aerial

reconnaissance of the ECFS-N played an important, but less significant, role in developing this

conclusion.

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To support its conclusion regarding the ECFS-N, the applicant evaluated the (1) geological

data, (2) geophysical and seismological data, and (3) geomorphic data used by Marple and

Talwani to infer the presence of the ECFS-N. The applicant stated that the only geologic data

that Marple and Talwani cite in support of the ECFS-N is the coincidence of the ECFS-N with

the westward termination of the Norfolk arch axis, which is shown above in Figure 2.5.1-6. In

their paper, Marple and Talwani note that their depiction of the Norfolk arch axis is modified

from a small-scale'map in Pazzaglia (Ref.' 6, RAI 2.5.1-2 in RAI Letter No. 3), which shows the

Norfolk arch axis'terminating westward against the Fall Line. The Fall Line is the boundary

between the Coastal Plain and Piedmont physiographic provinces and is a narrow zone of small

waterfalls and rapids that occurs at the point where the major rivers pass from the resistant

granites and other ancient rocks of the Piedmont to the more easily eroded sands, clays, and

shales of the Coastal Plain. Low hills rise to elevations of about 300 ft along the Fall Line.

Regarding this modification by Marple and Talwani, the applicant stated the following:

Specifically, Marple and Talwani (2000) have modified Pazzaglia's map by

showing the Norfolk arch axis as terminating about 25 km east of the Fall Zone,

on trend with their inferred location of the ZRA-N [ECFS-N]. Marple and Talwani

(2000) provide no additional references, interpretations or original data to justify

their changes to Pazzaglia's map'of the Norfolk arch axis. Thus; it is not'

possible to determine if their modification of the Norfolk arch axis is based on.

independent data, or simply are-interpretation of the Norfolk arch location that is

compatible with their model of the'ZRA-N [ECFS-N]. We conclude that the

location of the Norfolk arch axis, as presented in Marple and Talwani (2000), -

does' not provide independent geologic evidence in support of the ZRA-N

[ECFS-N]. Therefore, there is no known geologic evidence to support the

existence of the ZRA-N [ECFS-N] '-

The geophysical or seismological data presented by Marple and Talwani in support of the

ECFS-N is an east-west trending seismic reflection profile along Interstate 64 (1-64) through

Central Virginia. This geophysical inference of the ECFS-N is based on the Marple and Talwani

characterization of the seismic reflection data presented in a publication by Pratt et al. (Ref. 7,

RAI 2.5.1-2 in RAI Letter No. 3).'However,-the'applicant pointed out that Pratt and others-do

not interpret a steeply dipping crustal shear zone in the vicinity of the ECFS-N. The only

crustal-scale structure in this region interpreted by Pratt and others is an east-dipping shear

zone that underlies the Goochland terrain about 30 km beneath the inferred location of the -

ECFS-N. As such, the applicant concluded that the 1-64 seismic reflection profile does not

support the interpretation by Marple and Talwani.

The geomorphic data that Marple and Talwani use to postulate the existence of the ECFS-N

are inferred river anomalies. -Specifically,' Marple and Talwani use their interpretation of

geomorphic anomalies alongstreams that cross the inferred location of the ECFS-N to

postulate its existence. -These anomalies include channel incision, upward-displaced fluvial

surfaces, cross-valley change, sinuosity change, anastomosing stream pattem, and stream

deflections. The applicant stated that of these six categories of river anomalies, only "upwarddisplaced fluvial surfaces" require a tectonic interpretation. The other five anomalies are

examples of channiel pattern changethat can be and typically are produced by non-tectonicprocesses. The applicant examined each of these river anomaly categories with reference to

the ECFS-N to weigh the evidence for its existence and concluded the following: --

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'Mtn

Based on our independent assessment of "river anomalies" on the ZRA-N

[ECFS-N], we find (1) no evidence for the existence of a fault and (2) direct

stratigraphic evidence against the types of deformation postulated by Marple and

Talwani (2000). In some cases, we could not verify or duplicate geomorphic

observations, such as channel incision, cited by Marple and Talwani (2000). The

"upward displaced fluvial surfaces" cited in their paper are inferred only from

qualitative analysis of convexities of river profiles and, therefore, this type of

"anomaly" does not provide evidence for tectonic uplift and is inconsistent with

other geomorphic observations. And finally, we documented direct stratigraphic

evidence for no Quaternary deformation in the vicinity of a large meander of the

Nottoway River that Marple and Talwani (2000) interpreted to have formed in

response to systematic folding and northeastward tilting. We conclude that the

fluvial geomorphic features cited by Marple and Talwani (2000) are likely

produced by non-tectonic fluvial processes, are not anomalous, and, thus do not

support their interpretation of the presence and activity of the ZRA-N (northern

segment of the ECFS).

To evaluate the applicant's response to RAI 2.5.1-2, the staff reviewed the evidence presented by Marple and Talwani as well as the applicant's analyses of the evidence to support the

existence of the ECFS-N. The staff finds that the geologic, seismologic, and geomorphic evidence presented by Marple and Talwani to support the existence of the ECFS-N is

questionable. The staff concurs with the applicant's conclusion that the majority of the geologic data cited by Marple and Talwani in support of their postulated ECFS apply only to the central

and southern segments. There are no Cenozoic faults or structure contour maps indicating uplift along the ECFS-N. Accordingly, the staff finds that evidence for the existence and recent

activity of the northern segment of the ECFS is low; however, the staff believes that the

ECFS-N should be included as a possible contributor to the seismic hazard for the ESP site.

The applicant gave the ECFS-N a 10 percent probability of existence as part of its modeling of

the seismic sources to determine the SSE. The staff believes, based on its review of the

evidence, that a 10 percent probability of existence is an acceptable value. In summary, the

staff concludes that the applicant has adequately investigated the possibility of the existence of

an ECFS-N. Section 2.5.1.1.1 of this SER summarizes the applicant's revisions to SSAR

Section 2.5.1 resulting from RAI 2.5.1-2.

Local Faults

Other potential Quaternary tectonic features characterized by the applicant include the Hylas

shear zone, Mountain Run fault zone, and Lake of the Woods thrust fault. The Hylas shear

zone, Mountain Run fault zone, and Lake of the Woods thrust fault are prominent structural

features between 5 and 25 miles from the ESP site (see SER Figure 2.5.1-2). The applicant

concluded that these Paleozoic faults have not been reactivated and are therefore not capable

tectonic sources. In RAI 2.5.1-4, the staff asked the applicant to explain its conclusions

regarding the Hylas shear zone and Lake of the Woods thrust fault. In its response to

RAI 2.5.1-4, the applicant stated that these faults show no concentration or alignment of historic

seismicity, geomorphic expression, or Quaternary deformation. The applicant further stated

that, based on its review of the literature, these faults are Paleozoic structures with mylonitic

shear textures. This implies that the faults formed at deep crustal levels and that their current

surface exposure is the result of exhumation. Based on geologic evidence of Quaternary

faulting or deformation, Crone and Wheeler (Ref. 59, SSAR Section 2.5) categorize the

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Mountain Run fault zone as only:Class C. Crone and Wheeler's comprehensive database of

Quaternary features does not mention the Hylas shear zone and Lake of the Woods thrust

fault. Based on the lack of historical seismicity, geomorphic evidence, and Quaternary

defoormationr along the Lake of the Woods thrust fault and Hylas shear zone, the staff concurs

with the applicant's conclusion that these two faults are Paleozoic faults that have not been

reactivated during the Quaternary Period. Section 2.5.1.1.1 of this SER summarizes the

applicant's revisions to SSAR Section 2.5.1 resulting from RAI 2.5.1-4.

In RAI 2.5.1-5, the staff asked the applicant to describe the physiographic features associated

with the Mountain Run and Kelly's Ford scarps along the Mountain Run fault zone which led the

applicant to conclude that the scarps resulted from fluvial erosion and not tectonic deformation.

In its response, the applicant stated that it performed reconnaissance-level field and aerial

evaluations of the Mountain Run fault zone. To evaluate the potential for Quaternary activity of

the Mountain Run fault zone, the applicant examined several geologic profiles across the

Mountain Run fault zone, including both the Mountain Run and Kelly's Ford scarps. Based on

its examination across these geologic profiles, the applicant concluded the following:

* No consisten't expression of a scarp is present along the Mountain Run fault in the;

vicinity of the Rappahannock River." The northwest-facing Kelly's Ford scarp is similar to

a northwest-facing scarp along the southeastern valley margin of Mountain Run; both

scarps were formed by streams that preferentially undercut the southeastern valley

walls, creating asymmetric valley profiles. -

* No northwest-facing scarp is associated with the Mountain Run fault zone between the

Rappahannock and Rapidan rivers. Undeformed late Neogene (2-5 Ma) colluvial

deposits bury the Mountain Run fault zone in this region, demonstrating the absence of

Quaternary (2 Ma-present] fault activity.

* The northwest-facing Mountain Run scarp southwest of the Rapidan River alternates -

with a southeast-facing scarp on the opposite side of the Mountain Run valley; both sets

of scarps have formed by the stream impinging on the edge of the valley.

Based on the evidence cited in the applicant's response, the staff concludes that the scarps

along the Mountain Run fault zone are most likely products of fluvial erosion and not Cenozoic

fault activity. In particular, the Mountain Run fault zone is overlain by undeformed late Neogene

colluvial deposits and thus has not experienced Quaternary surface fault rupture.-

Section 2.5.1.1.1 of this SER summarizes the applicant's revisions to SSAR Section 2.5.1.

resulting from RAI 2.5.1-5.

The applicant also identified the seven fall lines across the Piedmont and Blue Ridge provinces

of North Carolina as another potential Quaternary tectonic feature. Weems identified these

seven fall lines (Ref. 70, SSAR Section 2.5), which are based on the alignment of short stream

segments with anomalously steep gradients. Because other studies of potential tectonic- - -

features in the CEUS do not include the seven fall lines identified by Weems, the applicant

concluded that they do not represent a capable tectonic source: In its response to RAI 2.5.1-3,

the applicant stated that Weems does not present direct credible evidence for a tectonic origin

of the fall lines. 'The applicant stated that thef all lines described by Weems are not defined by

formal, consistently applied criteriaVand thus are not as well defined and laterally continuous as

depicted. In particular, Weems selectively correlated different features to form a laterally2-163
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continuous fall line, while in other cases similar features are not correlated. The applicant also

stated that, based on its evaluation of the stratigraphic, structural, and geomorphic relations

across and adjacent to the fall zones, differential erosion resulting from variable bedrock

hardness is a more plausible explanation than Quaternary tectonism. As part of its response to

RAI 2.5.1-3, the applicant presented a detailed analysis of geologic and geomorphic data to

support its conclusion that the fall lines are not tectonic features. This analysis shows that

Weems postulated three hypotheses for the origins of the fall lines in the Blue Ridge and

Piedmont provinces:

(1) variable erosion across linear belts of rocks of varying hardness

(2) late Cenozoic climatic and sea level fluctuations, producing "waves" of headwaterretreating nick points that are expressed as fall zones and fall lines

(3) localized neotectonic uplift along fall lines

Weems rejected the first two hypotheses, stating that control of fall lines by rock hardness "is

true only locally and occurs as a consequence of uplift." He also stated that climatic control

does not adequately explain the observed patterns of fall lines. Weems concluded that tectonic

uplift "is the dominant cause of the existing Piedmont fall lines" because neither differential rock

erosion, nor regional creation of nick points by climate-driven changes in fluvial patterns, could

"adequately explain the observed patterns." The applicant concluded that Weems adopted a

tectonic interpretation primarily because the alternative interpretations were less compelling, and not because of direct evidence supporting a tectonic origin. The applicant also found that it

was unable to reproduce Weems' delineation of individual fall zones or his correlations of fall

zones as laterally continuous fall lines. In summary, the applicant found that Weems' model for

the lateral continuity of fall lines for hundreds of miles along trend in the Blue Ridge and

Piedmont provinces is based on subjective assessments of some steep stream reaches as

anomalous fall zones.

To further assess the claims made by Weems, the applicant conducted geomorphic analyses of

the Tidewater and Central Piedmont fall lines because these two features lie within the North

Anna site vicinity. Concerning the Tidewater fall line, the applicant found that a profile of

Pliocene marine sand shows no deformation across the Tidewater fall line at the

Rappahannock River. The applicant also found that a very strong correlation exists between

variations in rock type and gradient changes in the South Anna River profile that strongly

suggests that the Tidewater fall line formed as a result of variable erosion across rocks of

varying hardness. Concerning the Central Piedmont fall line, the applicant found that the

increased gradients along the Rapidan and Rappahannock Rivers as they exit the Culpeper

Basin are associated with Jurassic igneous rocks and Paleozoic metamorphic rocks, not

Triassic basin sediments as stated by Weems. The applicant stated that the observed gradient

as the streams leave the basin is explained by differential erosion of bedrock without invoking

tectonic deformation along the Central Piedmont fall line.

Based on the evidence cited by the applicant in response to this RAI, in particular the

applicant's evaluation of the stratigraphy and structural relations associated with the fall zones,

the staff concludes that the applicant has accurately characterized the seven fall lines as

nontectonic features. The staff concurs with the applicant's interpretation that differential

erosion resulting from variable bedrock hardness is a more plausible explanation than

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Quaternary tectonism for the fall lines. The staff notes that evidence for the existence of the

seven fall lines as a Quaternary tectonic feature is based solely on the work of Weems and that

other geologists have not made this inference. Section 2.5.1.1.1 of this SER summarizes the

applicant's revisions to SSAR Section 2.5.1 resulting from RAI 2.5.1-3.-

The Stafford fault system approaches to within 16.5 miles of the ESP site to the northeast. In

SSAR Section 2.5.1.1.4, the applicant concluded that there is no Quaternary activity along the

fault system. In RAI 2.5.1-6, the staff asked the applicant to elaborate on the field observations

and aerial reconnaissance that support this conclusion. In its response, the applicant stated

that it based its conclusion that the Stafford fault system is not a capable tectonic source on a

review of existing literature, discussions with researchers familiar with the area, aerial and field

reconnaissance, and geomorphic analyses. The applicant examined the topographic profiles of

several terraces that cross the Stafford fault system and found only minor, nontectonic relief on

some of the terrace surfaces. In addition', the applicant did not find any scarps or anomalous

breaks in the topography on the terrace surfaces associated with the mapped fault traces.

Based on the evidence cited by the applicant, in particular the applicant's examination of the'

topography of the'profiles that cross the fault system, the staff concludes that the applicant

accurately characterized the Stafford fault'system as being inactive-during the Quaternary'

Period.

Based on its review of SSAR Section 2.5.1.1.4 and the applicant's responses to the RAls, cited

above, the staff concludes that the applicant identified and properly characterized all regional.

tectonic features. The staff concludes that SSAR Section 2.5.1.1.4 provides an accurate and

thorough description of the regional tectohics,'with an emphasis on potential Quaternary

activity, as required by 10 CFR 52.17 and 10 CFR 100.23. :-

To support its ge6logic interpretations of the region surrounding the ESP site, the applicant in

SSAR Section 2.5.1.1:5 reviewed the regional 'maps of gravity and magnetic anomalies

published by GSA in 1987. The applicant used the-regional gravity map to identify the

Piedmont gravity gradient and interpreted this feature as an eastward thinning of the North

American crust and lithosphere. The applicant interpreted the regional magnetic anomalies as

upper crustal variations in magrietic susceptibility, such as mafic and ultramafic rocks, and used

the magnetic data as supporting evidence for its interpretation of its seismic reflection data.

The staff concludes that the'regional gravity and -magnetic data support the applicant's overall

conclusions concerning the regional geologic and tectonic features. --

2.5.1.3.2 Site Geology

The staff focused its review of SSAR Section 2.5.1.2 on the applicant's description of the siterelated geologic features, seismic conditions, and conditions caused by human activities.

Based on its review of SSAR Sections 2.5.1.2.1 and 2.5.1.2.2, described below, the staff

concludes that the applicant has provided a thorough and accurate description of these

geologic features and chafacteiristics in support of the ESP application: In SSAR

Section 2.5.1.2.1, the applicant described the- local topography as gently undulating, varying in

elevation from'about 200 to 500 ft with the site grade for the existing units at about 271 ft. InSSAR Section 2.5.1.2.2, the applicant described the compressional orogenies and extensional

episode that produced the folding and faulting in the region surrounding the site. -The applicant

also described the local erosion and Weathering that produced the residual soils that cover the

ESP site. The staff concludes that these two SSAR sections, which describe readily observable

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local geologic features, contain an accurate and thorough description of the local site geology

as required by 10 CFR 52.17 and 10 CFR 100.23.

In SSAR Section 2.5.1.2.3 the applicant described the soil and rock layering beneath the ESP

site. The applicant based its description of the site stratigraphy on several borings performed

for the existing NAPS Units 1 and 2 and the abandoned NAPS Units 3 and 4, and as part of the

ESP application subsurface program. The applicant stated in SSAR Section 2.5.1.2.3 that the

borings drilled as part of the ESP application subsurface program reveal "severely weathered,

fractured and jointed intervals in Zone III-IV and Zone IV rock," and that these fracture zones

range in thickness from about 0.5 to 1 foot thick. The applicant encountered these fracture

zones in four of the seven new borings performed as part of the ESP subsurface program. In

RAI 2.5.4-2, the staff asked the applicant to describe the impact of the fracture zones on the

suitability of the site to host safety-related structures. In response to RAI 2.5.4-2, the applicant

stated that it would excavate and replace with lean concrete any weathered or fractured zones

encountered at the foundation level. In addition, the applicant stated that it would perform

multiple borings once the building locations are chosen. These borings will identify whether

there are any fracture zones beneath the foundation thicker than those encountered in the ESP

borings. The staff concludes that the applicant's proposal to excavate and replace weathered

or fractured zones with lean concrete is an adequate method to ensure the stability of the

foundation. The replacement of fractured rock with lean concrete is well understood and

commonly done to enhance the strength and stability of the rock to support building loads.

Accordingly, the NRC staff proposes to include a condition in any ESP that might be issued

requiring that the ESP holder and/or an applicant referencing such an ESP replace weathered

or fractured rock at the foundation level with lean concrete before initiation of foundation

construction. This is Permit Condition 5. In addition, the applicant's proposal to perform

additional borings, once it has selected building locations, is necessary to ensure that any

significant weathered or fractured zones are identified. The need for additional borings to

identify any weathered or fractured rock beneath the new foundations is COL Action

Item 2.5-1. Section 2.5.4 of this SER provides further discussion of the above permit condition

and action item as well as the engineering properties of the soil and rock beneath the ESP site.

Based on its review of SSAR Section 2.5.1.2.3 and the applicant's response to the staff's RAls,

cited above, the staff concludes that the applicant adequately described the site area

stratigraphy. The staff concludes that SSAR Section 2.5.1.2.3 provides an accurate and

thorough description of the site area stratigraphy, with an emphasis on the uppermost layers of

rock and residual soil, as required by 10 CFR 52.17 and 10 CFR 100.23. Section 2.5.4 of this

SER provides the staff's complete evaluation of the applicant's description of the ESP site

subsurface materials and engineering properties.

SSAR Section 2.5.1.2.4 describes the local faults and folds within the metamorphic bedrock

underlying and surrounding the site. The applicant identified seven bedrock faults within a

5-mile radius of the ESP site and concluded, based on site area investigations and a review of

the published literature, that none of the faults are capable tectonic sources, as defined in

RG 1.165. The NAPS licensee thoroughly investigated one of the faults, unnamed fault "a,"

which traverses the ESP site, following its exposure within the excavations for the abandoned

Units 3 and 4. The staff concluded in its 1974 SER for the abandoned Units 3 and 4 that the

"North Anna fault zone is neither genetically nor structurally related to any known capable fault,"

and concurred with Virginia Power's conclusion that fault "a" is not a capable tectonic source.

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Subsequent to Virginia Power's investigation, a local geologist mapped fault "a" over a total

distance of about 7 miles, which is considerably longer than the original length of about 3000 ft

mapped by Virginia'Power. In RAI 2.5.3-2, the staff asked the applicant to evaluate the

evidence for the continuation of fault "a" beyond the ESP site. In its response, the applicant

stated that the local geologist; L. Pavlides, is deceased and did not document an explanation or

basis for his mapping of fault "a" beyond the ESP site. The applicant performed aerial

reconnaissance, field reconnaissance, and an air photo interpretation of fault "a" and, based on

these studies, concluded that no stratigraphic, structural, or geomorphic evidence would

support the existence of fault 'a" beyond the EPS site. Based on the evidence presented by the

applicant, in particular the evidence cited as a result of the field reconnaissance described

below, the staff concludes that the applicant has adequately investigated the possible extension

of fault ua" beyond the ESP site. During its field reconnaissance, the applicant found no scarps

or lineaments along the trace of fault ua" as mapped by Pavlides. The staff notes that the

NAPS licensee's trenching of the fault shows that fault "a" is most likely a minor fault or bedrock

shear within the Ta River metamorphic suite and that it is very unlikely that such a minor fault

could be recognized or mapped over-a significant distance without a significant number of

exposures. Section 2.5.3 of this SER provides further discussion of fault "a" and RAI 2.5.3-2.

Based on its review of SSAR Section 2.5.1.2.4 and the applicant's response to RAI 2.5.3-2,

cited above, the staff concludes that the applicant adequately described the site area structural

geology. The staff concludes that SSAR Section 2.5.1.2.4 provides an accurate and thorough

description of the site area structural geology, with an emphasis on the structural features

within a 5-mile radius of the ESP site, as required by 10 CFR 52.17 and 0 CFR 100.23. ;

Section 2.5.3 of this SER provides the staff's complete evaluation of the applicant's description

of the local bedrock faults near the ESP site and their potential for tectonic deformation and

producing vibratory ground motion.

SSAR Section 2.5.1.2.5 states that the only geologic hazards associated with the ESP site are

(1) vibratory ground motion from regional earthquake activity and (2) potential surface faulting

from site area earthquakes. SSAR Sections 2.5.2 and 2.5.3, respectively, discuss these two

potential geologic hazards. 'The corresponding sections of this SER provide the staff's review

of these potential hazards. In SSAR Table 1.9-1, the applicant identified the item, "Capable

Tectonic Structures or Sources," as an ESP site characteristic and design parameter. This item

specifies that there is no fault displacement potential within the investigative area.. The staff

reviewed the applicant's description of the site area geologic hazards provided in SSAR

Section 2.5.1.2.5 and concludes that the ESP site has no fault displacement potential.

Section 2.5.3 of this SER provides the staff's evaluation of the fault displacement potential for

the ESP site. The staff concludes that SSAR Section 2.5.1.2.5 does not address two other

potential site area geologic hazards, namely slope instability and liquefaction, also arising from

local or regional earthquakes. However, the applicant addressed these two topics in detail in

SSAR Sections 2.5.4 and 2.5.5.

SSAR Section 2.5.1.2.6 describes the engineering behavior of soil and rock at the ESP site. In

addition, SSAR Section 2.5.1.2.6 addresses prior earthquake effects, effects of human

activities (mineral extraction and ground water withdrawal), construction ground water control,

and unforseen geologic features. In its description of the soil engineering behavior, the

applicant stated that the high compressibilities and low maximum densities of the saprolite

preclude its use as engineered fill at the ESP site. Because of the relatively high initial

settlement of the NAPS pumphouse structure, constructed on about 65 ft of saprolite fill, the

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staff agrees with this conclusion. Accordingly, the staff is proposing Permit Condition 6, which

would prohibit the ESP holder and/or an applicant referencing such an ESP from using an

engineered fill with high compressibility and low maximum density, such as saprolite.

Based on its review of SSAR Section 2.5.1.2.6, the staff concludes that the applicant has

adequately described the site soil and rock characteristics. In particular, the applicant

thoroughly described zones of weathering and structural weakness within the soils and

bedrock, soil and rock types that could be unstable because of their physical properties, and the

effects of human activities (e.g., mining extraction and ground water withdrawal) at the site.

The staff concludes that SSAR Section 2.5.1.2.6 provides an accurate and thorough description

of the local site conditions, as required by 10 CFR 100.23. In addition, because of limited

ground water withdrawal and the distance of any mining activity from the site, the staff

concludes there is no potential for the effects, such as subsidence or collapse, of human

activity that could compromise the safety of the site.

SSAR Section 2.5.1.2.7 describes the ground water at the ESP site in terms of flow direction

and hydraulic conductivity. SSAR Section 2.4.12 provides a detailed discussion of the site

ground water conditions; Section 2.4.12 of this SER discusses the staff's evaluation of SSAR

Section 2.4.12.

2.5.1.4 Conclusions

As set forth above, the staff reviewed the geologic and seismologic information submitted by

the applicant in SSAR Section 2.5.1. On the basis of its review, as described above, the staff

finds that the applicant provided a thorough characterization of the geologic and seismologic

characteristics of the site, as required by 10 CFR 100.23. These results provide an adequate

basis to conclude that no capable tectonic faults exist in the plant site area (5 mi) that have the

potential to cause near-surface displacement. The staff concurs with the applicant's

classification of the CVSZ as a capable seismogenic source zone rather than a tectonic source

zone, since no capable tectonic sources have been identified within the CVSZ. In addition, the

staff concludes, as described above, that the applicant has identified and appropriately

characterized all the seismic sources significant to determining the SSE for the ESP site, in

accordance with RG 1.165 and NUREG-0800, Section 2.5.1. Based on the applicant's

geological, geophysical, and geotechnical investigations of the site vicinity and site area, the

staff concludes that the applicant has properly characterized the site lithology, stratigraphy,

geological history, structural geology, and the characteristics of subsurface soils and rocks.

The staff also concludes that there is no potential for the effects of human activity (i.e., ground

water withdrawal or mining activity) to compromise the safety of the site.

2.5.2 Vibratory Ground Motion

SSAR Section 2.5.2 describes the applicant's determination of the ground motions at the ESP

site from possible earthquakes in the site area and region. SSAR Sections 2.5.2.1 through

2.5.2.4 describe the seismic source and ground motion models used by the applicant. SSAR

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Section 2.5.2.5 summarizes the seismic wave transmission characteristics of the ESP site.

Finally, SSAR Section 2.5.2.6 describes the development of the SSE ground motion for the

ESP site.

The applicant stated that the information provided in SSAR Section 2.5.2 complies with -

NUREG-0800 and uses the procedures recommended in RG 1.165. In addition, the applicant,

based its seismic ground motion calculations on the EPRI seismic source model for the CEUS.

According to RG 1. 1 65, applicants may use the seismic source interpretations developed by

LLNL in 1993 or those developed by EPRI as inputs for-a site-specific analysis; RG 1.165 also

recommends a review and update, if necessary, of both the seismic source and ground motion

models used to develop the SSE ground motion for a given site.

2.5.2.1 Technical Informration in the Application

2.5.2.1.1 'Seismicity

SSAR Section 2.5.2.1 describes both the review and update of the earthquake catalog used to

define the seismic sources for the ESP site.: The applicant used the original EPRI seismicity

catalog, which is complete only through 1984. Therefore, in addition to reevaluating the EPRI

catalog, the applicant added seismicity data for the time period from 1985 through 2001 (see

SER Figure 2.5.1-4).

The seismicity catalog used for the original EPRI study compiled the data from'the seismic

networks in the CEUS. Therefore, to develop the EPRI catalog, it was necessary to remove

duplicate earthquakes,' ensure a consistent magnitude scale (mb), remove data from events

other than earthquakes (e.g., mine blasts and sonic booms), and perform a final check to

ensure that the catalog includes significant historic events. To update the 1984 EPRI seismicity

catalog, the applicant focused on sources of seismic data in the region surrounding the ESP

site. The applicant stated that the most complete regional catalog for recent earthquakes is*

published by the Virginia Polytechnic Institute and State University (VT) and maintained by

Martin Chapman of VT. The VT seismic catalog is complete through 2001 for Virginia,

Maryland, Delaware (south of latitude 40° N), West Virginia (south of latitude 400 N), North

Carolina, South Carolina, Georgia,' Florida, Alabama, Tennessee (east of longitude 880 W), and

Kentucky (east'of longitude 880 W). .However, the VT seismic network and database do not

completely cover the region surrounding the ESP site. To'supplement the VT catalog,- the

applicant used the seismic catalog from the Advanced National Seismic System (ANSS) for

latitudes of 39.70 N and higher. The updating of seismicity in the ESP site region bounded by

latitude 350 to 41 0 N and longitude 740 to 820 W resulted in the identification of 30 additional

earthquakes (24 from the .VT catalog and 6 from the ANSS catalog).:

2.5.2.1.2 Geologic Structures and EPRI Seismic Source Model for the Site Region

SSAR Section 2.5.2.2 describes the seismic-source interpretations from the 1989 EPRI study

and the evaluation of new information on seismic sources since the EPRI study. In general, the

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applicant found that the 1989 EPRI seismic source models did not need to be updated for the

ESP site seismic source characterization.

Six independent earth science teams (ESTs) developed the characterization of CEUS seismic

sources in the EPRI project. These ESTs evaluated geological, geophysical, and seismological

data to model the occurrence of future earthquakes and analyze earthquake hazards at nuclear

power plant sites in the CEUS. The six ESTs involved in the EPRI project included (1) the

Bechtel Group, (2) Dames and Moore, (3) Law Engineering, (4) Roundout Associates,

(5) Weston Geophysical Corporation, and (6) Woodward-Clyde. Consultants. EPRI

implemented the results of the seismic source characterizations from each of the ESTs in a

PSHA for nuclear power plant sites in the CEUS. SSAR Tables 2.5-5 through 2.5-10

summarize the seismic source information developed by each of the ESTs for sources in the

region surrounding the ESP site. This information includes the Mmax, closest distance to the

ESP site, probability of activity, and an indication as to whether new information regarding the

seismic source has been identified since the original EPRI seismic hazard analyses. The

application does not present earthquake recurrence values for each of the seismic sources

because the recurrence values were computed for each 1-degree latitude and longitude cell

that intersects any portion of a seismic source and, as such, many larger source zones have

multiple recurrence values.

In RAI 2.5.2-4(a), the staff asked the applicant to provide additional seismicity parameters,

beyond those shown in SSAR Tables 2.5-5 through 2.5-11, for the seismic source zones

surrounding the ESP site. In response to RAI 2.5.2-4(a), the applicant provided the seismic

source recurrence values used for the EPRI study for the 1-degree latitude and longitude cell

encompassing the ESP site region. SER Section 2.5.2.3.2 provides a complete description of

the applicant's response to RAI 2.5.2-4(a) and the staff's review of the applicant's response.

The applicant stated the following concerning the seismic source characterizations of the

original EPRI study:

Except for the three specific cases described earlier [below], no new

seismological, geological, or geophysical information in the literature published

since the publication of the 1986 EPRI source model (Reference 120) suggests

that these sources should be modified. The three cases where new information

requires modification of the EPRI source characterizationsis the addition of the

northern segment of the [East Coast Fault System] ECFS (ECFS-N) as a new

potential seismic source, the new recurrence and geometry parameters for the

existing Charleston source (modeled after the southern segment of the [East

Coast Fault System] ECFS (ECFS-S), and the new recurrence parameters for

the New Madrid source.

SSAR Sections 2.5.2.2.2 through 2.5.2.2.7 briefly describe the seismic source characterizations

made by the six ESTs for each of the sources surrounding the ESP site. Since the largest

contributor to the seismic hazard at the ESP site is the CVSZ, the applicant described its source

characterization by the six ESTs in SSAR Section 2.5.2.2.8. The six ESTs characterize the

largest Mmax earthquake for the CVSZ as mb 6.6 to 7.2, with each magnitude value

accompanied by a weight.- For example, the Dames and Moore EST assigned the Mm values

for the CVSZ as mb 6.6 'and 7.2, with a corresponding weight for these two magnitudes of 0.8

and 0.2, respectively. The applicant stated that, since the EPRI study, two paleoliquefaction

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features have been found within the CVSZ, and that these new observations are "consistent

with the Mmax values and recurrence parameters assigned bylthe EPRI teams." Furthermore, in

SSAR Section 2.5.2.2.8, the applicant concluded the following:

The lack of widespread liquefaction features in the 300 km of stream exposures

searched within the CVSZ, despite the presence of mid-to-late-Halocene

potentially liquefiable deposits, has led someresearchers (Reference 71) to ''

conclude that it is unlikely that any earthquakes have occurred in the area'

investigated in excess of M-7 during the Holocene.

In RAI 2.5.2-7, the staff asked the applicant to describe how the modern' and historical

seismicity of the CVSZ is distributed within either a specific source zone or a background

source zone. In its response, the applicant described the source model used by each of the'six

EPRI teams to characterize the CVSZ. SER Section 2.5.2.3.2 provides a complete description

of the applicant's response to RAI 2.5.2-7 and the staff's review of the applicant's response.

In RAI 2.5.2-4(b), the staff asked the applicant to justify its decision not to update the Mmax

assigned to the CVSZ for the 1989 EPRI seismic source models, considering the 1994 EPRI'

study, "Seismotectonic Interpretation and Conclusion from the Stable Continental Region

Database." In its response, the applicant stated that EPRI initiated the 1994 study in the"

mid-1 980s specifically for use by the EPRI teams in their development of the 1989 EPRI

seismic source models. EPRI provided the preliminary results of the 1994 study to each of the

EPRI teams for their use in assigning Mmaxvalues in stable continental regions (SORs), such as

the ESP site region. As such, the EPRI teams used the estimates of Mmx and source zone

geometry drawn from the preliminary results of the 1994 EPRI study for their 1989 seismic

source models. SER Section 2.5.2.3.2 provides 'a complete'description of the applicant's

response to RAI 2.5.2-4(b) and the staff's review of the applicant's response.

SSAR Section 2.5.2.2.9 describes the post-EPRI PSHA studies within the North'Anna site

region for comparison with the PSHA completed as part of the ESP application. Since the EPRI

seismic hazard project, researchers have completed three PSHA studies that overlap or include

the seismic sources within the North Anna site region. These three studies include the

following:

* Savannah River nuclear site (Ref. 125, SSAR Section 2.5)

* seismic hazard of Virginia (Ref. 126, SSAR Section 2.5) -

* USGS National Seismic Hazard Mapping Project (Ref. 127, SSAR Section 2.5)

The PSHA perforimed for the Savannah River nuclear site in South Carolina specifies sources,

recurrence rates, focal depths, and M .. values for earthquake sources 'in' the southeastern

United States. As part of the Savannah River PSHA, Bollinger (Ref. 125,'SSAR

Section 2.5) identified three seismic sources that fall within the North Anna site region. 'These

sources include the CVSZ, the Giles County seismic zone, and ancomplementary background

zone., For the CVSZ, the Savannah River PSHA assigns an Mma of mb 6.4, which is

comiparable to the range of M- values given for the CVSZ by the EPRI teams. For the Giles''

County seismi6'z6ne and complementary background zone, the Sa6vaninah River PSHA assigns

maximum values of 6.3 and 5.7, respectively.' These Mmax values are also similar to those used

by the EPRI teams for these two source zones.

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The applicant stated that researchers at VT (Ref. 126, SSAR Section 2.5) performed a seismic

hazard assessment of Virginia in 1994 on a county-by-county basis. The study defined a total

of 10 seismic sources based primarily on patterns of seismicity, with 7 of the 10 sources located

within the region surrounding the North Anna site. For each source zone, the authors of the

study assumed an Mmax of mb 7.25. This Mmax is based on the assumption that an earthquake

similar to the one that occurred in 1868 in Charleston, South Carolina (mb 6.8 to 7.5), could

occur in any of the sources within the North Anna site region. The applicant stated that this

Mmax is consistent with the range of Mmax values that the EPRI teams assigned to the CVSZ and

Giles County seismic zones.

The third PSHA performed after the EPRI 1989 study was the 2002 USGS National Seismic

Hazard Mapping Project. The 2002 USGS national seismic hazard maps are the updated 1996

USGS seismic hazard maps that incorporate changes in the recurrence and geometry of the

Charleston, South Carolina, seismic source, as well as the recurrence and Mmax assigned to the

New Madrid seismic source zone. Rather than defining many local seismic- source zones, the

USGS hazard study includes only a small number of sources surrounded by larger background

zones. Within the ESP site region, the USGS model defines a single source zone, the

Extended Margin Background Zone, which covers nearly the entire eastern and southeastern

United States. The Mmax value assigned to the Extended Margin Background Zone by USGS is

7.5, which corresponds to mb 7.2. The applicant stated that this Mmax value is consistent with

the range of maximum values assigned to the CVSZ by the EPRI teams.

2.5.2.1.3 Correlation of Seismicity with Geologic Structures and EPRI Sources

As part of the review and update of the 1989 EPRI seismic source model, the applicant

compared the updated seismicity (1985 through 2001) with the earlier EPRI seismicity catalog

(1627 through 1984). As a result of this comparison, the applicant concluded that the updated

catalog does not show (1) any earthquakes within the site region that can be associated with a

known geologic structure, (2) a unique cluster of seismicity that would suggest a new seismic

source outside of the EPRI source model; (3) a new pattern of seismicity that would warrant

significant revision to the EPRI seismic source geometry, (4) an increase in the MMax for any of

the EPRI seismic sources, and (5) any changes to the recurrence values for the EPRI seismic

sources.

2.5.2.1.4 1989 EPRI Probabilistic Seismic Hazard Analysis, Deaggregation, and 1-Hz, 2.5-Hz,

5-Hz, and 10-Hz Spectral Velocities

SSAR Section 2.5.2.4 describes the confirmation of the 1989 EPRI PSHA results for North

Anna. For its confirmation, the applicant used the peak ground acceleration (PGA) hazard

curves for comparison with the 1989 EPRI PSHA results for North Anna. The applicant found

that the average difference in annual probability of ground motion exceedance is +1.1 percent,

which corresponds to a 0.3 to 0.7 percent increase of the ground motion amplitude. This

difference is much less than the total uncertainty in seismic hazard calculations, and, as such,

the applicant concluded that the current PSHA for. the ESP site correctly models the seismic*

sources and ground motion equations. To further confirm the accuracy of the current PSHA,

the applicant also replicated the 11-, 2.5-, 5-, and 1 0-Hertz (Hz) spectral velocity hazard curves

using the 1989 EPRI seismic sources and ground motion models. In addition, using the

procedure described in RG 1.165, the applicant calculated the controlling earthquakes for the

ESP site using the 1989 EPRI results. The low-frequency controlling earthquake magnitude

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and distance are M, 5.9 and 25 km, respectively, and the high-frequency controlling earthquake

magnitude and distance are M, 5.5 and 18 km, respectively. The applicant used these

controlling earthquakes for comparison with the updated PSHA results for the ESP site

presented in SSAR Section 2.5.2.6.1.

2.5.2.1.5 Seismic Wave Transmission Characteristics of the Site

SSAR Section 2.5.2.5 briefly summarizes the subsurface model used for the ESP site. The

foundation materials are divided into the following five zones from surface to bedrock:

* residual clays and clay silts (Zone I)

* weathered saprolite (Zone IIA)

* saprolite (Zone IB)

* weathered rock (Zone 1II)

* parent rock (Zone IV)

The applicant stated that the containment (reactor building) and primary safety-related

structures would be founded on sound bedrock, either Zone IV or Zone III-IV (slightly to

moderately weathered rock). The applicant also stated that other safety-related structures

(possibly the diesel generator building and certain tanks) may be founded on Zone IlIl

weathered rock or Zone II saprolitic soils. -.

Section 2.4.5.7 of the SSAR presents a detailed description of the seismic wave transmission

characteristics of each of the above soil and rock layers. The description includes the shear -

wave velocity, as well as the variation of shear modulus and damping with strain for each of the

zones.

In RAls 2.5.2-1(c) and 2.5.2-8, the staff asked the applicant to explain how it factored the

properties of the site-specific subsurface materials into the determination of the SSE. In itsresponses, the applicant stated the following:

The SSE spectrum is calculated directly using the EPRI 2003 ground motion

models. For the North Anna ESP site, the selected SSE directly incorporates the

hard rock foundation assumption of the EPRI 2003 ground motion models (a

shear-wave velocity of 2.8 km/s or about 9,200 ft/s). The containment (reactor)

building and primary supporting safety-related structures would be founded on

sound bedrock, either Zone IV or Zone III-IV materials (see SSAR

Section 2.5.2.5) for which this shear wave velocity is a good approximation.

Therefore, site-specific materials are factored into the determination of the SSE

by recognizing that the hazard analysis performed to develop the SSE uses

attenuation relations that are directly applicable to specific subsurface conditions

at the North Anna site. - - -

As set forth in the DSER, the staff considered the applicant's response above to be inadequate

based on a comparison of the hard rock shear wave velocity (9200 ft/s) assumed by the EPRI

2003 ground motion models and the bedrock Zone 111-IV shear wave velocity (3300 ft/s)

beneath the ESP site. DSER Open Item 2.5-2 covered the necessity to include the local site

conditions in the determination of the SSE. As.a result of Open Item 2.5-2, the applicant reran

its analysis to determine the seismic wave transmission characteristics of the site. The

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applicant's new analysis used a rock subsurface profile that extends from the top of Zone III-IV

bedrock to a depth of 160 ft under the site where the shear wave velocity reaches about

9200 ft/s. The applicant used the ESP rock subsurface profile to estimate the amplification of

the SSE ground motion at a control point located at the top of competent Zone III-IV rock. The

following SER Section (2.5.2.1.6) provides a complete description of the applicant's response to

Open Item 2.5-2, and SER Section 2.5.2.3.5 provides the staff's evaluation of the applicant's

response.

2.5.2.1.6 Safe-Shutdown Earthquake Ground Motion

SSAR Section 2.5.2.6 describes the development of the SSE ground motion for the ESP site.

The first four subsections of SSAR Section 2.5.2.6 describe the updating of the 1989 EPRI

PSHA in terms of (1) a new regional earthquake catalog, (2) new Mmax information, (3) new

seismic source characterizations, and (4) new ground motion models. The subsequent

subsections of Section 2.5.2.6 describe (1) the controlling earthquakes, (2) the selected SSE

ground motion, (3) sensitivity studies, and (4) the future modification of the selected SSE

spectrum.

SSAR Section 2.5.2.6 addresses the new geoscience information (new seismic sources, new

magnitudes, new recurrence intervals, new ground motion models) by examining the effect of

this new information on the median seismic hazard at levels of 1 0' per year. The applicant

used the 1989 EPRI seismic sources and ground motion models to compare the effect of this

new information on the seismic hazard at the ESP site with the seismic hazard developed for

North Anna.

New Regional Earthquake Catalog

This section compiles the seismic sources surrounding the ESP site that contribute 99 percent

of the seismic hazard, using both the PGA hazard results and the 1-Hz spectral velocity hazard

results. The applicant used this compilation of seismic sources from the 1989 EPRI PSHA to

determine whether the seismic activity rates used in the 1989 EPRI study are still adequate.

The applicant examined recent seismic activity rates using earthquakes recorded in the region

since 1984 and compared these rates to-those used in the 1989 EPRI PSHA. The results of

this comparison show that recent seismicity, recorded from 1985 to 2001, indicates that seismic

activity rates have decreased for the sources contributing most to the ESP site. Therefore, the

applicant used the seismic activity rates derived from the 1989 EPRI study to calculate the

seismic hazard at the ESP site.

New Maximum Magnitude Information

This section describes the applicant's review of the geologic and seismologic data published

since the 1986 EPRI seismic source model to determine if changes to the Mmax values for any of

the seismic source zones are needed. The applicant stated that the Mmax used for the EPRI

source models relied on an EPRI study (Ref. 195, SSAR Section 2.5) of large earthquakes

occurring worldwide within SCRs. Based on its review, the applicant concluded that the range

of Mmax values assigned by the EPRI teams for the Charleston, South Carolina, seismic source

is too low. For the Charleston seismic source, the applicant identified a new geologic structure

as the possible source of the 1886 Charleston earthquake, referred to as the ECFS-S. For the

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ECFS-S Mmax values, the applicant decided to use the 2002 USGS values and weights. These

Mmax values range from Mw 6.8 to 7.5. The Charleston source Mmax values used by the six EPRI

teams for the 1989 PSHA range, from Mw 6.5 to 8.0. -*r

New Seismic Source Characterizations . .

This section describes the applicant's review of the geologic and seismologic data published

since the 1989.EPRI seismic source model to determine whether any new seismic sources

have been postulated or whether significant changes to the characterizations of previously

identified sources are needed.. The applicant concluded that three changes to the 1989 EPRI

seismic source characterizations were necessary, namely (1) identification of a postulated

ECFS-N, (2) revision to the recurrence interval and source geometry of the Charleston seismic

source, and (3) revision to the recurrence interval of the New Madrid seismic source..

As modeled, the ECFS runs along the Atlantic seaboard and consists of the ECFS-N, ECFS-C,

and ECFS-S (see SER Figure 2.5.1-6). The ECFS-N is located approximately 70 miles

southeast of the ESP site and was not previously included in the 1989 EPRI PSHA. For the

ECFS-N, the applicant assumed a probability of existence of 0.1 ;and a probability of activity

(given existence) of 0.1.- For the ECFS-N, the applicant adopted the Mmax parameters and

weights used in the 2002 USGS national seismic hazard map for the Charleston source. The

applicant selected the recurrence values and weights of 550 years (0.1), 25,000 years (0.5),

and 50,000 years (0.4), respectively. The applicant stated that it assigned low weights to the

probability of existence and probability of activity-because the existence of the fault is not well -

documented and is highly uncertain. In addition, no geologic, geomorphic, or seismologic

evidence indicates that the fault exists as a tectonic feature or, if it does exist, that it is active.

New data published since the original EPRI study have resulted in revisions to the recurrence -

interval and source geometry for the Charleston seismic source.. As stated earlier, the applicant

adopted the Mmax values used by.the 2002 USGS national hazard maps for the Charleston

seismic source. In addition to the Mmax values, the applicant also reduced the recurrence

interval for the Charleston source from several thousand years, used by the 1989 EPRI PSHA,

to 550 years. The applicant stated that it based the reduction in the recurrence interval for the

Charleston seismic source on recent paleoliquefaction studies, which provide evidence of

previous earthquakes in the Charleston source area. In addition to M,. values and recurrence

intervals, the applicant used the ECFS-S as an alternative source geometry for the Charleston

source. The applicant also assumed that the mean recurrence interval of 550 years applies to

the M,,X values. The applicant stated that this approach is conservative because the mean

recurrence interval may not be directly associated with earthquakes as large as the assumed

Mmax values. -

In RAI 2.5.2-5, the staff asked the applicant to explain how it incorporated the alternative

characterization ofthe ECFS-S into the final PSHA. In its response, the applicant stated that it

evaluated the alternative characterization of the ECFS-S, both independently and additively, to

conservatively assess the maximum possible change to hazard at the North Anna ESP site

from this newly postulated source. The revisions to the ECFS-S include a shorter recurrence

interval (550 years) and different weights for the M,,, (M, 6.8 to 7.5). The applicant added the

ECFS-S to the source models of each of the six EPRI teams for the final PSHA. SER

Section 2.5.2.3.4 provides a complete description of the applicant's response to RAI 2.5.2-5

and the staff's evaluation of the applicant's response.

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SSAR Section 2.5.2.6.5 states that the applicant examined the effects of the new

characterization of the ECFS-N and ECFS-S fault segments by calculating the seismic hazard

from these two fault segments and comparing this seismic hazard to that predicted from the

1989 EPRI seismic sources. The applicant calculated the seismic hazard from these two fault

segments using the 2003 EPRI ground motion models rather than the earlier 1989 ground

motion models. As shown in SSAR Figures 2.5-40 and 2.5-41, the ECFS-S fault increases the

total median and mean hazard for 1-Hz spectral acceleration by several percent at the 1 O'5

hazard level. The ECFS-N fault segment, for which the applicant assigned a 10 percent

probability of existence and activity, does not'contribute to the overall hazard. For higher

frequency ground motion (i.e., 10-Hz spectral acceleration), neither the ECFS-S nor the

ECFS-N fault segments contribute significantly to the overall seismic hazard. SSAR

Section 2.5.2.6.5 states that this results from the domination of the higher frequency ground

motion by seismic sources closer than the distant ECFS. The ECFS-N fault segment is

70 miles southeast of the ESP site, and the ECFS-S is 300 miles south of the ESP site.

New Ground Motion Models

To estimate the ground motion at the ESP site from each of the seismic sources, the applicant

used the new 2003 EPRI-sponsored study that compiles and evaluates 13 new ground motion

attenuation models for the CEUS (Ref. 116, SSAR Section 2.5). The previous EPRI PSHA

used only three ground motion attenuation models.

For lower frequency ground motion (i.e., 1-Hz spectral acceleration), the new ground motion

models result in median hazard results that are about the same as the hazard results derived

using the 1989 ground motion models. In contrast, the 2003 mean hazard is significantly lower

than the 1989 mean hazard. In addition, for higher frequency ground motion (i.e., 10-Hz

spectral acceleration), SSAR Section 2.5.2.6.5 states that both the median and mean hazards

increase significantly at annual frequencies of 10'5. Figure 2.5-44 in the SSAR compares a

10-Hz seismic hazard for both the 1989 ground motion models and the 2003 ground motion

models. SSAR Section 2.5.2.6.5 provides the following rationale for the higher hazard for

higher frequency ground motion determined by the newer model:

A major difference between the 1989 and 2003 ground motion models is that the

estimates of aleatory [random] uncertainty are larger in the 2003 study. In 1989,

a standard deviation of natural log (ground motion) of 0.5 was used for all

frequencies, whereas in 2003, values of 0.6 and 0.7 are common (they vary

depending on magnitude, distance, and frequency). At annual frequencies of

10'5, which are sensitive to the tails of the ground motion aleatory distribution,

this difference in standard deviation increases seismic hazard. This would likely

be true for any CEUS location. A compensating factor at low frequencies (1 and

2.5 Hz) [1 Hz] is the use of ground motion models that reflect a two-corner

source, which'acts to reduce low frequency [1 Hz] ground motion estimates from

those used in 1989. Thus the median 1 Hz seismic hazard is about the same for

both models. The mean amplitudes using the 2003 ground-motion models are

closer to the median amplitudes than is the case for the 1989 models, reflecting

convergence on what are reasonable models to use for ground motion

estimation in the eastern US. In 1989, the ground motion models were quite

diverse, with one model developed by estimating peak ground acceleration and

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velocity, then using spectral amplification factors to estimate spectral amplitudes.

In 2003, the available models estimate spectral amplitudes directly.

PSHA and Controllina Earthauakes

Using the 2003 EPRI ground motion models and adding the ECFS-S fault segment, the

applicant calculated the PSHA results for the'ESP site. 'Table 2.5-22 of the SSAR, reproduced

below, compares the 1989 EPRI PSHA and the 2003 PSHA results.

Table 2.5.2-1 Updated Seisnmic Hazard Results at ESP Site

Frequency Median/Mean Updated PSHA 1989 PSHA Difference

1 Hz iO' median 0.096 g 0.091 g 6%

10' mean 0.134 g 0.219 g -39%

2.5 Hz 10'5 median 0.316 g 0.232 g 36%

. 5 mean 0.364 g 0.519 g -30%

5 Hz 10'5 median 0.639 g 0.439 g 46%

10'5 mean 0.735 g - 0.753 g -2%

10 Hz 10'5 median 1.020 g' 0.660 g 55%

10`5 mean 1.216 0.827 g 47%

As shown in Table 2.5.2-1 above, the largest difference is at 10 Hz, where the updated PSHA

indicates higher ground motion amplitudes for the' 105 median and mean by 55 percent and'

47 percent, respectively. At 1 Hz, 2.5 Hz, and 5 Hz, the updated PSHA shows a higher median

10'5 hazard, but a lower mean 10`5 hazard.

Selected SSE Ground Motion

The method for determining the SSE for a site, as described in RG 1.165, is based on the use

of a reference probability. The basis for the procedure in RG 1.165, as well as the

determination of the reference probability, is that existing nuclear power plants do not represent

an undue risk to the health and safety of the public. As such, using the existing plants as a

reference, RG 1.165 recommends a procedure to determine the seismic design basis for future

plants. The reference probability is the average probability of exceeding the SSE ground

motion at 5 Hz and 10 Hz, using either the 1993 LLNL PSHA or the 1989 EPRI PSHA. The

NRC staff calculated a reference probability level for 29 nuclear power plant sites in the CEUS;

the median reference probability for these 29 sites, using median hazard results, is 10'o5 per

year. A similar value was obtained using both the 1993 LLNL and the 1989 EPRI PSHA level;

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LZA

therefore, RG 1.165 endorses both the LLNL and the EPRI PSHA results as suitable for

seismic hazard estimation for future siting.

To determine the site SSE, the applicant used the method described in RG 1.165, but with a

higher reference probability. In RAI 2.5.2-1 (d), the staff asked the applicant to justify this higher

reference probability. The applicant cited Section B.3 in Appendix B to RG 1.165 and the

following three factors to justify changing the reference probability:

(1) The revised EPRI ground motion models (Ref. 116, SSAR Section 2.5) indicate

generally higher ground motions and aleatory uncertainties at higher frequency

amplitudes of interest than previous models.

(2) The mean recurrence time for large earthquakes in the New Madrid, Missouri, region

and in the Charleston, South Carolina, region has decreased since the EPRI and LLNL

studies in the 1980s.

(3) Use of the mean hazard instead of the median hazard results in a higher reference

probability because mean hazard curves lie above median hazard curves.

The applicant stated that the combined effect of these three factors would increase the

reference probability by a factor of at least 5. Therefore, the applicant selected a mean hazard

value of 5x105 as its reference probability. The applicant then deaggregated the PSHA results

using the new reference probability to determine the controlling earthquakes for the ESP site.

The controlling earthquakes for the ESP site have a magnitude of 5.4 at 12 miles (19.31 km)

and a magnitude of 7.2 at 191 miles (307.4 km).-The first magnitude-distance pair is the highfrequency (i.e., 5 and 10 Hz) controlling earthquake and is consistent with an earthquake from

the CVSZ. The second magnitude-distance pair is the low-frequency (i.e., 1 and 2.5 Hz)

controlling earthquake and is consistent with an earthquake from the ECFS-S fault.

Figures 2.5.2-1 and 2.5.2-2, reproduced from SSAR Figures 2.5-49 and 2.5-50, respectively,

depict the results of the deaggregation of the PSHA results.

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0

O 0.15

I -:

U.

0.10

>7

5.5-6

Distance. (kin)

Figure 2.5.2-1 Magnitude-distance deaggregation for low frequencies (l'and 2.5 Hz) at a

mean annual frequency of 5x1 05. using updated source and ground motion models

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1Us

Figure 2.5.2-2 Magnitude-distance deaggregation for high frequencies (5 and 10 Hz) at a

mean annual frequency of 5x105 using updated source and ground motion models

To determine these two controlling earthquakes, the applicant followed the procedure in

Appendix C to RG 1.165, using the higher reference probability and the mean PSHA hazard

results rather than the median results. Using the two controlling earthquakes, the applicant

then determined two ground motion response spectra using the EPRI 2003 ground motion

relationships and scaling the two spectra to the appropriate ground motion amplitudes.

Figure 2.5.2-3, reproduced from SSAR Figure 2.5-48, shows the hard rock (9200 fWs) ground

motion response spectra for the two controlling earthquakes.

In addition to using the methodology described in RG 1.165 to determine the SSE ground

motion, the applicant chose to use an alternative approach, described as a performance-based

approach. In RAI 2.5.2-1, the staff asked the applicant to explain how the performance-based

approach meets the requirements of 10 CFR 100.23, which provides the geologic and seismic

siting criteria, as well as a definition of the SSE. In its response, the applicant explained how

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the performance-based approach conforms to the requirements of 10 CFR 100.23. In

RAI 2.5.2-9, the staff asked the applicant for further details on the performance-based

approach to supplement the information provided in SSAR Section 2.5.2.6. In its response, the

applicant provided further justification for th6 performance-based approach, including the

derivation of some key relationships. Section 2.5.2.3.6 of this SER discusses this further.

Selection of Enveloping Horizontal SSE Spectrum

Initially, to determine the final SSE for the ESP site, the applicant enveloped the two controlling

earthquake ground motion response spectra and the performance-based spectrum.

Figure 2.5.2-3, reproduced from SSAR Figure 2.5-54A, shows these spectra. However, as a

result of Open Item 2.5-2, described above in the previous SER subsection, the applicant.

incorporated the local site geologic properties into its determination of the final SSE. The

applicant's new analysis used a rock subsurface profile that extends from the top of Zone lIl-IV

bedrock (21 ft depth) to depths at which the shearwave velocity in the bedrock under the site

reaches about 9200 ft/s (160 ft depth). The applicant used this best-estimate profile to estimate

the amplification of the SSE ground motion at a control point located at the top of competent

Zone lII-IV rock. The applicant selected this control point at the top of Zone III-IV rock to be

consistent with Section 3.7.1 of NUREG-0800, which states that the control point for sites with a

thin soil layer is specified on "an outcrop or a hypothetical outcrop at a location on the top of the

competent material."

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I Ito

10 -. -- 5 Selected SSE spectrum (envelope) -

Performance-based spectrum

- - - Mean 5x10-5 low-freq RG spectrum

- -Mean ,x10-5 high-freq RG spectrum

,1 I

-~4-1

__t I 5 lI I f4 ,'I 1'tt' j t[l1

.0.I

._ :.._: ;ii.,..$_ .__.i.J

0.0

- 0. * ! 72 r :J,.: ---,t ;---*---

0. 0 0

i..... . .. ' ' iti

t, , ! t, 7.! f i li | *i j

0.1 1 10 100

Frequency (Hz)

Figure 2.5.2-3 Comparison of performance-based spectrum, mean 5x10-5 scaled spectra,

and selected SSE spectrum (which overlaps the performance-based spectrum and

envelops the other two)

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To determine the control point SSE at the top of Zone III-IV rock, the applicant (1) developed a

shear wave velocity profile for the ESP site, (2) generated alternative randomized rock columns

to incorporate the variability in the rock properties, (3) selected seed earthquake time histories,

and (4) performed the final ground response analysis.

The applicant's shear wave velocity profile is based on its subsurface exploration for the ESP

site and Virginia Power's subsurface explorations for the existing units. For these explorations,

the applicant made shear wave velocity measurements mainly at 5-ft depth intervals, but

sometimes at 10-ft depth intervals. The applicant also defined the material properties of

density, Poisson's ratio, and the behavior of shear wave velocity and material damping as a

function of strain. SSAR Section 2.5.4.7 describes the subsurface shear wave velocity and

related material property information for the ESP site.

The applicant developed 50 alternative randomized rock columns by varying the material

properties described above. The applicant generated 50 randomizations of the generic ESP

site rock column velocity profile between elevations with shear wave velocities of 9200 ft/s and

3300 ft/s. The applicant kept the same damping value for all sublayers within any given profile

but varied the damping value between one artificial rock column and the next.

Next, the applicant selected two seed time histories to match the low- and high-frequency

controlling earthquake response spectra shapes (see Figure 2.5.2-3). The applicant selected

these two time histories using the controlling earthquake magnitude and distance values from

the database of CEUS time histories given in NUREG/CR-6728 (Ref. 9, SSAR Section 2.5)..

To perform the final ground response analysis, the applicant used the two low-frequency and

high-frequency input hard rock motions for each of the 50 artificial rock profiles. The applicant

modeled the site using horizontal layers, each 7.5 ft thick, overlying a uniform half-space of

hard bedrock (V. at 9200 ft/s). Figure 2.5.2-4, reproduced from Figure 8 in the March 30, 2005,

response to Open Item 2.5-2, shows the 50 response spectra for the high- and low-frequency

time histories at the control point at the top of Zone III-IV rock (model layer 1).

. 1 . . 2-183
I ! any

3

2.5-

2i -

0-

0.1 . 10 100

Frequency (Hz)

Figure 2.5.2-4 Response Zone III-IV control point (Elevation 250 ft., Layer 1) - 5% Critical

Damping ARS - High Frequency (upper dark gray group) and Low Frequency (lower light

gray group) time histories. Log-average of each set of 50 response spectra for the high

and low frequency time histories indicated by the heavy blue and red lines, respectively.

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Next, the applicant fit a smooth function through the enveloped log-average spectrum, which is

shown in Figure 2.5.2-4. This smooth function is the final ESP site horizontal SSE ground

motion spectrum, which the applicant has defined at the control poinit at the top of Zone III-IV

rock. The spectral acceleratii6rit 25 Hz for the ESP site horizontal SSE is 1.476g and the

PGA at 100 Hz is 0.555g.

In order to develop the transfer function between the hard rock (V. 9200 ft/s) at a depth of

161 ft and the control point at the top of Zone III-IV (V, 3300 ftls), the applicant computed the

ratio of the hard rock response spectrum and the SSE spectrum at 21 frequency points. -The

transfer function 'provides the-ground response of the ESP site to the hard rock input SSE

motion. Figure 2.5.2-5 shows the transfer function for the ESP site. For some of the lower

frequencies (0.1 to 2 Hz), the ESP site slightly de-amplifies the hard rock input ground motion,

but for intermediate and high frequencies (2 to 100 Hz), the ESP site amplifies the input ground

motion by as much as 1.664 at 20 Hz.

3

2

C.t

1

0

frequency (Hz)

Figure 2.5.2-5 Transfer Function for ESP Site

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_XE

Development of Vertical SSE Spectrum

To determine the vertical SSE spectrum, the applicant used the vertical-to-horizontal (V/H)

response spectral ratios provided in NUREG/CR-6728. The vertical SSE spectrum is given by

multiplying the horizontal SSE spectrum by the WH ratios. The V/H ratios given in NUREG/CR6728 are for generic CEUS hard rock conditions and depend on the PGA value of the horizontal

SSE spectrum. For the ESP site, the V/H ratios used by the applicant are based on having a

PGA between 0.2g and 0.5g. However, after incorporating the local ESP site properties to

determine the final horizontal SSE spectrum (see Open Item 2.5-2), the applicant's horizontal

SSE PGA value increased from 0.37g to 0.55g. Rather than using the V/H ratios given in

NUREG/CR-6728 for a PGA greater than 0.5g, the applicant performed a site-specific analysis

to confirm the appropriateness of the V/H ratios for a PGA between 0.2g and 0.5g.

Figure 2.5.2-6, reproduced from SSAR Figure 2.5-48A, shows the final horizontal and vertical

SSE ground response spectrum at the control point at the top of Zone III-IV rock.

For its analysis to confirm the NUREG/CR-6728 V/H ratios for a PGA between 0.2g and 0.5g,

the applicant used site-specific shear and compressional wave profile data together with four

different earthquake magnitude-distance pairs from the high-frequency (5 and 10 Hz)

deaggregation. The applicant computed horizontal and vertical ground motion spectra for each

of the magnitude-distance values. In addition, the applicant used site-specific data from its

ESP explorations as well as older data from Dominion's site explorations for Units 1 and 2 to

develop two velocity profile models. The applicant assigned weights of 0.75 and 0.25 to these

two models, with the higher weight for the more recent ESP site investigation model. The

applicant stated that the V/H ratios that it obtained from the site-specific analysis are about 30%

lower than the V/H ratios provided in NUREG/CR-6728 for a PGA between 0.2g and 0.5g. As

such, the applicant concluded that these V/H ratios (see SSAR Table 2.5-27A) are appropriate

for the North Anna ESP site. Higher V/H ratios result in a higher vertical SSE spectrum. The

V/H ratios used by the applicant range from 0.75 at low frequencies to 1.12 at 50 Hz.

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1 0 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

1* -Horizontal Zone III-IV spectrum

- - -Vertical Zone III-IV spectrum .1 __ _ , __ ..... __-- . -.. .. ... -

0

0.1- CL

0.1- .' -

. of/ . S5% Critical Damping|

0.01

0.1 1 10 100

Frequency (Hz)

Figure 2.5.2-6 (SSAR Figure 2.5-48A) Selected Horizontal and Vertical Response Spectra

for the Hypothetical Rock Outcrop Control Point SSE at the Top of Zone III-IV Material

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Sensitivity Studies

The applicant performed two sensitivity studies to demonstrate the appropriateness of the final

SSE shown in Figure 2.5.2-6.

The first sensitivity study uses a higher minimum magnitude value for each of the seismic

source zones. Currently, the EPRI and LLNL studies use an mb of 5.0 as the minimum

magnitude for calculations, which corresponds to an Mw of 4.6. SSAR Section 2.5.2.6.8 states

that there is "abundant evidence that earthquakes with M, less than 5 do not cause damage to

nuclear plant structures and equipment." An Mw of 5 corresponds to an mb of 5.4. As such, the

applicant reran the PSHA with the lower bound magnitude, mb, set to 5.4. SSAR Table 2.5-28

shows the lower mean 5x10 5 spectral accelerations resulting from a higher minimum

magnitude value. The lower frequency ground motion is similar to the recommended ground

motion spectrum. However, the higher frequency ground motion (i.e., 10 Hz and above) is as

much as 20 percent lower than the motion at the same frequency for the performance-based

spectrum derived from using a higher minimum magnitude value. The applicant stated that this

result demonstrates that the recommended ground motion spectrum incorporates substantial

conservatism.

For the second sensitivity study, the applicant revised the uncertainty for the base-case ground

motion model to match the uncertainty values of California ground motion models. The

uncertainty for CEUS ground motion models, especially for higher frequencies (i.e., 5 Hz and

above), exceeds the uncertainty reported for ground motion models based on California strongmotion data. This uncertainty, referred to as aleatory uncertainty, represents the scatter of the

observed ground motion about the predicted ground motion. SSAR Section 2.5.2.6.8 states

that "it is not obvious that aleatory uncertainties should be higher for ground motions in the

eastern U.S. than in California." Using lower aleatory uncertainty, the applicant reran the PSHA

and compared the recommended ground motion spectrum to that obtained by using the lower

uncertainty. SSAR Table 2.5-28 shows the resulting ground motion spectrum using the lower

aleatory uncertainty values. A comparison between this ground motion spectrum and the

recommended ground motion spectrum shows that a fairly significant decrease (about

10 percent) in the selected spectrum would occur if the lower aleatory ground motion

uncertainties were used in place of those reported in the 2003 EPRI ground motion study.

Future Modification of the Selected Spectrum

SSAR Section 2.5.2.6.9 describes potential modifications to the selected SSE ground motion

spectrum to account for embedment and structure effects. According to the applicant, the COL

application would include these modifications. The modifications to the SSE spectrum would

account for horizontal and vertical spatial variation and incoherence of the ground motion, as

well as scattering effects and soil-structure interaction. Horizontal spatial variation in ground

motion is more prominent for structures with large plan dimensions and would reduce the input

into the structure at high frequencies. SSAR Section 2.5.2.6.9 states that this occurs because

the presence of large structures modifies the ground motion input to the base mat and that the

modifications become significant at higher frequencies, especially above 10 Hz. The applicant

concluded that the SSE spectrum is "an unrealistic input for analysis and design of structures,"

and, "in order to obtain a realistic design spectrum, the Engineering Design Spectrum (EDS),

factors must be considered that affect the shape of the spectrum experienced by structures with

2-188
large base mats, such as those typical of nuclear power plants." The applicant referred to this

"realistic design spectrum" as an engineering design spectrum (EDS).

2.5.2.1.7 Operating-Basis Earthquake

SSAR Section 2.5.2.7 describes the establishment of the operating-basis earthquake (OBE)

ground motion for the ESP site. Rather than performing a detailed analysis, the applicant

decided to establish the OBE earthquake spectrum as one-third of the SSE spectrum, in

accordance with Appendix S to 10 CFR Part 50.

2.5.2.2 Regulatory Evaluation

SSAR Section 2.5.2 presents the applicant's determination of ground motion at the ESP site

from possible earthquakes that might occur in the site region and beyond. In SSAR

Section 1.8, the applicant stated that SSAR Section 2.5.2 conforms to the requirements of

10 CFR 50.34, "Contents of Applications; Technical Information," Appendix S to 10 CFR

Part 50, and 10 CFR 100.23. The applicant further stated in Section 1.8 that it developed this

information in accordance with the guidance presented in NUREG-0800, Revision 3,-

Section 2.5.2; RGs 1.70 and 1.165; and DG-1 105, "Site Investigations for Foundations of

Nuclear Power Plants." (RG 1.198, of the same title, issued November 2003, superseded

DG-1 105 since the applicant submitted the SSAR.).

In its review of the application, the staff considered the regulatory requirements of 10 CFR

52.17(a)(1)(vi) and 10 CFR 100.23(c) and (d), which require that the applicant for an ESP

describe the seismic and geologic characteristics of the proposed 'site. In particular, 10 CFR

100.23(c) requires that an ESP applicant investigate the geologic, seismologic, and engineering

characteristics of the proposed site and its environs with sufficient scope and detail to support

estimates of the SSE ground motion and to permit adequate engineering solutions to actual or

potential geologic and seismic effects at the proposed site. In addition, 10 CFR 100.23(d)

states that the SSE ground motion for the site is characterized by both horizontal and vertical

free-field ground motion response spectra at the free ground surface. Section 2.5.2 of

NUREG-0800 provides guidance concerning the evaluation of the proposed SSE ground

motion, and RG 1.165 provides guidance regarding the use of PSHA to address the

uncertainties inherent in the estimation of ground motion at the ESP site. The staff notes that

the application of Appendix S to 10 CFR Part 50 in an ESP review, as referenced in 10 CFR

100.23(d)(1), is limited to defining the minimum SSE for design.

2.5.2.3 Technical Evaluation

This section of the SER provides the staff's evaluation of the seismological, geological, and

geotechnical investigations the applicant conducted to determine the SSE ground motion for the

ESP site. The technical information presented in SSAR Section 2.5.2 resulted from the

applicant's surface and subsurface geological, seismological, and geotechnical investigations

performed in progressively greater detail as they moved closer to the ESP site. The SSE is

based upon a detailed evaluation of earthquake potential, taking into account regional and local

geology, Quaternary tectonics, seismicity, and specific geotechnical characteristics of the site's

subsurface materials.

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Ila

SSAR Section 2.5.2 characterizes the ground motions at the ESP site from possible

earthquakes that might occur in the site region and beyond to determine the site SSE spectrum.

The SSE represents the design earthquake ground motion at the site and the vibratory ground

motion for which certain nuclear power plant SSCs must be designed to remain functional.

According to RG 1.165, applicants may develop the vibratory design ground motion for a new

nuclear power plant using either the EPRI or LLNL probabilistic seismic hazard analyses for the

CEUS. However, RG 1.165 recommends that applicants perform geological, seismological,

and geophysical investigations and evaluate any relevant research to determine whether

revisions to the EPRI or LLNL PSHA databases are necessary. As a result, the staff focused

its review on geologic and seismic data published since the late 1980s that could indicate a

need for changes to the EPRI or LLNL PSHAs.

2.5.2.3.1 Seismicity

The staff focused its review of SSAR Section 2.5.2.1 on the adequacy of the applicant's

description of the historical record of earthquakes in the region. The historical earthquake

catalog used in the original EPRI analysis was complete through 1984. Therefore, in addition to

reevaluating the EPRI seismicity catalog, the applicant added seismicity data for the time period

from 1985 through 2001.

The staff reviewed both the original EPRI seismicity catalog and the update to the catalog. The

applicant added 30 more earthquakes to the regional catalog for the ESP site. Figure 2.5.2-7

depicts the earthquake epicenters in the region surrounding the ESP site. The more recent

events since 1984 are shown as solid dots. The cluster of seismicity to the south-southwest of

the ESP site is from the CVSZ.

Because the applicant used the EPRI seismicity catalog, which is part of the 1989 EPRI seismic

hazard study that the NRC endorsed, the staff concludes that the seismicity catalog used by the

applicant is complete and accurate through 1984. The staff compared the applicant's update of

the regional seismicity catalog with its own listing of recent earthquakes and did not identify any

significant omissions. Accordingly, the staff concludes that the applicant accurately updated

the regional seismicity.

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I , I I t
.

r 

-

'+

Perrstvsrd A72

r

t~fi0

cith .rd-

~613

N 1~ .3,: -, ,

h , 1

/

f .

/o

Legend

MAGNITUDE

* 0- 1

* 3

. 4

. 5

Figure 2.5.2-7 Regional seismicity for ESP site .2- . .

2-191:
LK

2.5.2.3.2 Geologic and Tectonic Characteristics of the Site and Region

The staff focused its review of SSAR Section 2.5.2.2 on the applicant's characterization of

potential seismic sources in the region surrounding the ESP site. The applicant evaluated

recently published studies to determine if the seismic source models used for the 1989 EPRI

study needed updating. The applicant concluded that no new information would suggest

potentially significant modifications to the EPRI seismic source model, with the following three

exceptions:

(1) the newly postulated ECFS

(2) the smaller recurrence interval for the Charleston seismic source zone

(3) the smaller recurrence interval for the NMSZ

In RAI 2.5.2-4(a), the staff asked the applicant to provide additional seismicity parameters

beyond those shown in SSAR Tables 2.5-5 through 2.5-11 for the seismic sources surrounding

the ESP site. In response to RAI 2.5.2-4(a), the applicant provided the recurrence parameters

("a" and "b" values) used in the EPRI study for the latitude and longitude degree cell

encompassing the ESP site region. Because RG 1.165 endorsed the EPRI PSHA methodology

and results, the staff used the information the applicant provided in response to RAI 2.5.2-4(a)

to determine if any of the seismicity parameters should be updated. In particular, the staff

asked the applicant in RAI 2.5.2-4(b) to justify its decision to not update Mm, values assigned to

the CVSZ by the 1989 EPRI ESTs considering the 1994 EPRI study, "Seismotectonic

Interpretation and Conclusion from the Stable Continental Region Database." In its response to

RAI 2.5.2-4(b), the applicant stated that EPRI initiated the 1994 EPRI study in the mid-1 980s

specifically for use by the EPRI teams in their development of the EPRI seismic source model.

Each of the EPRI teams had access to the preliminary source zone geometry drawn from the

1994 EPRI study in their 1989 seismic source models. Because the Mmax values used by the

EPRI teams generally encompass the Mma,, values recommended by the 1994 EPRI study, the

staff concludes that the applicant adequately characterized the seismic source zones,

particularly the CVSZ, surrounding the ESP site. Section 2.5.2.1.6 of this SER summarizes the

applicant's revisions to SSAR Section 2.5.2 resulting from RAI 2.5.2-4.

In RAI 2.5.2-7, the staff noted that some of the EPRI ESTs did not include the CVSZ as a

specific source and asked the applicant to describe how the modern and historical seismicity of

the CVSZ is distributed among either a specific source zone or a background source zone. In

its response, the applicant described the source model used by each of the six EPRI teams to

characterize the CVSZ. The staff reviewed each of the source models for the CVSZ that the

applicant provided in its response to ensure that it had adequately characterized the seismic

activity of the CVSZ. Each of the EPRI ESTs included the seismicity within the CVSZ as either

a specific seismic source zone or as part of a background seismic source zone, and the staff

concludes that these source models are acceptable in this respect.

Based on its review of SSAR Section 2.5.2.2 and the applicant's responses to the RAls, as set

forth above, the staff concludes that the applicant adequately investigated and characterized

the regional seismic sources. The staff concludes that the 1989 EPRI seismic source models,

with the exceptions noted above, remain valid for the ESP site. In addition, the staff concludes

that the applicant identified those source zones that may warrant updating based on the results

of its sensitivity studies which are presented in SSAR Section 2.5.2.6.

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2.5.2.3.3 Correlation of Earth'quake Activity with Seismic Sources

The staff focused its review of SSAR Section 2.5.2 on the applicant's efforts to correlate

seismicity with known geologic features. Based on a comparison of the updated earthquake

catalog to the EPRI catalog, the applicant concluded that none of the earthquakes within the

site region can be associated with a known geologic structure. In addition, the applicant

concluded that the updated catalog does not show a unique cluster of seismicity that would

suggest a new seismic source outside of the EPRI seismic source model. Since the seismicity

in the region surrounding the ESP site '(see SSAR Figure 2.5-2) is notfnarrowly focused along

any known faults or fault zones, the applicant used areal seismic source zones to characterize

the seismic hazard for the ESP site. EPRI team's developed these areal source zones in the

mid-1 980s.

The staff compared the applicant's seismicity maps with its own and concludes that the'

applicant has adequately investigated the correlation of earthquake activity with known geologic

sources. In particular, the staff plotted the epicenters of the most recent earthquakes

surrounding the site (see SER Figure 2.5.2-4) and concurs with the applicant's conclusion that

there are no new seismic sources that were not included in the 1989 EPRI seismic source

model.

2.5.2.3.4 Probabilistic Seismic Hazard Analysisard Controlling Earthquakes

To evaluate the applicant's PSHA and controlling earthquakes, the staff reviewed the

information presented in SSAR Sections 2.5.2.4 and 2.5.2.6. In SSAR Section 2.5.2.4,-the

applicant reproduced the 1989 EPRI PSHA using the 1989 seismic sources, 1989 ground

motion models, and current PSHA computer program. The applicant concluded that its current'

PSHA computer program accurately models the 1989 EPRI results for the ESP site location.

For its PSHA, the applicant considered (1) af new regional earthquake catalog, (2) new MmaX

information, (3) new seismic source characterizations, and (4) new gr6uhd motion models.

Based on PSHA sensitivity studies, which i ncorporate each of these four items, the applicant

concluded that the more recent characterization of the Charleston seismic source recurrence

interval and the new ground motion models result in significant changes to the PSHA for the

ESP site.

For Revision 3 (September 2004) of Section 2.5.2 of the SSAR, the applicant repeated its

deaggregation of the PSHA results to determine the'controlling earthquake magnitudes and

distances.. Although the applicant used the same reference probability (mean 5x1 0-5), the most

recent deaggregatiorn uses the mean PSHA hazard results rather than the median-hazard

results to calculate the controlling earthquakes. Because the mean hazard curves are higher

than the median curves, the applicant's use bf the mean curves'is conservative.

In its response to RAI 2.5.2-5, the applicant explained how'it incorporated the alternative

characterization of the Charleston seismric source into the final PSHA. It stated that the

alternative characterization of the Charleston source was evaluated both independently and

additively to conservatively assess the maximum possible change'to the hazard at the North

Anna ESP site from the revision to this'postulated source.' The revisions to the Charleston

source include a shorter recurrence interval (550 years) and different weights for the Mmax (M,

6.8 to 7.5). The ECFS-S seismic source was added to the source models for each of the six

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EPRI teams for the final PSHA. Because the applicant reduced the recurrence interval,

increased the weighting of higher Mmax values, and also included the alternate source geometry

of the ECFS-S into the final PSHA, the staff concludes that the applicant conservatively

updated the characterization of the Charleston seismic source. This latter modification is

conservative because it amounts to counting the Charleston seismic source twice. The result of

these changes to the PSHA is that the low-frequency controlling earthquake for the ESP site

has a magnitude of 7.2 at a distance of 308 km.

In RAI 2.5.2-2, the staff asked the applicant to provide additional details on the 2003 EPRI

ground motion evaluation that it used for the ESP PSHA. To update the ground motion

attenuation models in the CEUS, EPRI sponsored a Senior Seismic Hazard Advisory

Committee (SSHAC) Level 3 analysis. NUREG/CR-6372 provides the guidelines for performing

such an analysis. The EPRI ground motion study used 13 different ground motion attenuation

relationships grouped into four clusters. In RAI 2.5.2-2(c), the staff asked the applicant to

provide the weight assigned to each of the 13 ground-motion relationships within their

respective cluster. For cluster 1, EPRI gave the highest weight (0.90) to the three attenuation

relationships reported by Silva et al. The staff inferred from this higher weight that these

relationships must have fit the data much better than other relationships. However, the

applicant did not provide plots or tables of the residuals as a function of attenuation relation,

magnitude, distance, and frequency. Therefore, the staff was unable to evaluate the weighting

EPRI selected for cluster 1. Similarly, for clusters 2 and 3, the ground motion experts applied

higher weights to different attenuation relationships within each cluster. Neither the EPRI 2003

ground motion report nor the applicant's response to RAI 2.5.2-2 provides the rationale for

these weights.

In RAI 2.5.2-2(b), the staff asked the applicant to provide additional information on the Silva et

al. cluster 1 attenuation relationships. In response, the applicant provided additional

documentation on these attenuation relationships. The Silva et al. cluster 1 relationships use

an expression for the seismic attenuation parameter, Q, that is frequency dependent. This

frequency-dependent Q value was derived from an inversion of the data from the 1988

Saguenay earthquake. This inversion solves for Q, as well as the local site attenuation

parameter kappa and the stress drop, which is the difference between the initial stress before

and earthquake and the final stress. The staff was unable to determine how the recordings

from a single earthquake can provide well-resolved values of both crustal Q and site kappa. In

addition, the 0 value of 317 at 1 Hz is much lower than values found in other studies of eastern

North American earthquakes. In addition, other studies have found less frequency dependence

of Q in the east than in the west, which is contrary to the findings of Silva et al.

In RAI 2.5.2-2(d), the staff asked the applicant to explain the weights given to each of the four

clusters. In response to RAI 2.5.2-2, the applicant stated that the expert panel members,

convened for the EPRI ground motion study, were asked to subjectively evaluate how well the

alternative ground motion models relied on seismological principles. The staff considers the

applicant's response to RAI 2.5.2-2(d) to be somewhat indirect. The applicant provided

additional information, but the details still remain abstract in terms of specific "seismological

principles." The response emphasizes the ranking of model clusters and the judgments

involved in balancing data consistency and adherence to seismological principles. However,

the applicant provided only abstract and very general references to these seismological

principles. As a result, the staff was unable to evaluate the criteria or the weights applied to the

four clusters.

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In Open Item 2.5-1, the staff requested clarification and further information from the applicant

regarding each of the three issues outlined above. With regard to the unequal weighting for the

cluster 1 attenuation relationships (RAI 2.5.2-2(a)), the applicant provided the staff with tables

of statistics that compare each of the ground motion relationships and the CEUS earthquake

database. For each model and ground motion frequency, the applicant determined the

deviation between the median-model prediction and the actual recorded motion. Using the

mean and variance of the deviations, the applicant determined the weight for each model in

cluster 1. In addition to the tables of statistics, the applicant also provided plots of residuals for

each of the cluster 1 ground motion models and plots comparing the final overall cluster 1

model to the actual CEUS earthquake data.

With regard to the staff's concerns, described above in RAI 2.5.2-2(b), concerning the Silva et

al. cluster 1 attenuation relationships, the applicant stated the following:

The model functional form, basis for parameter selection, and the results

developed in Silva et al. (2002) and its predecessor.- Silva et al. (1997), are the

responsibility of the lead author. Of particular relevance is the interdependence

between model parameters, how the parameters were determined, model

sensitivity to its parameters, and reasonable ranges in parameter values, based

on expert judgement and expert interpretation of the scientific literature. It is

unclear if a summary justification for the -results of the Silva et al. (1997 and

2002) studies would resolve the items identified that seem, ultimately, to

represent differences in expert judgement.

Differences in expert judgement are often difficult to reconcile. For this very

reason, the SSHAC [Senior Seismic Hazard Advisory Committee] process was

developed and accepted for use by the NRC. The EPRI 2003 ground motion

model was developed by implementing a SSHAC Level 3 assessment process

during which the EPRI Expert Panel identified the Silva et al. relationships as

ones that should be included in the assessment and evaluated. The EPRI

Expert Panel considered specific parameterizations of individual ground motion

relationships in determining whether or not 'a relationship should be included in

the'SSHAC Level 3 assessment process." All ground motion relationships,

identified as viable by the Expert Panel were evaluated using the same criteria

following the SSHAC Level 3 process. '

-The SSHAC process does not guarantee that every scientist will agree with the

assessments. It is rather intended to assure that the assessed results reflect the

preponderance of current scientific views, which is the underpinning of safety

decisionmaking.

Since the EPRI 2003 expert panel members gave the three Silva et al. attenuation relationships

the highest overall weight (0.90) in cluster 1, the staff asked the applicant to explain whether.

this biased the final overall cluster 1 ground motion model towards the model functional form

and parameters used by these three attenuation relationships. . Specifically, the three Silva

et al. attenuation relationships each have different earthquake source terms and parameters;

however, these relationships have the same wave propagation travel path terms and

parameters. As such, the staff asked the applicant to explain if this limited path variability

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biased the overall cluster 1 ground motion model. In response to the staff's concern, the

applicant stated the following:

The ground motion models in Cluster 1 considered a range of alternative stress

drop models and alternative Q and path models. Collectively, these models

represent alternative single-corner [shape] source spectrum models for the

CEUS. In aggregate, these models provide a measure of the epistemic

[modeling] uncertainty in the median ground motion based on the single-corner

source spectrum models (e.g., intra-cluster variability).

The applicant also stated that, as part of the CEUS model development, EPRI evaluated

whether an additional component of uncertainty for wave propagation travel path effects should

be included for each of the model clusters. The individual models within each model cluster

contribute to the overall cluster variability since they each use different source and path

parameters. However, the EPRI (2004) report states that there may be additional variability in

the modeling parameters that is not captured by the ground motion models that make up a

cluster. As described above, the staff expressed concern that the path variability for cluster 1

may be too small since the three Silva et al. attenuation relationships, which have an overall

weight of 0.90, each have the same travel path model terms and parameters. EPRI, as part of

its ground motion assessment, compared the overall cluster 1 ground motion variability (both

source and path) with the variability of different path model terms and parameters used by the

different individual models. In other words, EPRI isolated the travel path variability by equally

weighting each of the alternative travel path models and compared this variability to the overall

variability for each of the ground motion clusters. Figure 4-6 of the EPRI (2004) ground motion

report shows this travel path variability, and Figure 4-2 of the report depicts the cluster 1

variability. Comparing the variability shown in Figures 4-2 and 4-6, the applicant concluded that

"these variabilities were similar, although the results in Figure 4-6 are higher, particularly at

distances beyond 100 km." The applicant stated that most of the models in cluster 1 had

already "considered the variability in path effects as aleatory [e.g., random scatter] variability

and thus it is ultimately included in the overall probabilistic hazard analysis."

With regard to the staff's concerns, described above in RAI 2.5.2-2(d), the latest version of the

EPRI ground motion report provides an expanded explanation of the seismological principles

that the expert panel members used to determine the overall weight for each of the four

clusters. The seismological principles considered by the expert panel members include

(1) seismic source modeling, (2) crustal wave propagation, and (3) near-surface crustal effects.

Based on the single criterion of seismological principles, the four ground motion clusters were

weighted fairly equally (0.245, 0.221, 0.257, and 0.277). In addition to seismological principles,

the expert panel members also relied on consistency with the CEUS earthquake database and

the modeling of variability as criteria for determining the final overall cluster weights (0.275,

0.312, 0.196, and 0.217).

For its review of the applicant's response to Open Item 2.5-1, the staff examined the plots and

tables of model residuals provided by the applicant for the cluster 1 ground motion models.

The staff verified that, for the ground motion frequencies (1, 5, and 10 Hz), the three Silva et al.

ground motion models do provide the smallest mean residual values (i.e., best fit to the

earthquake data) cormpared to the other cluster 1 models. As a result, EPRI gave weights of

0.192, 0.148, and 0.560 to these three ground motion models.

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To resolve the concern that these three models, which account for 90 percent of the overall

cluster 1 model, do not adequately represent the variability in travel path, the staff compared

Figures 4-2 and 4-6 in the EPRI (2004) ground motion report. As noted by the applicant, there

is a slightly higher variability for distances beyond 100 km as shown in Figure 4-6. This result

suggests that travel path variability for the overall cluster 1 model may be somewhat low.

However, for source distances out to about 300 km, the differences in variability are negligible.

This result implies that the overall cluster 1 model uncertainty contains a sufficient amount of

travel path variability.

To resolve the concern regarding the use and application of seismological principles to assign

final overall weights to each of the four cluster groups, the staff reviewed the new information

provided in the latest version of the EPRI ground motion'report.' Based on the criterion of

seismological principles, the EPRI expert panel members gave similar weights to each of the

four ground motion clusters. This result implies that the EPRI expert panel members did not

find significant differences among the four model clusters regarding the use of seismological

principles. The staff also reviewed the seismological principles used by the expert panel

members and determined that these principles are relevant and significant for ground motion

estimation.

In conclusion, as described above, the applicant has adequately resolved each of the staff's

concerns with regard to the development by EPRI of new ground motion models for the CEUS.

Therefore, the staff concludes that the applicant's use of the EPRI (2004) ground motion

attenuation models provides an adequate estimate of the ground motion for CEUS earthquakes

and, as such, an adequate characterization of the seismic hazard for the ESP site.

The staff concludes that the applicant's PSHA adequately characterized the overall seismic

hazard of the ESP site. As set forth above, the staff finds that the applicant's underlying

assumptions and update of the previous EPRI PSHA adequately incorporate the most recent

studies and evaluations of the seismic source zones surrounding the ESP site. The staff also

concludes that the applicant's controlling earthquakes for the ESP site (magnitude of 5.4 at

20 km and magnitude of 7.2 at 308 km) are generally consistent with previous PSHA results for

the region. In addition, the staff finds that the ground motions developed by the applicant from

the controlling earthquakes are consistent with the most recent ground motion evaluations.

Accordingly, the staff concludes that the applicant followed the guidance in RG 1.165 for

evaluating the regional earthquake potential and determining the ground motion resulting from

the controlling earthquakes. Based on the foregoing, the staff considers Open Item 2.5-1 to be

resolved.

2.5.2.3.5 Seismic Wave Transmission Characteristics of the Site

The staff focused its review of SSAR Section 2.5.2.5 on the applicant's incorporation of the

seismic wave transmission characteristics of the material overlying the base rock at the site into

the determination of the SSE. SSAR Section 2.5.4.7 provides a description of the transmission

characteristics of the site material.

In RAls 2.5.2-1 (c) and 2.5.2-8, the staff asked the applicant to explain how it factored the

properties of the site-specific subsurface materials into the determination of the SSE.-

According to the applicant's responses, it calculated the' SSE directly using the EPRI 2003

ground motion models, which assume generic hard rock conditions for all of the CEUS. The

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shear wave velocity assumed by the EPRI 2003 ground motion models for the generic hard

rock conditions is 9200 ft/s. The applicant stated that, since the containment (reactor) building

and primary supporting safety-related structures would be founded on sound bedrock, either

Zone IV or Zone III-IV rock, the generic hard rock conditions assumed by the EPRI 2003,

ground motion report are a "good approximation' for the ESP site. As such, the applicant did

not factor in any of the local ESP site properties for its determination of the SSE.

As set forth in the DSER, the staff considered the applicant's response above to be inadequate

based on a comparison of the average bedrock Zone III-IV shear wave velocity (3300 ft/s) and

the generic hard rock shear wave velocity (9200 ft~s) assumed by EPRI 2003. SSAR

Figure 2.5-62 shows that the measured shear wave velocity values for the upper soil and rock

layers beneath the ESP site are below that of the hard rock conditions assumed by EPRI 2003.

Thus, the hard rock shear wave velocity of 9200 ft/s may not be reached at the ESP site until a

considerable depth below the ground surface. In addition, 10 CFR 100.23(d)(1) states the

following:

The Safe Shutdown Earthquake Ground Motion for the site is characterized by

both horizontal and vertical free-field ground motion response spectra at the free

ground surface.

Therefore, as further set forth in the DSER, the staff determined that the applicant's SSE did

not represent the free-field ground motion at the free ground surface. Open Item 2.5-2 covered

the necessity to include the local ESP site conditions into the determination of the SSE.

In response to Open Item 2.5-2, the applicant reran its analysis to determine the response of

the ESP site at the free ground surface, as required by 10 CFR 100.23(d)(1). The applicant's

new analysis use a rock subsurface profile that extends from the top of Zone III-IV bedrock to a

depth of 160 ft under the site where the shear wave velocity reaches about 9200 ft/s. The

applicant defined the top of rock layer Zone III-IV to be its control point for consistency with the

guidance in Section 3.7.1 of NUREG-0800, which states the following:

For sites composed of one or more thin soil layers overlying a competent

material or in case of insufficient recorded ground-motion data, the control point

is specified on an outcrop or a hypothetical outcrop at a location on the top of the

competent material.

The applicant used the ESP rock subsurface profile to estimate the ground motion amplification

of the site and, therefore, to determine an SSE that incorporates the local site rock properties.

To determine the control point SSE at the top of Zone III-IV rock, the applicant (1) developed a

shear wave velocity profile for the ESP site, (2) generated alternative randomized rock columns

to incorporate the variability in the rock properties, (3) selected seed earthquake time histories,

and (4) performed the final ground response analysis. SER Section 2.5.2.1.6 describes each of

these-steps in detail.

The staff reviewed the applicant's analysis to ensure that it accurately incorporates the local site

properties and conditions as well as their uncertainties. The applicant developed 50 different

randomized rock columns in order to model the uncertainties in the rock properties, such as

shear wave velocities, densities, and damping values. The staff also verified that the response

spectra from the two earthquake time histories used by the applicant for its convolution match

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the low- and high-frequency spectra from the two controlling earthquakes. As a result of theapplicant's inclusion of the local site rock properties, some of the spectral acceleration values

for the final SSE ground motion spectrum increased by as much as a factor of 1.67. As shown

previously in Figure 2.5.2-6, these increases mainly occur at frequencies above 10 Hz. The

staff concludes that the applicant's site response analysis accurately incorporates the local site

properties as well as the variability in these properties. Based on the above, the staff considers

Open Item 2.5-2 to be resolved.

2.5.2.3.6 Safe-Shutdown Earthquake Ground Motion

The staff focused its review of SSAR Section 2.5.2.5 on the applicant's procedure to determine

the SSE. For SSAR Revision 3, issued in September 2004, the applicant used two different

methods to determine the ground motion response spectra for the ESP site.

Originally, the applicant used a new method to determine the site SSE, referred to as a

performance-based approach. In RAI 2.5.2-1,- the staff asked the applicant to explain how the

performance-based approach meets the requirements of 10 CFR 100.23, which provide the

geologic and seismic siting criteria as well as a definition of the SSE. In response to

RAI 2.5.2-1, the applicant explained how the performance-based approach conforms with the

requirements of 10 CFR 100.23. In RAI 2.5.2-9, the staff asked the applicant for further details

on the performance-based approach beyond those provided in SSAR Section 2.5.2.6. In;

response to RAI 2.5.2-9, the applicant provided further justification for the performance-based

approach, including the derivation of some of the key relationships.

After reviewing the applicant's responses to RAls 2.5.2-1 and 2.5.2-9 regarding its

performance-based approach, the staff informed the applicant that it would need to devote

additional time and resources to review this new method. In a letter dated August 19,2004, the

applicant informed the staff that it would revise SSAR Section 2.5.2 to base the selected SSE

on the reference probability approach, in accordance with RG 1.165. The applicant also

indicated that it would retain the performance-based approach in the SSAR as "alternate and

further justification for the final SSE." Since the applicant has chosen to determine the final

SSE in accordance with RG 1. 1 65, the staff decided that it will not evaluate the performance-.

based approach for conformance with the requirements of 10 CFR 100.23 or review the overall

acceptability of the approach. Therefore, the staff did not reach any conclusion with respect to

the information in the SSAR regarding the performance-based approach or the applicant's

responses to RAls 2.5.2-1 and 2.5.2-9 that pertain to the performance-based approach. -

In conjunction with its decision to base the final SSE on the reference probability approach in

accordance with RG 1.165, the applicant also decided to use a higher reference probability

(5x105) than that recommended by RG 1.165 (1x10-5). In addition, the applicant chose to use

the mean PSHA curves rather than the median curves. Because the mean hazard curves are

higher then the median curves, the applicant's use of the mean curves is conservative. In

RAI 2.5.2-1 (d), the staff asked the applicant to justify the proposed higher reference probability.

In response to RAI 2.5.2-1 (d), the.applicant stated that it used a higher reference probability

because of (1) higher ground motion estimates from the 2003 EPRI ground motion models,

(2) shorter recurrence intervals for the New Madrid and Charleston seismic sources, and (3) the

use of the mean hazard instead of the median hazard. Each of these factors (particularly the

first two) increase the overall seismic hazard level for the CEUS and specifically, for the 29

nuclear power plant sites used to determine the original reference probability. Because the

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Its

reference probability recommended in RG 1.165 (lx105) is based on the LLNL and EPRI

PSHAs from the late 1980s, the staff concurs with the applicant's conclusion that this value is

likely to be out of date and overly conservative.

To evaluate the applicant's use of a higher reference probability (5x1 0-5) and use of mean

rather than median PSHA results, the staff performed an independent analysis to reevaluate

the reference probabilities for the 29 nuclear power sites in the CEUS that were used to

determine the original reference probability. For its independent analysis, the staff used the

most recent 2002 USGS PSHA mean and median hazard curves to determine the probability of

exceeding the SSEs for the 29 CEUS sites. The staff also applied the same 5 Hz and 10 Hz

site correction factors that were used in the LLNL seismic hazard analysis, published in 1993.

Although the staff has not officially endorsed the 2002 USGS PSHA results, the.staff was able

to verify that the reference probability proposed by the applicant (5x1 05) is sufficiently

conservative. This larger reference probability value (5x1 0-5) implies a lower return period

(20,000 yrs) for the design ground motion; however, the staff was able to verify through its

analysis that this revised reference probability results in a final SSE of adequate severity that is

representative of the seismic hazard for the ESP site.

Using the RG 1.165 approach, the applicant determined the ground motion response spectra

for the ESP site controlling earthquakes (magnitude of 5.4 at 20 km and magnitude of 7.2 at

308 km). The applicant then enveloped these two response spectra with the performancebased spectrum to create the final SSE spectrum. The staff's acceptance of the use of the

performance-based spectrum to envelope the two controlling earthquake response spectra

does not imply that the staff has endorsed the performance-based approach. As described in

Appendix F to RG 1.165, any smooth spectral shape that envelopes the two controlling

earthquake response spectra is acceptable as the site SSE. However, as set forth in the

DSER, the staff (see Open Item 2.5-2) determined that this final SSE did not meet the

requirements specified in 10 CFR 100.23(d)(1), which states that "the Safe Shutdown

Earthquake Ground Motion for the site is characterized by both horizontal and vertical free-field

ground motion response spectra at the free ground surface." As discussed above, the

applicant addressed the staff's concern by performing a detailed site response analysis that

incorporates the local site properties as well as the variability in these properties. Therefore,

the final ESP site SSE meets the requirements specified in 10 CFR 100.23 in that it

incorporates the local site subsurface properties and represents the free-field ground motion.

To determine the vertical SSE spectrum, the applicant used the V/H response spectral ratios

provided in NUREG/CR-6728. To confirm the appropriateness of these V/H ratios, the

applicant performed a site-specific analysis. For the site-specific analysis, the applicant used

the ESP site compressional and shear wave profile data together with four different earthquake

magnitude-distance pairs to compute vertical and horizontal ground motion spectra for the Zone

111-IV hypothetical rock outcrop control point. The applicant stated that the V/H ratios that it

obtained from the site-specific analysis are about 30% lower than the V/H ratios provided in

NUREG/CR-6728 for a PGA between 0.2g and 0.5g. As such, the applicant concluded that

these V/H ratios are appropriate from the North Anna ESP site.

To verify the adequacy of the V/H SSE ratios used by the applicant, the staff evaluated the

applicant's site specific analysis. For its evaluation, the staff considered the adequacy of the

four magnitude-distance pairs and the compressional and shear wave velocity profiles.

Regarding the magnitude-distance pairs, four earthquake magnitude-distance pairs used by the

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applicant range from'M = 5.1 to 6.1 with accompanying distances from 7.5 km to 75 km. For

comparison, the high-frequency controlling earthquake from the CVSZ for the ESP site is M =

5.4 at 20 km. Accordingly, the staff finds that they adequately represent the range of

magnitudes and distances from a local earthquake in the CVSZ. Regarding the compressional

and shear wave velocity profiles,- the applicant used data from both its ESP site exploration and

older data from the licensee's exploration for Units 1 and 2. The applicant formed two -velocity

models from these two data sets, giving larger weight (75 percent) to the model based on the

more recent ESP velocity data. The staff verified that these two models accurately represent

the actual site properties given by the compre6sional and shear wave velocity profiles. The

staff then compared the site-specific V/H ratios with the ratios actually used by the applicant

from NUREG/CR-6728. On average, the mean V/H ratios from the site-specific analysis are

approximately 30 percent lower, over the complete frequency range considered, than the V/H

ratios used by the applicant from-NUREG/CR-6728 for a PGA between 0.2g and 0.5g. Since

the V/H ratios used by the applicant range from 0.75 to greater than 1.0 and these V/H ratios

are 30 percent higher than V/H ratios from the site-specific analysis, the staff finds that they are

conservative and adequate for the North Anna ESP site.

In SSAR Sections 2.5.2.6.9 and 2.5.2.6.10, the applicant alluded to future modifications of the

site SSE spectrum in order to obtain an engineering design spectrum (EDS) that represents

'the proper input into the large nuclear power plant structures." The applicant stated that the

ESP site SSE is not suitable for the design of the SSCs of nuclear power plants because of

high spectral accelerations in the high-frequency range (about 15 to 30 Hz). According to the

applicant, the EDS would take into account plant-specific structural characteristics and local site

conditions, as well as the ESP SSE spectrum. However, the ESP application does not include

the EDS because the applicant has not selected a specific reactor design. The applicant

proposed to include the EDS as part of a COL application. Because the applicant did not

provide any specific recommendations or procedures for developing the EDS; the staff cannot

evaluate the merits of the proposed approach.

The staff considers the SSE developed for the ESP site to be consistent with Appendix S to

10 CFR Part 50, which defines the SSE as the "vibratory ground motion for which certain

structures, systems, and components must be designed to remain functional."

Section 2.5.2.3.5 of this SER addresses the applicant's compliance with 10 CFR 100.23(d) with

regard to the SSE. Future modifications of the SSE spectrum, if any, in an application for a

COL or CP must be compatible with 10 CFR Parts 50 and 100.

2.5.2.4 Conclusions

As set forth above, the staff reviewed the seismological information submitted by the applicant

in SSAR Section 2.5.2. On the basis of its review of SSAR Section 2.5.2 and the applicant's

responses to the RAls and open items, as described above, the "staff finds that the'applicant

has provided a thorough characterization of the seismic sources surrounding the site, as

required by 10 CFR -100.23. In addition, the staff finds that the applicant has adequately

addressed the uncertainties inherent in the characterization of these seismic sources through a

PSHA, and that this PSHA follows the guidance provided in RG 1.165. The staff concludes that

the controlling earthquakes and associated ground motion derived from the applicant's PSHA -

are consistent with the seismogenic region surrounding the ESP site. In addition, the staff finds

that the applicant's SSE was determined in accordance with RG 1.165 and Section 2.5.2 of

NUREG-0800 and accurately includes the effects of the local ESP subsurface properties. The

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staff concludes that the proposed ESP site is acceptable from a geologic and seismologic

standpoint and meets the requirements of 10 CFR 100.23.

2.5.3 Surface Faulting

SSAR Section 2.5.3 describes the potential for tectonic fault rupture at the ESP site. The

applicant concluded that the site has no potential for tectonic fault rupture since no capable

tectonic sources exist within a 5-mile radius of the ESP site. SSAR Section 2.5.3.1 describes

the applicant's geological, seismological, and geophysical investigations to assess the potential

for surface faulting within a 5-mile, radius of the ESP site. SSAR Section 2.5.3.2 describes the

geologic evidence, or absence of evidence, for surface deformation. SSAR Section 2.5.3.3

describes the correlation of earthquake epicenters with faults in the vicinity of the ESP site.

SSAR Section 2.5.3.4 provides the ages of the most recent deformations in the site area.

Finally, SSAR Sections 2.5.3.5 through 2.5.3.8 describe tectonic structures in the site area, the

absence of capable sources and Quaternary deformation, and the potential for tectonic or

nontectonic deformation at the site.

2.5.3.1 Technical Informnation in the Application

2.5.3.1.1 Surface Faulting Investigations

Geological. Seismological, and Geophysical Investigations

According to SSAR Section 2.5.3.1, the applicant performed the following investigations to

assess the potential for surface faulting at and within a 5-mile radius of the ESP site:

* compilation and review of existing data

* interpretation of aerial photography

* field reconnaissance

* review of seismicity

* discussions with current researchers in the area

Based on previous site investigations performed for the existing NAPS Units 1 and 2, the

applicant concluded that (1) no evidence of surface rupture, surface warping, or the offset of

geomorphic features indicative of active faulting exists, (2) no historical seismic activity has

occurred in the site area, as the closest epicenter location is 30 miles away, and (3) inspections

of excavations during construction and examination of soil and rock samples from borings

reveal no evidence of geologically recent faulting.

The applicant performed aerial and field reconnaissance investigations within a 25-mile radius

of the ESP site, and it examined and interpreted aerial photographs of all known faults within

5 miles of the site. Through these studies, the applicant verified the existence of mapped

bedrock faults in the site area and assessed the presence or absence of geomorphic features

that indicate potential Quaternary fault activity.

In addition to its own investigations, the applicant used USGS maps of the area, as well as a

USGS compilation of all Quaternary faults, liquefaction features, and possible tectonic features

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in the eastern United States, to assess the potential for surface faulting within a 5-mile radius of

the ESP site.

Geologic Evidence for Surface-Deformation

SSAR Section 2.5.3.2 lists the following bedrock faults that are within 5 miles of the ESP site:

* Chopawamsic fault

* Spotsylvania thrust fault

* unnamed faults "a," ub," and "c"

* Sturgeon Creek fault

* Long Branch thrust fault

All of these faults formed during the early Paleozoic Era as part of the regional Taconic orogeny

and may have become reactivated during later Paleozoic orogenies (Acadian and Allegheny).

The applicant stated that several of the faults may have been locally reactivated during the

Triassic episode of continental rifting; however, none of these faults border Triassic basins,

implying that Triassic reactivation, if any, was not significant. Figure 2.5.3-1, reproduced from

SSAR Figure 2.5-56, shows these Paleozoic faults on an ESP site vicinity geologic map.

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i:. : MIf Do! ,X K.8 4 Seismic Epicenters

(b m=__tat

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SSAR Section 2.5.3.2 states that the applicant identified no deformation or geomorphic features

indicative of potential Quaternary activity in the literature or during aerial and field

reconnaissance. In addition, the recent USGS compilation of all Quaternary faults, liquefaction

features, and possible tectonic features in the eastern United States includes none of the faults

listed above as potential Quaternary faults.

In RAI 2.5.3-1, the staff asked the applicant to provide additional detail on its field investigations

and aerial reconnaissance of the site area; In response to RAI 2.5.3-1, the applicant stated that

it performed aerial and field reconnaissance along faults within a 5-mile radius of the ESP site.

The applicant's reconnaissance emphasized unnamed fault ua" and the Sturgeon Creek fault

because of their proximity to the site. In addition, the applicant covered parts of the

Spotsylvania, Chopawamsic, and Long Branch faults where these faults were mapped near

local roads and/or where they potentially offset plutonic (igneous) margins or metamorphic

contacts. Based on the absence of any geomorphic expression' indicative of potential

Quaternary deformation, the applicant concluded that none of the faults are capable. In

addition, the applicant stated that all of the faults in the site area cross gently rolling

topography, with relief on the order of 200 ft, and that this rolling topography formed through

dissection and erosion of a once broad, continuous Miocene (5-24 ma) pediment that extended

across the region. The applicant looked for potential elevation differences in the Miocene

pediment gravels across each of the faults that would suggest post-Miocene vertical separation.

Based on its field reconnaissance,'the applicant did not observe any significant elevation

differences. Therefore, the applicant concluded based on its detailed field observations and

aerial reconnaissance that, for all seven faults within the site area, no evidence or criteria would

suggest Quaternary activity on these structures.

Foundation excavations for the abandoned NAPS Units 3 and 4 exposed the unnamed bedrock

fault Ma" traversing the North Anna site. Detailed investigations of this fault show no evidence of

Quaternary faulting. Therefore, the applicant concluded that this fault is not a capable tectonic

source. In reviewing the applications for construction permits for abandoned NAPS Units 3 : ,

and 4, the applicant indicated that the Atomic Energy Commission (which subsequently became

the NRC) accepted this position in its 1974 SER for Units 3 and 4.

In RAI 2.5.3-2, the staff asked the applicant to further support its conclusion that unnamed fault

"a" does not extend beyond the ESP site, as mapped by Pavlides (Ref: 36, SSAR Section 2.5).

In its response, the applicant stated that the NAPS licensee discovered fault "a" in 1973 during

the foundation excavation for the abandoned NAPS Units 3 and 4 and subsequently mapped

fault "a" for a distance of about 3000 ft. Virginia Power did not observe fault "a" in the

foundation excavations for the existing Units 1 an'd 2. The applicant stated that Pavlides, who

is deceased, did not provide an explanation for extending fault "a" for a total distance of about::

7 miles. Subsequently, Mixon and others (Ref. 66, SSAR Section 2.5) adopted Pavlides'

interpretation of the extent of fault 'a." The applicant stated that Pavlides did not map any.

offset stratigraphic contacts in the Lake Anna area to support the mapped location of the fault.

In addition, a'close inspection of the'original mapping by Pavildes'compared to the compilationmap by Mixon shows that the offsets that are apparently mapped in the stratigraphic contacts

appear to be a compilation error. The applicant provided further evidence to support its original

mapping of fault "a" in response to RAI 2.5.3-1.

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Correlation of Earthquake with Capable Tectonic Sources

SSAR Section 2.5.3.3 states that no reported historical earthquake epicenters have been

associated with bedrock faults within a 25-mile radius of the ESP site vicinity. The applicant

established a seismic monitoring network for NAPS and recorded very small earthquakes

(microearthquakes) over a 3.5-year period from 1974 to 1977. The applicant used this

monitoring program to determine if seismic activity could be associated with faults in the site

area or if Lake Anna was producing reservoir-induced seismicity. The applicant concluded that

the microearthquakes detected in the site area could not be associated with either faults in the

site area or with the impoundment of Lake Anna. Four of the original 17 seismic monitoring

stations in the network were incorporated into the VT Central Virginia Monitoring Network for

the specific purpose of monitoring any changes in seismicity in the region of the NAPS. To

date, no changes in local earthquake activity have been observed that would alter the

conclusions regarding the lack of association of microearthquakes with faults in the site area.

Microearthquakes in the site area occur at a level no greater than the spatially varying

background activity found in the CVSZ.

Aaes of Most Recent Deformations

SSAR Section 2.5.3.4 states that none of the seven faults within 5 miles of the ESP site exhibit

evidence of Quaternary activity.- All of these faults formed during the Paleozoic Era as part of

the Taconic orogeny and may have been reactivated during later Paleozoic orogenies or during

the Triassic continental rifting. Based on a review of the available literature and field

investigations, the applicant concluded that the seven bedrock faults within 5 miles of the site

are old structures that formed during the Paleozoic-age orogenies or early Mesozoic-age rifting.

Relationship of Tectonic Structures in Site Area to Regional Tectonic Structures

SSAR Section 2.5.3.5 states that the seven faults in the site area are located within the

Chopawamsic belt, which is interpreted to be an island-arc that was accreted to North America

during the Taconic orogeny. Following the Taconic orogeny, rocks of the Chopawamsic belt

were deformed and thrust westward during the Acadian and Allegheny orogenies that occurred

later during the Paleozoic Era. Extensional tectonics may have also affected the rocks in the

Chopawamsic belt during the Mesozoic rifting.

Characterization of Capable Tectonic Sources

SSAR Section 2.5.3.6 states that no capable tectonic sources exist within 5 miles of the ESP

site.

Designation of Zones of Quaternarv Deformation Requiring Detailed Fault Investigations

SSAR Section 2.5.3.7 states that no zones of Quaternary deformation warrant detailed

investigations within the site area.

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Potential for Tectonic or Nontectonic Deformation at the Site

SSAR Section 2.5.3.8 states that the ESP site has a negligible potential for tectonic

deformation. Since the original studies in the early 1970s, no new information has been

reported to suggest the exist6n6e of any Quaternary surface faults or capable tectonic sources

within the site area. In addition, the site shows-no evidence of nontectonic deformation, such

as glacially induced faulting, collapse structures, growth faults, salt migration, or volcanic

intrusion.

2.5.3.2 Regulatory Evaluation

SSAR Section 2.5.3 describes the applicant's evaluation of the potential for surface deformation

that could affect the site. In SSAR Section 1.8, the applicant stated that the information

presented in SSAR Section 2.5.3 conforms with the requirements of GDC 2 of Appendix A to

10 CFR Part 50, Appendix S to 10 CFR Part'50, and 10 CFR 100.23. The applicant also stated

that it developed the geological, seismological, and geophysical information used to evaluate

the potential for surface deformation in accordance with the guidance presented in

NUREG-0800, Revision 3, Section 2.5.3, and RGs 1.70,1.132,1.165, and 4.7.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

100.23(d)(2),-which state that an applicant for an ESP must determine the potential for surface

tectonic and nontectonic deformations. The staff notes that application of Appendix S in an

ESP review, as referenced in 10 CFR 100.23(d), is limited to defining the minimum SSE for

design; Section 2.5.3 of NUREG-0800 and RG 1.1 65 provide specific guidance concerning the

evaluation of information characterizing the potential for surface deformation, including the ' -

geological, seismological, and geophysical data that the applicant must provide to establish the

potential for surface deformation.

2.5.3.3 Technical Evaluation

This section of the SER provides the staff's evaluation of the seismological, geological, and

geophysical investigations carried out by the applicant to address the potential for surface

deformation that could affect the site. The technical information presented in SSAR

Section 2.5.3 resulted from the applicant's surface and subsurface investigations performed in

progressively greater detail as they moved closer to the ESP site. Through its review, the staff

determined whether the applicant complied with the applicable regulations and conducted its

investigations with an appropriate level of thoroughness.

In order to thoroughly evaluate the surface faulting investigations performed by the applicant,

the staff sought the assistance of the USGS. The staff and its USGS advisors visited the ESP

site and met with the applicant to assist in confirming the interpretations, assumptions, and

conclusions presented by the applicant cohnerning potential surface deformation. Specific.

areas of review include the geological investigations (SSAR Section 2.5.3.1), evidence for

surface deformation (SSAR Section 2.5.3.2), correlation of earthquake activity with capable'

seismic sources (SSAR Section 2.5.3.3), ages of most recent deformations (SSAR

Section 2.5.3.4), site area and regional tectonic relationships (SSAR Section 2.5.3.5),:

characterization of capable tectonic sources (SSAR Section 2.5.3.6), Quaternary deformation in

the site region (SSAR Section 2.5.3.7), and the potential for surface tectonic deformation at the

site (SSAR Section 2.5.3.8).

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2.5.3.3.1 Surface Faulting Investigations

The staff focused its review of SSAR Sections 2.5.3.1 through 2.5.3.8 on the adequacy of the

applicant's investigations to ascertain the potential for surface deformation that could affect the

site. The staff reviewed the applicant's summary of previous site investigations performed for

the existing NAPS Units 1 and 2 and the abandoned NAPS Units 3 and 4, as well as recent

investigations.

In RAI 2.5.3-1, the staff asked the applicant to provide additional detail on its field investigations

and aerial reconnaissance of the site area. In its response, the applicant stated that it

performed aerial and field reconnaissance along each of the faults within a 5-mile radius of the

ESP site. The staff reviewed the evidence presented by the applicant's response to

RAI 2.5.3-1, particularly the applicant's documentation of its field reconnaissance. Specifically,

the staff reviewed the applicant's description of its search for evidence of Quaternary

deformation for each of the faults, including the applicant's field observations across the

Miocene pediment that extends across the region. The staff and its USGS consultants also

visited the site area and viewed the continuous, gently inclined Miocene surface referred to in

the applicant's response. The staff did not observe any significant vertical displacements that

would indicate post-Miocene (5-24 ma) displacement or activity. In summary, the staff and its

consultants did not observe evidence for Quaternary activity on any of these local faults and

conclude that the applicant has adequately investigated the potential for surface deformation as

required by 10 CFR 100.23.

In RAI 2.5.3-2, the staff asked the applicant to further support its conclusion that unnamed fault

'a" does not extend beyond the ESP site as mapped by Pavlides (Reference 36, SSAR 2.5.2).

In its response, the applicant stated that Virginia Power discovered fault "a" in' 1973 during the

foundation excavation for the abandoned NAPS Units 3 and 4 and subsequently mapped fault

"a" for a distance of about 3000 ft. Virginia Power did not observe fault "a" in the foundation

excavations for the existing NAPS Units 1 and 2. The applicant stated that Pavlides, who is

deceased, did not provide an explanation for extending fault "a" for a total distance of about

7 miles. Subsequently, Mixon and others (Ref. 66, SSAR Section 2.5.2) adopted Pavlides'

interpretation of the extent of fault "a." The applicant stated that Pavlides did not map any

offset stratigraphic contacts in the Lake Anna area to support the mapped location of the fault.

In addition, the applicant's inspection of the original mapping by Pavlides compared to the

compilation map by Mixon showed that the offsets apparently mapped in the stratigraphic

contacts appear to be a compilation error. During its field reconnaissance, the applicant found

no scarps or lineaments along the extended trace of fault "a" as mapped by Pavlides. The staff

notes that the NAPS licensee's trenching of the fault 'a" shows that it is most likely a minor fault

or bedrock shear within the Ta River metamorphic suite and that it is very unlikely that such a

minor fault could be recognized or mapped over a significant distance without a significant

number of exposures. The applicant provided further evidence, described above, to support its

original mapping of fault "a" in response to RAI 2.5.3-1. Based on this evidence, the staff

concludes that fault uaa is unlikely to extend much farther than originally mapped by the

applicant.

In SSAR Table 1.9-1, the applicant identified the item "Capable Tectonic Structures or Sources"

as an ESP site characteristic. This item specifies that no fault displacement potential exists

within the investigative area. As described above, the staff reviewed the applicant's description

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of unnamed fault "a" in SSAR Section 2.5.3.2.2 and concludes that the ESP site has no fault

displacement potential.

Based on its review of SSAR Sections 2.5.3.1 -through 2.5.3.8 and the applicant's responses to

the RAls, as set forth above, the staff concludes that the applicant adequately investigated the

potential for surface faulting in the site area. The staff concludes that the applicant performed

extensive field and aerial reconnaissance of the local faults and concurs with the applicant's

assertion that no capable faults exist within the site area. The staff and its USGS consultants

also visited the site area and were able to view some of these local faults.- Based on its site

visit and its review of SSAR Section 2.5.3, as set forth above, the staff concurs with the -

applicant's conclusion that there is no evidence of Quaternary folding or faulting that could be

associated with these local faults.

2.5.3.4 Conclusions

In its review of the geologic and seismologic aspects of the ESP site, the staff considered the

pertinent information gathered by the applicant during the regional and site-specific geological,

seismological, and geophysical investigations. As a result of this review, described above, thestaff concludes that the applicant performed its investigations in accordance with 10 CFR

100.23 and RG 1.165 and provided an adequate basis to establish that no capable tectonic

sources exist in the site vicinity that would cause surface deformation in the site area. The staff

concludes that the site is suitable from the perspective of tectonic surface deformation and

meets the requirements of 10 CFR 100.23.

2.5.4 Stability of Subsurface Materials and Foundations

SSAR Section 2.5.4 presents information on the stability of subsurface materials and

foundations at the ESP site. SSAR Section 2.5.4.2 describes the engineering properties of the

subsurface materials, SSAR Section 2.5.4.3 summarizes both the previous subsurface

investigations and ESP exploration program, SSAR Section 2.5.4.4 summarizes geophysical

investigations performed at the site, SSAR Section 2.5.4.5 describes the extent of anticipated

excavations, fills, and slopes, Section SSAR 2.5.4.6 describes the ground water conditions at

the site, SSAR Section 2.5.4.7 provides the response of subsurface materials to dynamic

loading, and SSAR Section 2.5.4.8 describes the liquefaction potential of the site. SSAR

Sections 2.5.4.1, 2.5.4.9, and 2.5.4.11 refer to topics that the SSAR covers in greater detail

elsewhere. Finally, SSAR Section 2.5.4.12 summarizes techniques that would be used to

improve subsurface conditions.'

2.5.4.1 Technical Information in the Application'

2.5.4.1.1 Geologic Features

SSAR Section 2.5.4.1 refers to the description of regional and site geologic features in SSAR

Sections 2.5.1.1 and 2.5.1.2. Section 2.5.1.3 of this SER contains the technical evaluation of

this information.

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2.5.4.1.2 Properties of Subsurface Materials

SSAR Section 2.5.4.2 describes the static and dynamic engineering properties of the ESP site

subsurface materials. Section 2.5.4.2 also describes the subsurface materials, as well as

laboratory test results and the engineering properties of the subsurface materials.

Description of Subsurface Materials

The applicant stated that it derived the properties of the subsurface materials encountered at

the site from 140 subsurface borings made to date at both the NAPS and the ESP sites. The

applicant divided the subsurface materials into five zones and described them as summarized

below. Figures 2.5.4-1 and 2.5.4-2, reproduced from SSAR Figures 2.5-57 and 2.5-58, show

two subsurface profiles (A-A' and B-B') that depict the layering of each of the soil and rock

zones beneath the ESP site as well as the ESP borehole locations.

Zone IV Bedrock

Zone IV is composed of fresh to slightly weathered gneiss, which is a metamorphic rock that

exhibits a banded texture (foliation) in which light and dark bands alternate. Gneiss is

composed of feldspar, quartz, and one or more other minerals such as mica and hornblende.

The top of the Zone IV (including Zone III-IV) bedrock at the ESP site ranges from an elevation

of 188 to 298 ft.

Zone IlIl Weathered Rock

The weathered rock has the same constituents as the parent rock. It is described as

moderately to highly weathered rock, sometimes with unweathered seams and sometimes with

a high fracture frequency. It is defined as having at least 50 percent core stone. The top of the

Zone IlIl bedrock at the ESP site ranges from an elevation of 205 to 298 ft.

Zone IIA and IIB Saprolites

Saprolites are a further stage of weathering beyond weathered rock. They have been produced

by the disintegration and decomposition of the bedrock in place and have not been transported.

Although classified as soils, saprolites contain the relict [remnant] structure of the parent rock,

as well as some core stone of the parent rock. The ESP site saprolites in many instances

maintain the foliation characteristics of the parent rock. They are classified primarily as silty

sands, although there are also sands, clayey sands, sandy silts, clayey silts, and clays,

depending on their degree of weathering. The fabric is anisotropic. The texture shows angular

geometrically interlocking grains with a lack of void network, very unlike the well-pronounced

voids found in marine or alluvial sands and silts.

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2-211
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I4
The distribution of the Zone IIA and IIB saprolites varies throughout the site. On average, the

Zone JIB saprolites represent about 20 percent of the saprolites on site and are typically very

dense, silty sands with 10 to 50 percent core stone. The thickest Zone JIB deposit encountered

in the'borings is 37 ft. The overlying Zone IIA'saprolites comprise, on average, about

80 percent of the saprolitic mnaterials o0n site. About 75 percent of the Zone IIA saprolites are

classified as coarse grained (sands, silty sands), while the remainder are fine grained (clayey

sands, sandy and clayey silts, and clays). The saprolites typically become finer toward the

ground surface. The thickest Zone IIA deposit encountered in the borings is 101 ft.

Zone I and Fill

Typically, very little Zone I residual soil exists onsite; on average, less than one percent of the

soil is Zone I. The Zone I soils are either at the surface or are immediately below the fill placed

during construction of the earlier units. This fill generally consists of Zone IIA soils.

Laboratory Testing

SSAR Section 2.5.4.2.4 describes the results of numerous laboratory tests of soil and rock

samples performed previously, as well as the new tests performed for the ESP site

investigation. The applicant performed the large majority of the tests on the Zone IIA saprolite'

soils for the various investigations for the SWR for the existing NAPS units; the following briefly

summarizes these investigations. .

Laboratory Tests for the SWR

The laboratory testing of the SWR soils focused on the strength, compressibility, and

liquefaction potential of the Zone IIA saprolites. The tests include (1) cyclic triaxial tests to

provide input for analysis of the liquefaction potential of the soils, (2) static triaxial shear tests

including both consolidated-undrained as well as unconsolidated-undrained tests to determine

shear strength parameters, (3) consolidation tests to determine the deformation behavior under

various loadings, and (4) examinations of thin section's to determine the fabric, texture, and

mineralogy of the saprolite. Appendix A to SSAR Section 2.5.4 presents the results of the '

laboratory testing of the SWR soils, which 'the applicant used to determine liquefaction'

potential, static stability, and the response of the soil to dynamic loading.

Laboratory Tests for ESP . -

The applicant performed laboratory testing for the ESP investigation to verify the large number

of test results for previous investigations. The ESP tests focused on (1) verifying the basic

properties of the Zone IIA saprolite, (2) obtaining chemical tests on the Zone IIA saprolites for

corrosiveness toward buried steel and aggressiveness toward buried concrete, and

(3) obtaining additi6nal strength and 'elastic modulus data for the bedrock on which the main

safety-related structures might be founded."Appendix B to SSAR Section'2.5.4 pesents the

results of the ESI, laboratory tests,'summarized for soil in SSAR Table 2.5-43 and for rock in

SSAR Table 2.5'44: The results listed in these SSAR tables include (1) Atterberg limits (i.e.,

liquid, plastic, and plasticity), (2) sieve weight percentages using a #200 sieve (0.075 mm

opening), and (3) soil chemistry (i.e., pH, chlorides, and sulfates). 'The applicant stated that the

ESP laboratory test results are similar to those obtained from previous testing.

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Engineering Properties

Table 2.5-45 of the SSAR presents the engineering properties of materials in subsurface

Zones IIA, IIB, Ill, III-IV, and IV, which the applicant derived from the previous'studies and from

ESP field exploration and laboratory testing programs. These properties include standard

geotechnical parameters such as natural moisture content, undrained shear strength, effective

cohesion, effective friction angle, total unit weight, standard penetration test (SPT) blow count

values, shear and compression wave velocities, elastic and shear moduli, consolidation

characteristics, and static earth pressure coefficients. The following sections describe the

sources and/or methods used to develop the selected properties shown in SSAR Table 2.5-45.

Rock Properties

The results given in SSAR Table 2.5-41 provide the basis for the recovery and rock quality

designations (RQDS). The ESP rock strength results shown in SSAR Table 2.5-44 and the rock

strengths from the investigations for the existing units form the basis for the unconfined

compressive strength. The unit weight is based on the values measured in the ESP rock

strength tests (SSAR Appendix 2.5.4B).

The elastic modulus values are based on the values shown in, SSAR Table 2.5-44. These

values agree well with those derived from the geophysical tests performed for the ESP

exploration program, as described in SSAR Section 2.5.4.4.2. The shear modulus values are

derived from the elastic modulus values using the Poisson's ratio values given in SSAR

Table 2.5-45, which are based on the values provided in SSAR Table 2.5-44. Low- and highstrain modulus values are essentially the same for high-strength rock (i.e., for the Zone IV

rock). Similarly, no strain softening is assumed for the Zone III-IV rock. The shear and

compression wave velocities are based on the crosshole and downhole seismic tests performed

as part of the ESP exploration program. These results, summarized in SSAR Section 2.5.4.4.2,

agree with those of the geophysical tests performed for the existing units.

In RAI 2.5.4-2(a), the staff asked the applicant to describe the extent of severely weathered

fracture zones in the Zone III-IV and IV rock that Virginia Power observed during the site

investigation for abandoned Units 3 and 4. The applicant observed similarly fractured rock in

four of the seven ESP borings. In response to RAI 2.5.4-2, the applicant provided a table that

shows an RQD of less than 25 percent in nine of the borings for abandoned Units 3 and 4. The

applicant noted that most of the rock thicknesses for the low RQD intervals (less than

10 percent) are only 1 to 2 ft thick. In RAI 2.5.4-2(b), the staff asked the applicant to describe

the impact of these fractured rock zones on the suitability of the site to host safety-related

structures. In response to RAI 2.5.4-2(b), the applicant stated the following:

As noted in these SSAR sections, any weathered or fractured zones

encountered at foundation level would be excavated and replaced with lean

concrete. If such zones exist below sound rock beneath the foundation, they

would have no impact on the stability of the foundation, since these zones are

typically only 0.5 to 1-foot thick, and are confined within an unfractured rock

mass with strengths of 4,000 to 12,000 psi (compared to the maximum

foundation pressure of just over 100 psi). The foundation itself would consist of

a large, thick, highly-reinforced concrete mat that is so stiff that it cannot logically

yield.

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- -

Multiple borings would be performed at each structure location once the building

-locations are chosen as part of detailed'engineering. These borings would

identify whether there are any thicker fracture zones beneath the foundation than

those encountered in the ESP borings and in the abandoned Units 3 and 4

borings. If any thick& zones are found, analysis would b6 performed to identify

their impact on foundation stability. If they are close enough to the foundation to

potentially impact stability, they'would be excavated and replace with lean

concrete.

Soil Properties

Grain size curves from 13 sieve analyses of Zone IIA silty sand samples from the ESP

laboratory testing program fit within the envelope of the 12 sieve analyses of Zone 'IA silty

sands sampled from borings near the SWR pump house. The natural moisture content of the

fine-grained Zone IIA saprolite, determined from the moisture content tests performed on finegrained Zone IIA saprolites for the past and the present (ESP) investigations, ranges from 14 to

56 percent.

The applicant estimated undrained shear strength of the fine-grained Zone IIA saprolite from

SPT -values and cone penetrometer test (CPT) results, as well as from the results of

18 unconsolidated-undrained triaxial compression tests and 3 unconfined compression tests.

The effective strength parameters for the fine-grained saprolite are based on the results of

consolidated-undrained triaxial tests on fine-grained saprolite run for the previous ISFSI (Ref. 6,

SSAR Section 2.5) and SWR investigations (Appendix A to SSAR Section 2.5.4).

The applicant stated that it would typically assume an effective angle of internal friction'of the'

medium-dense coarse-grained saprolite (N=20 blows/ft) of about 35 degrees. However, the

high silt content and the presence of low-plasticity clay minerals reduce this angle.

Consolidated-undrained triaxial tests reported in Appendices 2C and 3E to the UFSAR for the

existing units produced internal friction angles ranging from 23 to 33 degrees, with a median of

30.8 degrees.' Thus, the applicant selected an angle of 30 degrees. The average effective

cohesive component from the UFSAR Appendix 2C tests is 0.275 kps per square foot (ksf).

The applicant selected a value of 0.25 ksf for the cohesive component.

Based on a large amount of testing performed after low unit weights were measured in the

Zone IIA saprolites in the SWR area, the NAPS licensee concluded that there are isolated lower

densities, but that these are not typical. -Table 3.8-13 of the NAPS UFSAR identifies

125 pounds per cubic foot (pcf) as a design total unit weight. The 130 pcf shown in SSAR

Table 2.5-45 for the Zone IIB saprolites reflects the high relative density of that material.

The applicant stated that the SPT design N-value of 20 blows/ft for the Zone IlA saprolite is

conservatively based on the results reported in SSAR Table 2.5-40. Those results show

median N-values for the ESP and ISFSI investigations of 21 blows/ft, with the median N-values

for the existing units, abandoned Units 3 and 4, and SWR investigations ranging from 25 to

52 blows/ft.

The shear wave velocities measured in the ESP crosshole seismic tests in the Zone IIA sandy

silt from a depth of 7.5 to 27 ft range from 650 to 1350 ft/s, with an average of 998 ft/s. The

CPT seismic results are somewhat higher. The UFSAR has a value of 950 ft/s for the Zone IIA

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saprolite. The applicant selected a value of 950 ft/s for the Zone IIA saprolite, as shown in

SSAR Table 2.5-45. For the Zone IIB saprolite, the shear wave velocity derived from the low

strain value of shear modulus agrees well with the results from the CPT seismic tests, at

around 1600 ft/s. Section 2.5.4.7 of the SSAR gives the profile of shear wave velocity versus

depth for the saprolite.

The applicant derived the high-strain (i.e., in the range of 0.25 to 0.5 percent) elastic modulus

values for the coarse-grained Zone IIA saprolite and the Zone IIB saprolite using the

relationship with the SPT -value given in the literature (Ref. 151, SSAR Section 2.5). In

addition, the applicant derived the high-strain elastic modulus for the fine-grained Zone IIA

saprolite using the relationship with undrained shear strength (also given in SSAR Ref. 151).

The applicant stated that it slightly adjusted the Zone IIA coarse- and fine-grained values to

obtain a common value.. The applicant obtained the shear modulus (G) values from the elastic

modulus values using the relationship between elastic modulus (E), shear modulus, and

Poisson's ratio (v).

E

2(1+v)

The applicant derived the low-strain (i.e., 104 percent) shear modulus for the Zone IIA saprolite

from the shear wave velocity of 950 ft/s. Similarly, the applicant derived the low-strain shear

modulus (Gm,,) of the Zone IIB saprolite from the shear wave velocity of 1600 ft/s. The

applicant obtained the elastic modulus values for the Zone IIB saprolite from the shear modulus

values using the relationship between elastic modulus, shear modulus, and Poisson's ratio

(Ref. 150, SSAR Section 2.5).

The values derived from the settlement studies performed for the SWR pump house, as

detailed in Appendix 3E to the UFSAR, include the recompression ratio (total amount of

settlement) and the coefficient of secondary compression (after primary consolidation). The

values of unit coefficient of subgrade reaction are based on values for medium-dense sand

(Zone IIA saprolite) and very dense sand (Zone IIB saprolite) provided by Terzaghi (Ref. 152,

SSAR Section 2.5). The earth pressure coefficients (ratio of lateral load to vertical load) are

Rankine values, assuming level backfill and a zero friction angle between the soil and the wall.

In RAI 2.5.4-4, the staff asked the applicant to explain how the total thickness of the soil layers

sampled at the ESP site (105 ft) is sufficient to characterize the soil properties underlying the

site. The applicant responded that the 138 borings previously performed by Virginia Power for

Units 1 and 2 as well as the abandoned Units 3 and 4 characterize the soils at the North Anna

site very well. The applicant stated that the soils in all of borings show the same general

subsurface profile and that it used the ESP borings to show that the soil (and rock) profiles in

each of the borings fit within the general subsurface profile.

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Chemical Properties

The applicant performed chemical tests on selected Zone lIA samples. In addition to the tests

performed for the ESP site investigation (see the results shown in SSAR Table 2.5-43), Virginia

Power previously performed chemical tests on two samples from the subsurface investigation

for the existing units. The six pH test results range from 5.7 to 6.9, in the mildly corrosive to

neutral range. The six sulfate test results range from about 1 to 28 parts per million, indicating

no aggressiveness toward concrete. Three of the chloride test results range from 100 to

170 milligrams per kilogram (mg/kg), indicating little corrosive potential toward buried steel.

The fourth chloride test produced 920 mg/kg, indicating potential corrosiveness toward buried

steel.

2.5.4.1.3 Exploration

SSAR Section 2.5.4.3 describes the previous subsurface investigations performed at the NAPS

site as well as the ESP exploration program.

Previous Subsurface Investigation Programs

For the existing Units 1 and 2, the NAPS licensee performed 60 borings in 1968, with boring

depths ranging from 20 to 150 ft. For the abandoned Units 3 and 4; Virginia Power performed

47 borings in 1971, with boring depths ranging from 40 to 175 ft. Virginia Power performed an

additional 22 borings in the SWR area after 1976, as well as9 borings in 1994 for the ISFSI.

The borings used SPT sampling, Dames and Moore soil samplers, and NX-size double-tube

core barrels for rock coring. SSAR Tables 2.5-30 through 2.5-37 summarize the boring

locations, the elevations for each of the subsurface zones, and RQDs. Figure 2.5.4-3,

reproduced from SSAR Figure 2.5-59, shows the locations of the previous borings.

In RAI 2.5.4-3, the staff asked the applicant to describe how it integrated the NAPS licensee's

site investigations for the SWR and the ISFSI with its field investigations for the ESP site. The

applicant responded that the SWR and ISFSI borings are as close to the ESP area as any other

borings and disclosed the same subsurface profile displayed by the other borings at the

North Anna site (see SER Figure 2.5.4-3). In addition, the applicant stated that it-used some of

the SWR and ISFSI borings, which are close to the southeast corner of the ESP footprint, noted

in RAI 2.5.4-1, to help characterize the ESP area.

ESP Subsurface Investigation Proaram

The applicant stated that it performed the ESP subsurface investigation in 2002, covering the

area proposed for the new units and the cooling towers for the new units. 'This investigation

consisted of relatively few exploration points, compared to previous field explorations for the

existing units, abandoned units, SWR, and ISFSI. According to the applicant, it designed the

ESP field explorations primarily to confirm the results obtained from the previous extensive

investigations. The applicant stated that it would perform additional structure-specific

exploration and testing during detailed engineering, and a COL application would describe this

testing. Figure 2.5.4-4, reproduced from SSAR Figure 2.5-60, shows the ESP exploration point

locations.

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~9-.x-F - -0 *Ifrlu K-

,, v

II, \Uv Rt ,,,n ai L

Figure 2.5.4-3 Locations of previous boreholes

2-218
Figure 2.5.4-4 ESP borehole locations

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I zIrm

The scope of work related to the ESP site investigation consisted of the following:

* seven exploratory borings

* nine observation wells

* eight CPTs

* two downhole seismic cone tests

* two pore pressure dissipation tests

* two sets of crosshole seismic tests

* one downhole seismic test

* a survey of all exploration points

* laboratory testing of borehole samples and cores

Appendix B to SSAR Section 2.5.4 provides details and results of the exploration program. The

following summarizes the borings, observation wells (OWs), and CPTs.

Borings and Samples/Cores

According to the applicant, the seven borings drilled range from 50 to 170 ft in depth, averaging

85 ft. The 170-ft deep boring is 30 ft deeper than the deepest reactor design considered for the

ESP. The applicant stated that it conducted the SPT in general accordance with American

Society for Testing and Materials (ASTM) D1 586 and performed rock coring in general

accordance with ASTM D2113. The applicant stated that, after removal from the split inner

barrel, it carefully placed the recovered rock in wooden core boxes. The onsite geologist

visually described the core, noting the presence of joints and fractures and distinguishing

natural breaks from mechanical breaks. The geologist also computed the percentage recovery

and the RQD. Appendix B to SSAR Section 2.5.4 provides the boring logs and the photographs

of the rock cores. These boring logs describe in detail the soil and rock materials encountered

at different depths of the borings and also contain a record of the ground water level, the SPT

blow counts, and the elevation of the top of the rock surface. The applicant used these data for

the liquefaction analyses, bearing capacity calculations, and settlement analyses. The

applicant stated that the soil and rock materials encountered in the ESP borings are similar to

those found in the previous sets of borings conducted at the NAPS site.

In RAI 2.5.4-1, the staff asked the applicant to provide its basis for concluding that the

subsurface conditions in the southeast portion of the ESP footprint (an area of about 500 ft by

1000 ft, in which there are no borings) do not materially differ from conditions in adjacent areas

where borings were made. In its response, the applicant stated that the North Anna site is

underlain by a consistent geologic profile, which extends to a depth of several thousand feet.

The 145 borings performed throughout the North Anna site (including 7 for the ESP) indicate a

consistent overall subsurface profile, with expected variations in the thickness of the various

strata. As such, the applicant concluded that the southeast portion of the ESP footprint (see

SER Figure 2.5.4-3) should be similar to the rest of the site.

In RAI 2.5.4-6, the staff asked the applicant to explain why it did not provide laboratory test

results from the borings of subsurface materials over various depth intervals. The applicant

responded that the containment (reactor) buildings for the new units would be founded on the

Zone III-IV and/or Zone IV metamorphic gneiss bedrock at the North Anna site. Rock coring

and testing performed by Virginia Power for Units 1 and 2 gave unconfined compressive

strengths for the Zone III-IV and IV rock ranging from 1,000 to 16,300 psi with a median

2-220

l l l 1
strength of 6,800 psi. The applicant stated that these rock strengths are typical for this type of

rock and more than sufficient to support the maximum containment (reactor) building loads of

about 100 psi. The applicant added that, during logging of the rock cores in the field for the

ESP investigation, it was apparent that the metamorphic rock is a strong material. The

applicant stated that it performed sufficient tests on the ESP cores to verify that the rock

strengths are similar to or higher than those cores tested for Units 1 and 2. The applicant

determined that the median value of the unconfined compressive strengths of the Zone lll-IV

and IV rock from the ESP investigation is 18,400 psi.

Observation Wells

The applicant screened eight OWs with depths ranging from about 25 to 50 ft in soil and/or

weathered rock. The applicant advanced boreholes for these wells with hollow stem augers.

The applicant obtained samples at 5-ft intervals to provide information on an appropriate depth

to set the slotted screen. The applicant screened the ninth well in rock. Each well was

developed by pumping. The applicant considered the well developed when'the pH and

conductivity stabilized and the pumped water was reasonably free of suspended sediment. The

applicant then performed permeability tests in each well in general accordance with'

ASTM D4044, Section 8, using the slug test method. Appendix Bto SSAR Section 2.5.4

contains the details of the boring logs for the OWs, the well installation records, the well

development records, and the well permeability test results. The boring logs of the OWs also

describe the soil and rock seen in these borings. The applicant stated that it would use the

ground water level data, as recorded in the OWs, in developing the dewatering program at the

time of construction.

Cone Penetrometer Tests

The applicant stated that it advanced each of the CPTs to refusal (i.e., no further penetration),

to depths ranging from 4 to 58 ft. The applicant stated that it performed the piezocone'tests in

general accordance with ASTM D5778. The pore pressure filter'was located immediately

behind the cone fip. The applicant performed pore pressure dissipation tests at a depth of 27 ftin CPT-823 and at a depth of 32.5 ft in CPT-827. Appendix B to SSAR Section 2.5.4 contains

the CPT logs, shear wave arrival times, and pore 'pressure versus time plots, while SSAR

Tables 2.5-38 and 2.5-39 summarize the CPT locations and depths.

2.5.4.1.4 Geophysical Surveys

Previous Geophvsical Survey Programs

The NAPS licensee performed several geophysical studies for the investigation for the existing

Units 1 and 2, including a seismic refraction' survey in 1968. The seismic (compressional wave)

velocities measured by Virginia Power in the relatively unweathered rock (Zone IV) range from

13,000 to 16,000 ft/s. Compressional wave velocities measured in weathered rock are around

5000 ft/s. Shear wave velocities in the Zone IV rock range from about 4000 to 8000 ft/s. The

corresponding compressional wave velocities are about 8,000 to 16,000 ft/s. Unit weights

range from'about 140 to 170 pcf. Weston Geophysical performed seismic crosshole tests

between the Unit 1 and 2 reactors and obtained shear wave velocities in the Zone IV rock

between 5000 and 6000 ft/s. The UFSAR for the existing units provides a shear wave velocity

for the saprolite (Zone IIA) of 950 ft/s.

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"ii

Geophysical Surveys for ESP

For the ESP site geophysical investigation, the applicant performed two crosshole seismic

tests, one downhole seismic test in a borehole, and two downhole seismic tests using a cone

penetrometer.

Crosshole Seismic Tests

The applicant performed crosshole seismic tests immediately adjacent to borings B-802 and

B-805. The applicant stated that it performed these tests in accordance with

ASTM D 4428/D 4428M. The applicant used the B-802 location to obtain readings in rock,

while it used the B-805 location to obtain readings in soil. The applicant performed tests in

boring B-802 at 5-ft intervals in the rock at depths ranging from 27 to 90 ft; however, it only

obtained shear wave velocity results at depths ranging from 27 to 45 ft. The applicant stated

that severe high-frequency noise appears to have degraded the results in general, but

particularly below a depth of 45 ft. The high-frequency noise obscured all of the compressional

wave forms. The shear wave velocities in the rock at depths between 27 and 45 ft range from

4500 to 6000 ft/s. The applicant performed tests in borings B-805A, B, and C at 2.5- to 5-ft

intervals in the soil from near the surface to a depth of 27 ft. The seismic waveforms were

reasonably clear, except for the bottom interval, close to the rock interface. The shear wave

velocities range from about 610 to 1380 ft/s, the compressional wave velocities range from

about 1240 to 6550 ft/s, and the computed dynamic Poisson's ratios range from 0.27 to 0.49.

Downhole Seismic Tests

Since the crosshole tests in borings B-802A, B, and C yielded no compressional wave results

and gave no shear wave velocity results below a depth of 45 ft, the applicant conducted

downhole seismic testing in boring B-802B. Appendix B to SSAR Section 2.5.4 contains a

detailed description of the results. The applicant stated that the shear wave was reasonably

well defined to a depth of 45 ft, less defined from a depth of 45 to 65 ft, and not defined below a

depth of 65 ft. Between 22.5 and 65 ft, shear wave velocities range from about 3400 ft/s to

6380 ftWs. Between 22.5 and 87 ft, compressional wave velocities range from about 10,000 ftWs

to 16,600 ft/s. The computed dynamic Poisson's ratios range from 0.38 to 0.45.

Downhole Seismic Tests with Cone Penetrometer

The applicant performed downhole seismic tests at 5-ft intervals in CPT-822 and CPT-825. It

recorded shear waves with a geophone attached near the bottom of the cone string.

Appendix B to SSAR Section 2.5.4 plots shear wave arrival times versus depth. In CPT-822,

the computed shear wave velocity between depths of 10 .and 22 ft was about 1275 ft/s. In

CPT-825, the computed shear wave velocity between depths of 6 and 30 ft was 1 175 ft/s. For

greater depths, between 30 and 45 ft, the computed shear wave velocity was about 1660 ft/s,

and between 45 and 52 ft, it was about 2438 ft/s.

In RAI 2.5.4-5, the staff asked the applicant to explain why SSAR Table 2.5-45 does not give

shear wave velocities for Zone IIB saprolite and Zone Ill and lIl-IV weathered rock. In its

response, the applicant stated that SSAR Table 2.5-45 gives average shear wave velocities for

Zones 11, III, and III-IV but does not provide a range of values. In contrast, it provides both

average values and a range of shear wave velocity values for Zones IIA and IV. According to

2-222
- -

the applicant, it originally provided only average values for Zones IIB, III, and III-IV because the

ESP borings did not sample these zones as abundantly as Zones IIA and IV. In response to

this RAI, the applicant provided its method for determining the average shear wave velocity

values forZones IIB (1600 ft/s), 1I1 (2000 ft/s), and IlI-IV (3300 fts). In addition, the applicant

used its laboratory measurements of the soiVrock properties for Zones IIB, Ill, and III-IV to

indirectly determine the shear wave velocities. Accordingly, the applicant updated SSAR

Table 2.5-45 to include the range in shear wave velocity for these three soil/rock zones.

2.5.4.1.5 Excavation and Backfill

SSAR Section 2.5.4.5 describes the extent of anticipated safety-related excavations, fills, and

slope; excavation methods and stability; backfill sources and quality control; and construction

dewatering impacts., The applicant stated that the construction of the proposed new units would

involve a substantial amount of excavation in both soil and rock. Filling would consist almost

entirely of backfilling around structures back up to plant grade. The only new permanent slope

that may be created would be to the west of the SWR to accommodate the buried UHSs, if

warranted by the selected design for the proposed additional units.: The applicant stated that

the top of the slope would be at least 200 ft from the top of the SWR embankment and,

therefore, would not impact the SWR. Next, the applicant described excavation methods that it

would use in soil and rock (i.e., blasting techniques and alternatives to blasting),- backfill

sources, and quality control. The applicant stated that structural fill would be either lean

concrete or a sound, well-graded granular material. In addition, it would establish an'onsite

soils testing laboratory to control the quality of the fill materials and the degree of compaction.

To control soil erosion, the applicant stated that it would line any sumps and ditches.'

constructed for dewatering and slope the tops of excavations back to prevent runoff 'down the

excavated slopes during heavy rainfall.

2.5.4.1.6 Ground Water Conditions

In SSAR Section 2.5.4.6, the applicant briefly described the ground water conditions at the ESP

site and general plans for construction dewatering. - Section 2.4.12 of the SSAR describes the

ground water conditions at the ESP site in detail. -The following summarizes the applicant's

description of the ESP site ground water conditions in SSAR Section 2.5.4.6.

Nine OWs installed at the site as'part of the ESP subsurface investigation program have

exhibited ground water levels ranging from MSL elevations of 241 to 311 ft between

December 2002 and June 2003. Based on the results of the slug tests in the wells, hydraulic I

conductivity values for the saprolite in which eight of the wells were screened range from 0.2

to 3.4 ft/day. The applicant estimated the hydraulic conductivity of the shallow bedrock in which

one of the wells was screened to be about 2 to 3 ft/day. Ground water movement at the site is

generally to the north and east, toward Lake Anna.

The applicant stated that ground water is present in unconfined conditions in both the surficial

sediments and underlying bedrock at the ESP site. The ground water generally occurs at- -

depths ranging from about 6 to 58 ft below the present-day ground surface. The'design ground

water level for the new units would range from 265 to 270 ft MSL in elevation. Section 2.4.12 of

the SSAR derives this level. :

2-223
- IIN

The applicant stated that it can achieve dewatering for all major excavations using gravity-type

systems. For soils, because of their relatively impermeable nature, sump-pumping of ditches

would be adequate to dewater the soil. For rock, the applicant would use sump-pumping to

collect water from relief drains that would be installed in the major rock excavation walls to

prevent hydrostatic pressure buildup behind the walls.

2.5.4.1.7 Response of Soil and Rock to Dynamic Loading

In SSAR Section 2.5.4.7, the applicant estimated the seismic ground motion

amplification/attenuation using the shear wave velocity profiles for the different subsurface

materials, the variation of shear modulus and damping with strain, and the site-specific

acceleration time histories. The applicant stated that the reactor containment buildings for the

proposed additional units would be founded on Zone lll-IV or Zone IV bedrock. However, other

safety-related structures may be founded on the Zone lIl weathered bedrock, the Zone IIB very

dense saprolitic sand, and/or the Zone IIA saprolitic sand.

Shear Wave Velocity Profile

The applicant made various measurements, summarized in SSAR Section 2.5.4.4, at the ESP

site to obtain estimates of the shear wave velocity in the soil and rock. The applicant

considered the Zone IV bedrock to be the base rock at a depth of 70 ft in the

amplification/attenuation analysis. Table 2.5-45 of the SSAR shows an average shear wave

velocity of 6300 ft/s for Zone IV. While in some locations the top of Zone III-IV or Zone IV

bedrock is found close to or even above the planned plant grade, sound bedrock is relatively

deep in other locations. The applicant stated that, in the case of relatively deep bedrock, some

safety-related structures (excluding the reactors) may be founded on the Zone lIl weathered

rock, Zone IIB saprolite, or Zone IIA saprolite. SSAR Figure 2.5-62, Profile (a), focuses on this

situation; it shows the shear wave velocity values measured in Zone IIA saprolite for the ESP

subsurface exploration program using crosshole and CPT downhole seismic testing. SSAR

Figure 2.5-62 (reproduced previously as SER Figure 2.5.2-5) also shows the shear wave

velocity of 950 ft/s given in the UFSAR of the existing units for the saprolite. The applicant took

this as the average design value for the Zone IIA saprolite for the ESP evaluation. The design

shear wave velocity versus depth profile shown in SSAR Figure 2.5-62, Profile (a), is anchored

about the design value of 950 ft/s for the Zone IIA saprolite but reflects the expected increasing

values with depth demonstrated in the crosshole and downhole seismic tests.

The applicant stated, as noted in SSAR Section 2.5.4.10.2, that it would improve any Zone IIA

saprolites supporting safety-related structures to reduce potential settlement. In RAI 2.5.4-7,

the staff asked the applicant to reconcile two conflicting statements in SSAR Sections 2.5.4.7.1

and 2.5.1.2.6. The applicant stated in SSAR Section 2.5.1.2.6 that Zone lIl (weathered rock) is

not a suitable material for safety-related plant structures. However, the applicant stated in- - SSAR Section 2.5.4.7.1 that some safety-related structures (excluding the reactor containment

building) may be founded on the Zone lIl weathered rock, Zone IIB saprolite, or improved

Zone IIA saprolite. In response to RAI 2.5.4-7, the applicant noted that the statement in SSAR

Section 2.5.4.7.1 is correct, and therefore it will delete the statement in SSAR Section 2.5.1.2.6.

The applicant emphasized that only improved Zone IIA saprolite is appropriate for certain

safety-related structures (see RAI 2.5.4-11 below). To compute the response of the improved

Zone IIA saprolite to dynamic loading, the applicant computed the shear wave velocity through

the improved soil based on this increase in stiffness. Profile (b) of SSAR Figure 2.5-62 shows

2-224
these computed shear wave velocities and the unimproved Zone I1A shear wave velocities.

This profile also shows the shear' wave velocity values interpreted in SSAR Appendix 2.5.4B

from the CPT-825 downhole seismic tests at a depth of 52 ft during the ESP subsurface

exploration program. The applicant interpreted the subsurface materials below a depth of 30 ft

in the CPT log as a silty sand and sandy silt mix. These could be either Zone 116 saprolitic

sands or Zone IlIl weathered rock (or both). From depths between 30 and 40 ft, the design

profile uses the shear wave velocity for the Zone IIB saprolite from SSAR Table 2.5-45

(1600 ftls), which is very close to the 1650 ft/s measured in the CPT-825 downhole seismic test.

From depths of 40 to 55 ft, the design profile uses the shear wave velocity for the Zone IlIl

weathered rock from SSAR Table 2.5-45 (2000 ft/s). This is close to the mean of the two

CPT-825 downhole seismic velocities measured in this zone, as shown in SSAR Figure 2.5-62,

Profile (b). The applicant assumed Zone III-IV to extend from depths of 55 to 70 ft. Shear

wave velocity for this rock is 3300 ft/s, derived from several values measured in the downhole

seismic test performed adjacent to boring B-802 and from elastic modulus values from

unconfined compression tests (SSAR Section 2.5.4.2.5).

Variation of Shear Modulus and Damping with Strain

Figure 2.5.4-5, reproduced from SSAR Figure 2.5-63, shows normalized shear modulus

reduction curves, which are taken from research reports referenced in SSAR Section 2.5.4.

Curve 1 in this figure represents the Zone IIA saprolite (both unimproved and improved). This

modulus reduction curve is the average of (1) the 1970 Seed and Idriss (Ref. 167, SSAR

Section 2.5) average curve for sand and (2) five curves (from a 1993 EPRI report (Ref.'170,

SSAR Section 2.5)) that take into account several factors, including reference strain and

effective vertical stress. One of the five EPRI curves is'a low-plasticity clay curve to account for

the cohesive component of the'Zone IIA saprolite. Curve 2 in SSAR Figure 2.5-63 represents

the Zone 111 saprolite and is.the modulus reduction curve recommended by Seed, et al.

(Ref. 168, SSAR Section, 2.5) for gravels, based on tests of four different gravels and crushed

stone samples. The Zone 118 saprolite contains the relict structure of the parent rock. Since

this contains up to 50 percent of core rock remaining in the saprolite, the applicant stated that it

would behave more like a gravel or crushed stone than a sand.

The applicant stated that solid rock does not exhibit the strain-softening characteristics of soil.

Thus, the Zone III-IV rock has no modulus reduction curve. However, at some stage of

weathering; rock becomes sufficiently decomposed to exhibit modulus reduction. The applicant

considered Zone IlIl moderately to severely weathered rock as falling into this sufficiently

weathered state. Curve 3 in SSAR Figure 2.5-63 was developed for mudstone (a soft rock)

with a shear wave velocity of 1500 ft/s (Ref. 169,-SSAR Section 2.5). -SSAR Section 2.5.4.7.1

shows that Zone IlIl has a shear wave velocity of 2000 ft/s. The applicant stated that when

mudstone Curve 3 is used for shear modulus input in the soil/rock column amplification/

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1.0

0.9

0.8

0.7

0.6

2

E

CD

0.5

a

a

* 4%a -_ __

4% 44

44 4% ______ 44 ______ ______ 4%

4% 44

44 -A- 0

-4%- 44 _______ _______

__ * _

- A44 ___ ___ 44 ___

--s- -A44 44

44

___ ___ 44 ___

4% 4%

a

_____ 4%. 4%

_ - - - - - -

() Zone IIA Saprolite (sand)

© Zone IIB Saprolite (gravel)

® Zone IlI Weathered Rock

0.4

0.3

0.2

0.1

0

10-4 1 -3 10-2

Cyclic Shear Strain, Percent

10-1 1

Figure 2.5.4-5 Variation of normalized shear modulus with cycle shear strain

2-226

-1 . -
attenuation analysis for the Zone IlIl weathered rock, the shear modulus attenuation is

significantly less than that exhibited by the sand and gravel curves.

In SSAR Section 2.5.4.7.1, the applicant stated the following:

When the specific locations of safety-related structures are determined, if

structures such as the diesel generator building and/or certain tanks are founded

on saprolite or weathered rock, samples of foundation soils from those locations

would be tested to determine location-specific shear modulus degradation

relationships.

Figure 2.5.4-6, reproduced from SSAR Figure 2.5-64, plots the variation of the equivalent

damping ratio of saprolite and weathered rock as a function of cyclic shear strain.

Curve I in SSAR Figure 2.5-64,represents the Zone IIA saprolite (both unimproved and

improved). The applicant stated that this damping ratio versus cyclic shear strain curve is the

average of (1) the Seed and Idriss (Ref. 167, SSAR Section 2.5) average curve for sand and

(2) seven curves from Reference 170 that take into account several factors including reference

strain and effective vertical stress. One of these seven curves is a low-plasticity clay curve to

account forthe cohesive component of the Zone IIA saprolite. Curve II in SSAR Figure 2.5-64

represents the Zone IIB saprolite. The applicant used the Seed et al. (Ref. 168, SSAR

Section 2.5) curve for gravels. Curve IlIl in SSAR Figure 2.5-64 represents the Zone-liI

weathered rock. The applicant stated that it derived this curve by comparing Curve 3 in SSAR

Figure 2.5-63 with Curves 1 and 2 in SSAR Figure 2.5-63 and applying the differences

proportionally to SSAR Figure 2.5-64. The applicant stated that the damping ratio of the

Zone III-IV rock does not vary with cyclic shear strain. However, since this rock has some

intrinsic damping properties, the applicant used a damping ratio'of 2 percent.

In RAI 2.5.4-8, the staff asked the applicant to provide its basis for the selected modulusi

reduction and damping ratio curves for Zones IIA, JIB, and ll. In its response, the applicant

stated that it used the 1993 EPRI report (Ref. 170, SSAR Section 2.5), where applicable, as the

basis for the shear modulus reduction and damping ratio curves.

In RAI 2.5.4-8(c), the staff asked the applicant to explain its use of a damping ratio of 2 percent

for the Zone III-IV rock. In its response, the applicant stated that the damping ratio for rock

varies from site to site depending on'the various factors, including the mineral composition of

the rock, the integrity and fissuring of the rock mass, and the level of shear deformation in the

rock formation. According to the applicant, damping ratios for rock are generally between 0.5

to 4.5 percent. The applicant selected 2 percent for the Zone III-IV rock based on engineering

judgment and past experience. To determine the sensitivity of the selected damping ratio, the

applicant reran its analysis using damping ratios of 0.5, 1.0, and 5.0 percent. The results show'

only a slight difference in the peak acceleration for the different damping ratios.

2-227
25

20

0 15

C: .'L

E

C

(i Zone IIA Saprolite (sand)

_ . _ ,. _ . _ . .

( Zone 118 Saprolite (gravel)

O Zone ull Weathered Rock

5

0

10 10-3 10-2 10-1

Cyclic Shear Strain, Percent

1

Figure 2.5.4-6 Variation of damping ratio with cyclic shear strain

2-228
Site-SDecific Acceleration-Time Histories

The applicant developed two single horizontal-component acceleration time histories, which are

compatible with the low- and high-frequency response spectra developed from the two

controlling earthquakes and PSHA hazard curves. The applicant used these two acceleration

time histories in the soil column amplification analysis described below.

In RAI 2.5.4-9(a), the staff asked the applicant to'describe its method for developing the sitespecific acceleration time histories.' In its response, the applicant stated that it selected two

horizontal-component acceleration time histories which it then matched to the low- and high- -

frequency response spectra from-the two controlling earthquakes. The applicant then used

these spectrum-compatible time histories for the site response analysis. In RAI 2.5.4-9(b), the

staff asked the applicant to further describe the method it used for the development of the soil

column amplification/attenuation analysis. In its response, the applicant stated that it used the

SHAKE2000 computer program to compute the'site dynamic responses for the four soil and

rock profiles described in SSAR Section 2.5;4.7.1. The applicant provided the input soil

parameters, the depth at which the hard rock ground motion was input (70 ft), and information

on the number of iterations to compute the strain-compatible modulus and damping values for

the SHAKE analysis. In RAls 2.5.4-9(c) and (d),-the staff asked the applicant to further

describe the four soil profiles and how the analysis accounted for the variability of the soil.

properties. In response to RAls 2.5.4-9(c) and (d), the applicant provided the soil properties for

each of the four profiles and described the values that were varied in the analysis. The - -

applicant stated that the shear wave velocity (Vs) and Gmay, which is derived from V9-have the

most impact on the amplification/attenuation analysis. The applicant showed response spectra

for different levels of Gma (67 to' 150 percent).- In RAI 2.5.4-9(e), the staff asked the applicant

to justify its use of the mean 1 O uniform hazard spectrum as the input rock motion. In

response to RAI 2.5.4-9(e), the applicant stated that it initially used a time history matched to

the mean 1 04 uniform hazard spectrum, however, it later revised this approach to use time

histories that match the low- and high-frequency response spectra calculated from the two

controlling earthquakes.

Soil Column Amplification/Attenuation Analysis

The applicant used the SHAKE2000 computer program to compute the site dynamic responses

for the soil and rock'profile6, described in SSAR Section 2.5.4.7.1. The analysis, performed in

the frequency domain, used the two acceleration time histories briefly described in the previous

section and in SSAR Section 2.5.2. The analysis used (1) the low-frequency controlling'

earthquake time history wvith 'a peak acceleration of 0.21 g and (2) the high-frequency controlling

earthquake time history peak witha acceleration 6f 0.43g. -

Table 2.5-46 of the SSAR shows the zero period acceleration (ZPA) results for the SHAKE2000

analysis for the four soil profiles, given in SSAR Section 2.5.4.7.1. 'The'ZPA results for soil

Profile 1, with 30 ft of unimproved Zone IIA saprolite, are 0.91 g for the high-frequency case and

0.46g for the low-frequency case. The applicant also determined the ZPA results for the four;-

soil prdf iles using a G value that was 150 percent of the average Gm,.value. Using these,;

higher Gina; values, the applicant obtained 'ZPA values of 0.99g and 0.57g for the high-and lowfrequency cases, respectively. As described in SSAR Section 2.5.4.8 and below, the applicant

applied these amplified accelerations in the liquefaction evaluation of soils. --

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2.5.4.1.8 Liquefaction Potential

Soil liquefaction is a process by which loose, saturated, granular deposits lose a significant portion of their shear strength because of pore pressure buildup resulting from cyclic loading, such as that caused by an earthquake. Soil liquefaction can occur, leading to foundation

bearing failures and excessive settlements, when (1) the ground acceleration is high, (2) soil is saturated (i.e., close to or below the water table), and (3) the site soils are sands or silty sands

in a loose or medium-dense condition. The applicant stated that the ESP site meets the first

criterion, and the second criterion applies in many areas of the NAPS site; however, the third

criterion, involving the type and density of the soil, is much less clearly applicable. According to

the applicant, the Zone IIB soils are extremely dense. The Zone lIl weathered rock has over

50 percent core stone and has typically been sampled by rock coring. As such, neither of these

materials meets the loose or medium-dense criterion, and neither has liquefaction potential. The applicant stated that any needed structural fill would be a well-compacted, well-graded crushed stone that is not liquefiable. Reasoning that neither the Zone IIB soils nor the Zone Ill

weathered rock are susceptible to liquefaction, the applicant only discussed the liquefaction

potential of the Zone IIA saprolitic soil.

The applicant stated that there is no historical evidence that Zone IIA saprolitic soils have

undergone liquefaction at the ESP site. Attachment 4 to Appendix 3E to the UFSAR indicates

that examination of the structure and fabric of the material "leads to the conclusion that the

saprolite is not susceptible to liquefaction." Despite its apparent low potential for liquefaction, the Zone IIA saprolite at the NAPS site has been the subject of several previous liquefaction analyses. SSAR Section 2.5.4.8.2 examines these analyses in view of the accelerations

assumed for the ESP. In addition, the applicant performed a liquefaction analysis, summarized

below, on potentially liquefiable samples obtained from the recent ESP exploration program.

Effect of Soil Structure and Fabric on Liquefaction Potential

SSAR Section 2.5.4.8 describes the soil structure and fabric of the saprolite. The applicant stated that the fabric of the saprolite is similar to that of its parent rock, a biotitic [mineral in

mica group] quartz gneiss. According to the applicant, there is a strong foliation in the saprolite and the fabric is strongly anisotropic. The applicant contrasted the highly foliated and

anisotropic fabric of the saprolite with that of an alluvial- or marine-deposited sand. The

applicant stated that sand shows no foliation and no interlocking of grains. In addition-, a thin

section of sand shows a well-developed void network unlike that of saprolite. The applicant concluded by stating that the geometric interlocking of the grains and the lack of a void network

indicates that the saprolite could not liquefy. Despite this conclusion, the applicant analyzed the

potential of the saprolite to liquefy under both the high-frequency and low-frequency input

bedrock motions.

Acceptable Factor of Safety Against Liquefaction

According to RG 1.198 (Ref. 172, SSAR Section 2.5), a factor of safety (FS) of 1.1 against liquefaction is considered low, FSs of 1.1 to 1.4 are considered moderate, and an FS of 1.4 is

considered high. The Committee on Earthquake Engineering (Ref. 173, SSAR Section 2.5) states that there is no general agreement on the appropriate margin (factor) of safety. If the

design earthquake ground motion is regarded as reasonable, an FS of 1.33 to 1.35 is

suggested as adequate. However, when the design ground motion is excessively conservative,

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the Committee notes that engineers are content with an FS only slightly in excess of unity. The

SSE at rock for the existing NAPS units has a maximum acceleration of 0.12g, amplified to -

0.18g in the soil. The seismic margin maximum acceleration in soil (Ref. 174, SSAR

Section 2.5) is 0.30g. The maximum ESP acceleration at hard bedrock rock is 0.39g, amplified

at the unimproved soil surface to 0.99g (SSAR Table 2.5-46). :Based on these results, which

the applicant determined to be very conservative, the applicant considers an FS'of 1.1 to be

adequate for the Zone IIA soils at the ESP site.

Previous Liquefaction'Analyses

Virginia Power performed a detailed liquefaction analysis at the NAPS site in December 1994

for a seismic margin assessment (Ref. 174, SSAR Section 2.5). For the analysis, '

Virginia Power used a maximum acceleration of 0.3g, a magnitude of 6.8;and three different

approaches to assess the potential for soil liquefaction. For the first approach, Virginia Power.

used the Seed and Idriss simplified procedure (Ref. 175, SSAR Section 2.5), with 'some

modifications to account for the age of the saprolites and for the: overconsolidated nature of the

saprolites. The resulting FSs range from 1.54 to 3.51. For the second approach, Virginia

Power used a threshold strain analysis (Ref. 177, SSAR Section 2.5), with an average shear

wave velocity in the saprolite of 950 ft/s, resulting in an FS just under 3:0. For the third

approach, Virginia Power used the results of the 15 stress-controlled cyclic triaxial tests,

described in SSAR Section 2.5.4.2.4. The FSs against liquefaction range from 1.51 to 1.99 for

the SWR facilities (pump house, valve house, tie-in vault, and service water lines). Analysis of

the SWR embankment gave FS values ranging from 0.91 to 3.61, with an average of more than

1.5. The applicant stated that the few values below 1 occurred in localized zones and

concluded that overall FSs across the embankment are well within acceptable limits. A

consistent pattern of low FSs across the foundation would indicate that significant movements

of the embankments would occur.

Liquefaction Analyses Performed for ESP

Based on the deaggregation' of the PSHA in SSAR Section 2.5.2, the applicant used two

earthquakes in the liquefaction analysis. The low-frequency earthquake has a magnitude of 7.2

and a bedrock acceleration of 0.21g. The high-frequency earthquake has a magnitude of 5.4

and a bedrock acceleration of 0.43g. SSAR Table 2.5-46 shows the ZPA'values for'the four

soiVrock profiles described in SSAR S6ctiori 2.5.4.7.1. Since the'Zone IIB saprolite and the

Zone IlIl weathered rock are not liquefiabl6, the liquefaction analysis did not consider Profiles 2

and 3 in SSAR Table 2.5-46. In Profile 4, the Zone IIA saprolite is improved (i.e., this would be

the profile for any safety-related stru6tures founded on the Zone IIA saprolite). The applicant

stated that the-soil w tild be improved sufficiently to ensure that the improved soil has an FS

greater than or equal to 1.1 using the SSE ground motion.' In Profile 1, the Zone'IIA saprolite

(upper 30 ft) is not improved. Thus, the applicant considered only Profile 1 for the liquefaction

analysis. As noted above, the'applicant used PGA values of 0.57g and 0.99g for the'

liquefaction analyses, which are described below.

The applicant performed a liquefaction analysis of each sample of Zone IIA saprolite, obtained

by SPT sampling during the ESP subsurface investigation, to determine the FS against

liquefaction. The applicant also analyzed the CPT results following the method proposed by

Youd, et al. (Ref. 178, SSAR Section,2.5). The applicant stated that, using-PGA values of

0.57g and 0.99g, the analysis of the'SPT results gave FS values against liquefaction of greater

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than 1.1, except in one case. The applicant's analysis of the CPT results shows 5-foot thick

zones in two CPTs and a 22-foot thick zone in another CPT, where the FS values against

liquefaction are less than 1.1, implying that these soil zones would liquefy.

The applicant also performed a liquefaction analysis using shear wave velocity criteria

incorporating the design values of shear wave velocity shown in SSAR Figure 2.5-62 and

tabulated in SSAR Table 2.5-46. To correct the shear wave velocity values for overburden

pressure, the applicant used the method outlined in Youd, et al. (Ref. 178, SSAR Section 2.5).

The resulting values all fell into the no-liquefaction zone in Figure 9 of Reference 178.

However, when the applicant used the lower bound values of the shear wave velocity, shown in

SSAR Table 2.5-45, in the liquefaction analysis, most of the top 20 ft of Profile 1 fell into the

liquefaction zone as shown in Figure 9 of Reference 178.

The applicant also determined the liquefaction-induced dynamic settlement using the method

outlined in Tokimatsu and Seed (Ref. 179, SSAR Section 2.5). The maximum estimated

dynamic settlement of the Zone IIA saprolite caused by earthquake shaking is about 5 in.

The applicant concluded the following concerning the liquefaction potential of the soils at the

ESP site:

* Only the Zone IIA saprolites fall into the gradation and relative density categories where

liquefaction would be considered possible.

* The structure, fabric, and mineralogy of these saprolites lower the potential for

liquefaction very substantially.

* For a conventional liquefaction analysis, an FS of 1.1 is adequate, based on the

conservative estimate of the ESP design seismic acceleration.

* A liquefaction analysis of the ESP SPT samples using the low- and high-frequency ESP

seismic parameters gave FS values greater than 1.1 for all except one SPT result.

* A liquefaction analysis of the ESP CPT measurements using the low- and highfrequency ESP seismic parameters indicated an approximately 22-ft-thick zone and two

5-ft-thick zones where the FS against liquefaction was less than 1.1.

* A liquefaction analysis of the shear wave velocity profile indicated no liquefaction when

the average shear wave velocity values were used. Using lower shear wave velocity

values resulted in liquefaction of most of the top 20 ft.

* Estimated dynamic settlements caused by earthquake shaking are about 5 in.

Based on the above analysis, the applicant concluded that some of the Zone IIA saprolitic soils

have a potential for liquefaction based on the low- and high-frequency ESP seismic parameters.

The applicant stated that the liquefaction analysis did not take into account the beneficial

effects of the fabric of the saprolitic soil. The applicant concluded by stating that, if safetyrelated structures are founded on the Zone IIA saprolitic soils, these soils would be improved to

reduce potential settlements and to ensure that the FS against liquefaction is equal to or

greater than 1.1.

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In RAI 2.5.4-10, the staff asked the applicant to describe how it varied the significant soil

properties and seismic input values for each of the different liquefaction analyses. In addition,

the'staff asked the applicant to provide a sample liquefaction analysis. In its response, the

applicant stated that it based its liquefaction analyses on the work of Youd et al. (Ref. 178,

SSAR Section 2.5). For each of the three different analyses, the applicant varied Gmax, the

peak earthquake acceleration, and the earthquake magnitude.

2.5.4.1.9 Earthquake Design Basis

SSAR Section 2.5.4.9 refers to SSAR Section 2.5.2.6, which derives and discusses the SSE for

the ESP site in detail. Section 2.5.2 of this SER contains the staff's review of that information.

2.5.4.1.10 Static Stability

SSAR Section 2.5.4.10 describes the allowable bearing capacities for each subsurface zone as

well as the estimated settlement for each zone. The applicant stated that reactor containment-.

buildings at the ESP site would be founded on Zone III-IV or Zone IV bedrock. Depending on

the location of these buildings, the top of this bedrock could occur below the level of the

shallower reactor designs. In such cases, the applicant stated that it would excavate to sound

bedrock and pour lean concrete up to the bottom of the reactor foundation. In some locations,

the top of Zone III-IV or Zone IV bedrock is found close to or even above the planned plant

grade. In such cases, safety-related structures would be founded on bedrock or on a thin layer,

of lean concrete orcompacted structural fill on the bedrock. In other locations, sound bedrock

is relatively deep. In this case, the applicant stated that safety-related structures (excluding the

reactors) may be founded on the Zone Ill weathered rock, Zone IIB saprolite, or Zone IIA

saprolite. The following sections on bearing capacity and settlement focus on this latter

situation. '(As noted in SSAR Section 2.5.4.10.2, the applicant stated that it would improve any

Zone IIA saprolites supporting safety-related structures to reduce potential settlement.) -

Bearing Capacitv

Table 2.5-47 in the SSAR gives the allowable bearing capacity values for each zone. The

applicant stated that it based the Zone IIA allowable bearing capacity value of 4 ksf (4000 lb/ft2)

on Terzaghi's bearing capacity equations modified by Vesic (Ref. 180, SSAR Section 2.5).

According to the applicant, the analysis considers the effective strength parameters for the

coarse-grained material and both the undrained and effective strength parameters for the finegrained material given in SSAR Table 2.5-45. As discussed in SSAR Section 2.5.4.10.2,

settlement considerations usually dominate when this material is used for supporting

-A

1

capacity exceeds the maximum bearing pressures of many of the reactor designs considered in

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the application, the containment (reactor) buildings would not be founded on the Zone lIl

weathered rock. The bedrock in Zones III-IV and IV has an unconfined compressive strength of

4 ksi (576 ksf) and 12 ksi (1728 ksf), respectively (SSAR Table 2.5-45). The applicant stated

that allowable bearing capacities of these materials are much higher than any applied structure

bearing pressure. In addition, the applicant stated that, if excavation during construction

reveals any weathered or fractured zones at the foundation level, it would excavate such zones

and replace them with lean concrete. The allowable values of the bearing capacity of 80 and

160 ksf for Zone III-IV and IV rock, shown in SSAR Table 2-5.47, are presumptive values based

on various building codes for moderately weathered to fresh foliated rock.

In RAI 2.5.4-11, the staff asked the applicant to provide further details concerning its calculation

of the bearing capacities of. the soil and rock underlying the ESP site. In its response, the

applicant provided a sample calculation for the staff to review. In addition, the applicant stated

that the maximum bearing pressure from the containment building foundation is 15 ksf, which is

only a fraction of the allowable bearing capacity of the bedrock (Zone III-IV is 80 ksf and

Zone IV is 160 ksf).

Settlement Analysis

Peck et al. (Ref. 182, SSAR Section 2.5) indicates that total settlement should be limited to

2 in., and differential settlement to 0.75 in., for the large mat foundations that support major

power plant structures. According to Peck, for footings that support smaller plant components,

the total settlement should be limited to 1 in. and the differential settlement to 0.5 in.

Settlement of Materials in Zones 11,1, III, III-IV, and IV

The applicant stated that the settlement of the materials in Zones IIB, Ill, III-IV, and IV is

essentially elastic. The applicant analyzed a large foundation with an assumed size of 150 ft by

300 ft (e.g., a turbine building foundation) for settlement assuming a soil profile of 20 ft for

Zone 118, underlain by 30 ft of Zone III, 50 ft of Zone III-IV, and 400 ft of Zone IV. The applicant

used the high-strain elastic modulus values given in SSAR Table 2.5-45 as the stiffness values.

The applicant found that the foundation has an average bearing pressure of 6 ksf. The

computed total settlement of this structure is less than 0.5 in.

Settlement of Zone IIA

The applicant stated that Virginia Power recorded larger settlements than expected (i.e., 4.6 in.)

beneath the SWR pump house of the existing units because of the weight of the pump house

and the 30 ft of embankment fill that was built up around it. This settlement occurred over a

30-month period. The in-situ soil that settled beneath the pump house consists of about 65 ft of

Zone IIA, mainly micaceous sandy silt. The applicant stated that the primary cause of this fairly

large settlement appears to be the 5 to 20 percent mica content of these saprolites, along with

a significant portion of low-plasticity clay minerals. The applicant concluded that, although the

settlement of the SWR pump house is an extreme case and resulted from several factors, the

potential for excessive settlement of the Zone IIA saprolite makes this material unsuitable to

support any safety-related structure without ground improvement.

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2.5.4.1.11 "Design Criteria - ';

SSAR Section 2.5.4.11 summarizes the geotechnical design criteria. In addition, various

sections of the SSAR cover other applicable design criteria. SSAR Section 2.5.4.8 specifies

that the acceptable FS against liquefaction of site soils should be 1.1. SSAR Section 2.5.4.10

presents bearing capacity and settlement criteria. SSAR Table 2.5-47 provides allowable

bearing capacity values for the site subsurface materials. Generally acceptable total and

differential settlements are-limited to 2 in. and 0.75 in., respectively, for mat foundations and

1 in. and 0.5 in., respectively, for footings. SSAR Section 2.5.5.2 specifies that the minimum'

acceptable long-term static FS against slope stability failure is 1.5. SSAR Section 2.5.5.3 -. '

specifies that the minimum acceptable long-term seismic FS against slope stability failure is 1.'1.

In RAI 2.5.4-12, the staff asked the applicant to explain why it did not provide design criteria

pertaining to structural design. In its response, the applicant stated that structural criteria such

as allowable wall rotation and FSs against structure sliding and overturning are not site specific

and thus are not included in SSAR Section 2.5: The applicant stated that a COL application

would describe these structural criteria.

2.5.4.1.12 Techniques to Improve Subsurface Conditions

SSAR Section 2.5.4.12 outlines several ground improvement techniques that would be

implemented before the Zone IIA saprolitic soils could be used to support safety-related

foundations. As its primary choice for reducing the settlement potential of the Zone IIA

saprolitic soils, the applicant considered vibro-stone columns. According to the applicant, vibrostone columns have several advantages, including reduction of settlement, improvement'of

bearing capacity, and reduction of liquefaction potential. The vibro-stone column method

involves the insertion of a vibratory probe (aided by water jets or compressed air) into the base

of the stratum that needs improvement. Crushed stone is poured into the annulus and is

densified by the vibrator. This process results in a series of highly compacted stone columns,

typically about 3 ft in diameter, spaced on about 5- to 8-ft centers.

2.5.4.2 Regulatory Evaluation

SSAR Section 2.5.4 describes the applicant's evaluation of the stability of the subsurface

materials and foundations at the ESP site. In SSAR Section 1.8, the applicant stated that it

developed the'geological, geophysical, and geotechnical information used to evaluate the

stability of the subsurface materials in accordance with the requirements of 10 CFR 100.23.

The applicant applied the guidance of RS-002, RG 1.70, DG-1 105 (which has been superseded

by RG 1.198 since the applicant submitted the SSAR), RG 1.132; and RG 1.138, 'Laboratory

Investigations of Soils for Engineering Analysis and Design of Nuclear Power Plants."

In its review of SSAR Section 2.5.4, the staff considered the regulatory requirements in 10 CFR

100.23(c) and 10 CFR 100.23(d)(4). According to 10 CFR 100.23(c), applicants must

investigate the engineering characteristics of a site and its environs in sufficient scope and - -

detail to permit an adequate evaluation of the proposed site. Pursuant to 10 CFR 100.23(d)(4),

applicants must evaluate siting factors such as soil and rock stability, liquefaction potential, and

natural and artificial slope stability. Section 2.5.4 of RS-002 provides specific guidance

concerning the evaluation of information characterizing the stability of subsurface materials,

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including the need for geotechnical field and laboratory tests as well as the geophysical

investigations.

2.5.4.3 Technical Evaluation

This section provides the staff's evaluation of the geophysical and geotechnical investigations

carried out by the applicant to determine the static and dynamic engineering properties of the

materials that underlie the ESP site. The technical information presented in SSAR

Section 2.5.4 resulted from the applicant's field and laboratory investigations performed for the

ESP. The applicant intended its additional field and laboratory investigations to confirm the

large volume of geotechnical data developed by Virginia Power for the existing units and the

abandoned Units 3 and 4 within the ESP site area. The applicant used the subsurface material

properties from its field and laboratory investigations to evaluate the liquefaction potential,

bearing capacity, and potential for settlement.

Through its review of SSAR Section 2.5.4, the staff determined whether the applicant

demonstrated the stability of the subsurface materials under both static and dynamic conditions.

The staff also reviewed the applicant's field and laboratory investigations used to determine the

geotechnical properties of the soil and rock underlying the ESP site. In addition, the staff

observed some of the applicant's onsite borings and field explorations, performed in November

and December 2002, to determine whether the applicant followed the guidance in RG 1.132.

2.5.4.3.1 Geologic Features

SSAR Section 2.5.4.1 references SSAR Sections 2.5.1.1 and 2.5.1.2 for a description of the

regional and site geology. Section 2.5.1.3 of this SER presents the staff's evaluation of these

two sections.

2.5.4.3.2 Properties of Subsurface Materials

The staff focused its review of SSAR Sections 2.5.4.2 and 2.5.4.3 on the applicant's description

of (1) subsurface materials, (2) field investigations, (3) laboratory testing, and (4) static and

dynamic engineering properties of the ESP site subsurface materials.

Normally, an applicant performs a complete field investigation and sampling program to

evaluate the engineering properties and stability of the soil and rock underlying the site.

However, since the applicant relied on Virginia Power's previous field and laboratory

investigations for the existing and abandoned units, it used its ESP investigations to confirm

previously established soil and rock properties. In RAI 2.5.4-1, the staff asked the applicant to

provide its basis for concluding that the subsurface conditions in the southeast portion of the

ESP footprint (an area of about 500 ft by 1000 ft, in which there are no borings) do not

materially differ from conditions in adjacent areas, where borings were made. In response to

RAI 2.5.4-1, the applicant stated that the North Anna site is underlain by a consistent geologic

profile, which extends to a depth of several thousand feet. The applicant stated that the

145 borings performed throughout the North Anna site (including 7 borings for the ESP)

indicate a consistent overall subsurface profile, with expected variations in the thickness of the

various strata. As such, the applicant concluded that the southeast portion of the ESP footprint

(see SER Figure 2.5.4-3) should be similar to the rest of the site. Because of the consistency

of the soil and rock engineering properties across the NAPS and ESP sites, the staff has

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determined that Virginia Power's pjast investigations, combined with the ESP applicant's

explorations, are adequate to characterize-the subsurface conditions in the locations where

data were collected. Further, based on its review of the NAPS 'and ESP borings, the staff has

determined that a consistent geologic profile underlies the North Anna ESP site. The staff

concludes, therefore,'that the uncharacterized southeast portion of the site should have

subsurface conditions similar to those found at the rest of the site. Accordingly, the staff

concludes that the applicant has provided an adequate description of the subsurface profile.

The applicant's commitment to perform additional borings to confirm its conclusions regarding

engineering properties and the stability of soil and rock underlying future plant SSCs is COL

Action Item 2.5-1.

In RAI 2.5.4-3, the staff asked the applicant to describe how it integrated Virginia Power's site

investigations for the'SWR and the ISFSi with its field investigations for the ESP site.-. In its

response, the applicant stated that the SWR and ISFSI borings are as close to the' ESP area as

any other borings and disclose the same subsurface profile displayed by the other borings at

the North Anna site (see SER Figure 2.5.4-3). In addition, the applicant stated that it used

some of the SWR and ISFSI borings, which are close to the southeast corner of the ESP

footprint,,noted in RAI 2.5.4-1, to help characterize the ESP area;' Because of the consistency

of the soil and rock engineering properties across the NAPS and ESP sites, the staff has

determined that Virginia Power's past investigations, combined with' the ESP applicant's

explorations, are adequate to characterize the subsurface conditions in the locations where

data were collected. ' '

In RAI 2.5.4-4, the staff asked the applicant to explain how the total thickness of the soil layers

sampled at the ESP site (105 ft) is sufficient to characterize the soil properties underlying the

site. In its response, the applicant stated that'the 138 borings performed previously by

Virginia Power for Units 1 and 2 as well as'abandoned Units 3 and 4 characterize the soils at

the North Anna site very well. The applicant stated that the soils in all the borings show the

same general subsurface profile and that it used the ESP borings to show that'the soil (and.

rock) profiles-in each of the borings fit within'the general subsurface profile. Based on the

results of the NAPS and ESP borings, the staff has determined that a consistent geologic - -

profile underlies the North Anna ESP site. The staff concludes, thereforelhat the applicant

adequately sampled the soil underlying the ESP site inr order to confirm the results of borings

previously performed by Virginia Power. ! '

In RAI 2.5.4-2(a), the staff asked the applicant to describe the extent of severely weathered

fracture zones in the Zone IlI-IV and IV rock that Virginia Power observed during the site

investigation for abandoned Units 3 and 4.' The applicant observ6d similarly fractured rock in

four of the'seven ESP borings. In its response, the applicant provided a table that shows an

RQD of less than 25 percent in nine of the borings for abandoned Units 3 and 4. The applicant

noted that most of the rock for the low RQD intervals' (less than 10 percent) is' only 1 to 2 ft

thick. In RAI 2.5.4-2(b), the staff asked the applicant to'describe the impact of these fractured

rock zones on the suitability of the site to host safety-related structures. In its response, the

applicant stated the following: '

As noted in these SSAR sections, any weathered or fractured zones

encountered at foundation level would b'e excavated and replaced with lean

concrete. If such zones exist below sound rock beneath the foundation, they

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would have no impact on the stability of the foundation, since these zones are typically only 0.5 to 1-foot thick, and are confined within an unfractured rock

mass with strengths of 4,000 to 12,000 psi (compared to the maximum foundation pressure of just over 100 psi). The foundation itself would consist of

a large, thick, highly-reinforced concrete mat that is so stiff that it cannot logically

yield.

Multiple borings would be performed at each structure location once the building locations are chosen as part of detailed engineering. These borings would

identify whether there are any thicker fracture zones beneath the foundation than those encountered in the ESP borings and in the abandoned Units 3 and 4 borings. If any thicker zones are found, analysis would be performed to identify their impact on foundation stability. If they are close enough to the foundation to potentially impact stability, they would be excavated and replaced with lean

concrete.

In its response to RAI 2.5.4-2, the applicant stated its commitment to excavate and replace with lean concrete any weathered or fractured zones found at the foundation level, and the staff

proposes to include a condition in the ESP to require such activities (Permit Condition 2.5-1). The replacement of fractured rock with lean concrete is well understood and commonly done to enhance the strength and stability of the rock to support building loads. The excavation of weathered or fractured rock zones and their replacement with lean concrete will ensure the bearing capacity of such zones. The staff concludes that this is adequate to ensure the stability of structures that might be constructed on the proposed site.

In RAI 2.5.4-6, the staff asked the applicant to explain why it did not provide laboratory test results from the borings of subsurface materials over various depth intervals. In response to RAI 2.5.4-6, the applicant stated that the containment (reactor) buildings for the new units would be founded on the Zone III-IV and/or Zone IV metamorphic gneiss bedrock at the North Anna site. Rock coring and testing performed by Virginia Power for Units 1 and 2 gave unconfined compressive strengths for the Zone III-IV and IV rock ranging from 1,000 to 16,300 psi, with a median strength of 6,800 psi. The applicant stated that these rock strengths are typical for this type of rock and more than sufficient to support the maximum containment (reactor) building loads of about 100 psi. The applicant added that, during logging of the rock

cores in the field for the ESP investigation, it was apparent that the metamorphic rock is a strong material. The applicant performed tests on the ESP cores sufficient to verify that the rock strengths are similar to or higher than those cores tested for Units 1 and 2. The applicant determined that the median value of the unconfined compressive strengths of the Zone III-IV and IVrock room the ESP investigation 18,400 is psi. Because the applicant verified through rock coring and testing during its ESP investigation that the unconfined compressive strength of the Zone III-IV and IV rock is similar to or higher that the cores tested for Units 1 and 2, the staff concludes that the applicant has adequately sampled the Zone III-IV and IV rock.

Furthermore, the staff concurs with the applicant's conclusion that the strength of the Zone III-IV and IV rock is sufficient to support the load of a containment building.

Based on its review of SSAR Sections 2.5.4.2 and 2.5.4.3 and the applicant's responses to its RARs, as described above, the staff concludes that the applicant adequately determined the engineering properties of the soil and rock underlying the ESP site through its field and

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'laboratory investigations. In addition, the applicant used the latest field and laboratory -

methods, in accordance with RGs 1.132 and 1.138, to determine these properties. Accordingly,

the staff concludes that the applicant performed field investigation and laboratory testing

sufficient to determine the overall subsurface profile as well as the material properties

underlying the ESP site. The staff notes that the applicant committed to perform additional -

investigations once it has selected the building locations. The COL (or CP) applicant would

describe these additional investigations in its COL (or CP) application.

2.5.4.3.3 Relationship of Foundations and Underlying Materials

Section 2.5.4.3 in RS-002 directs the staff to compare the applicant's plot plans and the profiles

of all seismic Category I facilities with the subsurface profile and material properties. Based on

this comparison, the staff can determine if (1) the applicant performed sufficient exploration of

the subsurface and (2) the applicant's foundation design assumptions contain adequate

margins of safety. The applicant decided to defer providing this information until a CP or COL

application is submitted. Submission of a COL or CP applicant's plot plans and the profiles ofall seismic Category I facilities for comparison with the subsurface profile and material

properties is COL Action Item 2.5-2.

2.5.4.3.4 Geophysical Surveys

The staff focused its review of SSAR Section 2.5.4.3 on the adequacy of the applicant's

geophysical investigations to determine soil and rock dynamic properties. The applicant

performed two crosshole seismic tests, one downhole seismic test, and two CPT seismic tests.

The applicant compared the dynamic properties it obtained from these tests with the resultsfrom the previous geophysical surveys of the North Anna site performed by Virginia Power.

In RAI 2.5.4-5, the staff asked the applicant to explain why SSAR Table 2.5-45 does not provide

shear wave velocities for Zone IIB saprolite and Zone III and III-IV weathered rock. In its -

response, the applicant stated that SSAR Table 2.5-45 gives average shear wave velocities for

Zones IIB, III, and III-IV but does not provide a range of values. In contrast, it gives both

average values and a range of shear wave velocity values for Zones IIA and IV. The applicant

stated that it provided only average values for Zones 11B, Ill, and Ill-IV because the ESP borings

did not sample these zones as abundantly as Zones IIA and IV. In response to this RAI, the -

applicant also provided its method for determining the average shear wave velocity values for

Zones IIB (1600 ft/s), IlIl (2000 ft/s), and Ill-IV (3300 ft/s). Because the applicant used both

crosshole and downhole seismic tests, as well as direct and indirect methods, the staff

concludes that the applicant has adequately measured the shear wave velocity for each of the

soil and rock zones. For those zones (IIB, II, and Ill-IV) for which the applicant did not obtain-'

so many samples from the ESP borings, the applicant used its laboratory measurements of the

soil/rock properties to indirectly determine the shear wave velocities. Accordingly, the staff

concludes that the applicant adequately sampled the soil and rock underlying the ESP site in

order to determine the consistency of its dynamic properties with those previously obtained by

Virginia Power in earlier explorations. -

The staff has determined that the applicant used the latest geophysical and geotechnical

measurement methods and equipment in accordance with the recommendations of RGs 1.132

and 1.138 to determine the dynamic properties of the soil and rock underlying the site. Based

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on its review of SSAR Section 2.5.4.4 and the applicant's response to the RAI, described

above, the staff concludes that the applicant adequately determined the soil and rock dynamic

properties through its geophysical survey of the ESP site.

2.5.4.3.5 Excavation and Backfill

In SSAR Section 2.5.4.5, the applicant provided a general description of (1) the extent.

(horizontally and vertically) of anticipated safety-related excavations, fills, and slopes,

(2) excavation methods and stability, (3) backfill sources and quality control, and (4) control of

ground water during excavation. The staff found this general description to be useful.

However, the applicant has not selected a reactor design or location within the ESP site, and it

did not provide detailed excavation and backfill plans or plot plans and profiles as outlined in

Section 2.5.4 of RS-002. Therefore, the staff could not adequately evaluate the applicant's

excavation and backfill plans and will await the future submittal of these plans by the ESP

holder and/or as part of a COL or CP application. This is COIL Action Item 2.5-3. The staff

notes that, in SSAR Section 2.5.4.5, the applicant stated that it would (1) geologically map

future excavations for safety-related structures and (2) evaluate'any unforseen geologic

features that are encountered. In addition, the applicant stated that it would-notify the NRC

"when any excavations for safety-related striictures are open for their examination and

evaluation." The staff proposes to include a condition in any ESP that might be issued requiring

that the ESP holder and/or an applicant referencing such an ESP perform geologic mapping of

future excavations for safety-related structures, evaluate any unforseen geologic features that

are encountered, and notify the NRC no later than 30 days before any excavations for safetyrelated structures are open for NRC's examinations and evaluation. This is Permit

Condition 7.

2.5.4.3.6 Ground Water Conditions

In SSAR Section 2.5.4.6, the applicant provided a general description of (1) ground water~

measurements and elevations and (2) construction dewatering plans. The staff found this

general description to be useful. However, the applicant has not selected a reactor design or

location within the ESP site and did not provide an evaluation of ground water conditions as

the' affect foundation-stabilitj'or detailed dewate'ring plans as outlined in Section 2.5.4 of

RS-002. Therefore, the staff could not evaluate the ground water conditions as they affect the

loading and stability of foundation materials or the applicant's dewatering plans during

construction, as well ais'ground water control throughout the life of the plant. As such, the staff

will await the future submittal of these -evaluations and plans as part of the COL or OP

application. The need to evaluate ground water conditions as they affect foundation stability or

detailed dewatering plans is COL Action Item 2.5-4.

2.5.4.3.7 Response of Soil and Rock to Dynamic Loading

In its review of SSAR Section 2.5.4.7, the staff focused on the applicant's shear wave velocity

design profiles to determine the response of the'soil and rock underlying the ESP site to

dynamic loading. In addition, the staff reviewed the applicant's modeling of the variation of soil

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shear modulus and damping with cyclic shear strain. Finally, the staff reviewed the applicant's

site dynamic resporise, which was based on a soil amplificatio6/aftenuation analysis using the

four soil profiles.

In RAI 2.5.4-7, the staff asked the applicant to reconcile two conflicting statements in SSAR

Sections 2.5.4.7.1 and 2.5.1.2.6. The applicant stated in SSAR Section 2.5.1.2.6 that Zone IlIl

(weathered rock) is not a suitable material for safety-related plant structures. However, the

applicant stated in SSAR Section 2.5.4.7.1 that some safety-related structures (excluding the

reactor containment building) may be founded on the Zone Ill weathered rock, Zone IIB-'

saprolite, or improved Zone IIA saprolite. In response to RAI 2.5.4-7, the applicant stated that

the statement in SSAR Section 2.5.4.7.1 is correct and that it will delete the statement in SSAR

Section 2.5.1.2.6. The applicant emphasized that only improved Zone IIA saprolite is

appropriate for certain safety-related structures only if it is improved (see RAI 2.5.4-11 below).

Based on the applicant's clarification in its response to RAI 2.5.4-7, the staff concludes that it is

appropriate to'consider the construction of safety-related structures on improved Zone IIA, and

Zone IIB, and Zone IlIl materials.

In RAI 2.5.4-8, the staff asked the applicant to provide its basis for the selected modulus

reduction and damping ratio curves for Zones IIA, IIB, and IlIl materials. In response to

RAI 2.5.4-8, the applicant stated that it used the 1993 EPRI report (Ref.-170, SSAR

Section 2.5.2), where applicable, as the basis for the shear modulus reduction and damping*

ratio curves. The staff reviewed the curves that the applicant selected for each of the soil and

rock zones to determine whether the applicant based its selection on appropriate criteria, such

as grain size, cohesiveness, confining pressure, and shear wave velocity. The staff concludes

that the shear modulus and damping curves selected by the applicant were based on

appropriate criteria and are suitable for Zone IIA, IIB, and IlIl soil and rock.

In RAI 2.5.4-8(c), the staff asked the applicant to explain its use of a damping ratio of 2 percent

for the Zone III-IV rock. In response to RAI 2.5.4-8(c), the applicant stated that the damping

ratio for rock varies from site to site depending on various factors, including the mineral'

composition of the rock, the integrity and fissuring of the rock mass, and the level of shear

deformation in the rock formation. According to the applicant, damping ratios for rock are

generally between 0.5 to 4.5 percent. The applicant selected 2 percent for the Zone III-IV rock

based on engineering judgment and past experience. To determine the sensitivity of the

selected damping ratio, the 'applicant reran its analysis-using damping ratios of 0.5, 1.0, and

5.0 percent. The results reveal only a' slight difference in the peak acceleration for the different

damping ratios. Based on these results, the staff concludes that a damping ratio of 2 percent

for the Zone III-IV rock is acceptable.

In RAI 2.5.4-9(a), the staff asked the- applicant to describe the method that it used for the

development of the site-specific acceleration time histories. In response to RAI 2.5.4-9(a), the

applicant stated that it selected two horizontal-component acceleration time histories, which it

then matched to the low- and high-frequency response spectra from the two controlling,-

earthquakes. The-applicant next used these spectrum-compatible time histories for the site

response analysis. In RAI 2.5.4-9(b), the staff asked the applicant to further describe the

method it used for the development of the soil column amplification/attenuation analysis. In

response to'RAI 2.5.4-9(b), the applicant stated that it used the SHAKE2000 computer program

to compute the site dynamic responses for the four soil and rock profiles described in SSAR

Section 2.5.4.7.1. The applicant provided the input soil parameters, the depth at which the hard

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'1Ru

rock ground was input (70 ft), and information on the number of iterations to compute the straincompatible modulus and damping values for the SHAKE analysis. In RAls 2.5.4-9(c) and (d),

the staff asked the applicant to further describe the four soil profiles and how it accounted for

the variability of the soil properties in the analysis. In response to RAls 2.5.4-9(c) and (d), the

applicant provided the soil properties for each of the four profiles and an analysis that

demonstrated how it varied these properties. The applicant stated that V, and Gmax, which is

derived from VS. have the most impact on the amplification/attenuation analysis. The applicant

showed response spectra for different levels of _G,, (67 to 150 percent). In RAI 2.5.4-9(e), the

staff asked the applicant to justify its use of the mean 104 uniform hazard spectrum as the input

rock motion. In response to RAI 2.5.4-9(e), the applicant stated that it initially used a time

history matched to the mean 104 uniform hazard spectrum; however, in Revision 3 to its SSAR,

it revised this approach to use time histories that match the low- and high-frequency response

spectra calculated from the two controlling earthquakes. Because the applicant used both the

low-frequency and high-frequency time histories and four different rock/soil profiles and also

accounted for the variability in the soil and rock properties, the staff concludes that the applicant

accurately determined the dynamic response of the soil and rock underlying the ESP site to the

input hard rock ground motion. As a result of RAI 2.5.4-9, the applicant revised portions of

SSAR Sections 2.5.4.7 and 2.5.4.8.

Based on its review of SSAR Section 2.5.4.7 and the applicant's responses to the RAls, as

described above, the staff concludes that the applicant adequately determined the response of

the soil and rock underlying the ESP site to dynamic loading. The staff notes the applicant's

commitment in response to RAI 2.5.4-9 to perform further soil column amplification/attenuation

analyses at the COL stage, once it selects specific locations for the nuclear power plant

structures. This is COL Action Item 2.5-5. The applicant stated that this analysis would

involve subsurface investigations to determine actual strata thicknesses and confirm the

subsurface material properties at each location.

2.5.4.3.8 Liquefaction Potential

In its review of SSAR Section 2.5.4.8, the staff evaluated the applicant's liquefaction analyses.

The staff's review focused on the applicant's conclusion that only the Zone IIA saprolite is

susceptible to liquefaction, as well as the various liquefaction analyses and parameter inputs to

these analyses. The applicant concluded that soil Profile 1, which has 30 ft of unimproved

Zone IIA saprolite, is potentially susceptible to liquefaction in most of the upper portions. The

applicant stated that, if safety-related structures are founded on the Zone IIA saprolitic soils,

these soils would be improved to reduce any liquefaction potential.

In RAI 2.5.4-1 0, the staff asked the applicant to describe how it varied the significant soil

properties and seismic input values for each of the different liquefaction analyses. In addition,

the staff asked the applicant to provide a sample liquefaction analysis. In its response, the

applicant stated that it based the liquefaction analyses on the work of Youd et al. (Ref. 178,

SSAR Section 2.5). For each of the three different analyses, the applicant varied Gmr,, the

peak earthquake acceleration, and the earthquake magnitude. Based on its review of the

sample liquefaction analysis, the staff concludes that the applicant used the latest empirical

method and adequately varied the significant soil and seismic input parameters in accordance

with the guidance provided in RG 1.198, which recommends the Youd et al. method.

Therefore, the applicant's liquefaction analyses are acceptable.

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Based on its review of SSAR Section 2.5.4.8 and the applicant's response to RAI 2.5.4-10,

described above, the staff concludes that the applicant has employed an acceptable

methodology to determine the liquefaction potential of the soil underlying the ESP site.

Because portions of the Zone IIA saprolite are susceptible to liquefaction, the applicant stated

that, if safety-related structures are founded on the Zone II saprnlitic soils, these soils would be

improved to reduce any liquefaction potential. Accordingly, the staff proposes to include a

condition for any ESP that might be issued requiring that the ESP holder and/or an applicant

referencing such an ESP improve Zone II saprolitic soils to reduce any liquefaction potential if

safety-related structures are to be founded on them. This is Permit Condition 8. The

applicant described techniquesfor improving the Zone IIA saprolitic soils in SSAR

Section 2.5.4.12.

2.5.4.3.9 Earthquake Design Basis:

SSAR Section 2.5.2.6 presents the applicant's derivation of the SSE. Section 2.5.2.3.6 of this

SER summarizes the staff's evaluation of the SSE.

2.5.4.3.10 Static Stability

In its review of SSAR Section 2.5.4.10,,the staff focused on the applicant's determination of the

bearing capacities for each of the soil and rock zones, as well as the applicant's settlement

analysis. The applicant presented bearing capacities for each of the soil and rock zones and

described how it obtained these results. In addition, the applicant stated that the settlement of

a large foundation with an assumed size of 150 ft by 300 ft, underlain by Zone IIB, would be

less than 0.5 in.

In RAI 2.5.4-11, the staff asked the applicant to provide further details concerning its calculation

of the bearing capacities of the soil and rock underlying the ESP site. In its response, the

applicant provided a sample calculation for the staff to review. In addition, the applicant stated

that the maximum bearing pressure from the containment building foundation is 15 ksf,-which is

only a fraction of the allowable bearing capacity of the bedrock (Zone III-IV is 80 ksf and -

Zone IV is 160 ksf). During its review of the sample bearing capacity calculation, the staff - -

determined that the applicant used the widely accepted bearing capacity formulas developed by

Terzaghi (D.P. Coduto, "Foundation Design," 2nd edition, issued 2001). Accordingly, the staff

concludes that the applicant adequately determined bearing capacity values for each of the soil

and rock zones. In addition, the staff concludes that the bearing capacities of Zones III-IV and

IV rock are sufficient to handle the load of a containment building foundation.. -

Based on its review of SSAR Section 2.5.4.1 0 as described above, the staff concludes that the

applicant provided an adequate preliminary assessment of the static stability of the ESP site.

However, as described in RS-002, for the staff to perform a complete review of site static

stability, the staff will need a COL or CP applicant to provide an analysis of the stability of all

planned safety-related facilities when the locations of the plant structures are finally specified.

This analysis should include bearing capacity, rebound, settlement, and differential settlements,

as well as lateral loading conditions for all safety-related facilities. Therefore,-the staff

concludes that the applicant's description of the static stability is adequate to provide assurance

of the stability of the ESP site,- but the staff needs additional information to support any finding

regarding detailed structure-specific stability. The need to provide an analysis of the stability of

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'III

all planned safety-related facilities, including bearing capacity, rebound, settlement, and

differential settlements under deadloads of fills and plant facilities, as well as lateral loading

conditions, is COL Action Item 2.5-6.

2.5.4.3.11 Design Criteria

In SSAR Section 2.5.4.11, the applicant provided general geotechnical criteria, such as

acceptable FSs against liquefaction, allowable bearing capacities; acceptable total and

differential settlements, and acceptable FSs against slope stability failure. The applicant did not

provide structural design criteria, such as wall rotation, sliding, and overturning.

In RAI 2.5.4-12, the staff asked the applicant to explain why it did not provide design criteria

pertaining to structural design. In its response, the applicant stated that structural criteria, such

as allowable wall rotation and FSs against structure sliding and overturning, are not site specific

and thus are not included in SSAR Section 2.5. The applicant stated that a COL application

would describe these structural criteria. Since 10 CFR Part 52, Subpart A, does not require the

submission of such information, the staff concludes that the applicant's decision not to include

structural design criteria in the ESP applicant is justified.

Based on its review of SSAR Section 2.5.4.11 and the applicant's response to the RAI, the staff

concludes that the applicant adequately presented the necessary design criteria for the ESP

site. The need to provide design-related criteria that pertain to structural design (such as wall

rotation, sliding, and overturning) is COL Action Item 2.5-7.

2.5.4.3.12 Techniques to Improve Subsurface Conditions

In SSAR Section 2.5.4.12, the applicant presented a general description of the ground

improvement techniques it may employ so that the Zone IIA saprolitic soils could be used to

support safety-related foundations. Although this general description was useful to the staff, a

COL or CP applicant should provide specific plans for each proposed ground improvement

technique it plans to employ so that the staff may determine whether the chosen techniques will

ensure that Zone IIA saprolitic soils will be able to support safety-related foundations. This is

COL Action Item 2.5-8.

2.5.4.4 Conclusions

Based on its review of SSAR Section 2.5.4 and the applicant's responses to the associated

RAls, described above, the staff concludes that the applicant adequately determined the

engineering properties of the soil and rock underlying the ESP site through its field and

laboratory investigations. 1 In addition, the applicant used the latest field and laboratory

methods, in accordance with RGs 1.132, 1.138, and 1.198, to determine these properties.

Accordingly, the staff concludes that the applicant performed sufficient field investigations and

laboratory testing to determine the overall subsurface profile, as well as the properties of the

soil and rock underlying the ESP site. Specifically, the staff concludes that the applicant

adequately determined (1) the soil and rock properties through its field investigations and

laboratory tests, (2) the response of the soil and rock to dynamic loading, and (3) the

liquefaction potential of the Zone IIA saprolitic soils. The staff notes that the applicant

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committed to perform additional field investigations once it has selected the locations for safetyrelated structures at the COL stage.

In SSAR Sections 2.5.4.5 (excavation and backfill), 2.5.4.6 (ground water conditions), 2.5.4.10

(static stability), 2.5.4.11 (design criteria), and 2.5.4.12 (techniques to improve subsurface

conditions), the applicant did not provide information sufficient for the staff to perform a

complete evaluation. In addition, the applicant did 'not provide any information on the -

relationship of the foundation and underlying materials (Section 2.5.4.3 in RS-002). Each of the

these topics depends on specific'information related to building location and design and will be

submitted as part of any COL or CP application.

In SSAR Table 1.9-1, the applicant identified three subsurface material properties as ESP site

characteristics. The first site characteristic specifies that there is no potential for liquefaction at

the ESP site. The applicant demonstrated, in SSAR Section 2.5.4.1.8, that any liquefaction at

the ESP site would be limited to the ZoneIIAsaprolites, and if any safety-related structures are

founded on the Zone IIA saprolites, these-soils would be improved to reduce potential

settlements and to ensure an FS for liquefaction greater than or equal to 1.1. The second site

characteristic specifies a minimum bearing capacity value of 15 ksf. The bearing capacities for

rock of Zones Ill and above underlying the ESP site are greater than 15 ksf (see SSARTable 2.5-45).; Finally, the third site-characteristic specifies a minimum shear wave velocity of

3500 ft/s for the material underlying the foundation. The applicant stated that the reactorcontainment would be founded'on'Zone III-IV or IV bedrock. Because the average shear wave

velocity (Vj) of the Zone III-IV bedrock is slightly less (3300 ft/sec) than this postulated PPE

value (3500 ftlsec), the COL or CP applicant should determine the V, of the actual material -

underlying the foundation for the reactor containment to ensure that V, equals or exceeds that

of the chosen design. This'is COL Action Item 2.5-9. The staff has reviewed the applicant's

suggested site characteristics and plant design parameters related to'SSAR Section 2.5.4 for

inclusion in an ESP, should the NRC issue one to the applicant. For the'reasons set forth

above, the staff agrees with the applicant's site characteristics and values.

2.5.5 Stability of Slopes

SSAR Section 2.5.5 presents information on the stability of permanent slopes at the NAPS site.

The applicant used previous geological, geophysical, and geotechnical investigations as a basis

for determining the stability of the slopes at the site. -SSAR Section 2.5.5.1 ,describes the

existing slope characteristics, SSAR Section 2.5.5.2 describes the design' criteria and analyses

of slope stability, SSAR Section 2.5.5.3 presents information from two sample borings on or

close to the slope, SSAR Section 2.5.5.4 states that the slope does not contain compacted fill,

and SSAR Section 2.5.5.5 describes a potential new slope that may be excavated at the site.

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It.

2.5.5.1 Technical Information in the Application

2.5.5.1.1 Slope Stability Analysis and Design Criteria

Existing Slope Characteristics

SSAR Section 2.5.5.1 describes an existing 2-horizontal to 1-vertical (2h:lv), 55-ft-high slope

that descends from north of the SWR down to the south of the existing excavation made for the

abandoned NAPS Units 3 and 4. The slope was excavated during construction of NAPS

Units 1 and 2 and is made almost entirely of cut material. Since the top of this slope is 200 ft

from the top of the SWR embankment, the applicant concluded that any potential instability of

the slope would have no impact on the stability of the SWR embankment. However, sloughing

or collapse of the slope could impact the new units, depending on their final location.

The NAPS licensee took two slope borings, conducted for the Unit 1 and 2 investigation, close

to the area of the slope. As shown in the boring profiles, the soils in the slope consist almost

entirely of Zone IIA saprolites. Saprolites are a further stage of weathering beyond weathered

rock. Although saprolites are classified as soils, they still contain the relict structure of the

parent rock and some core stone of the parent rock. About 75 percent of the Zone IIA

saprolites are classified as coarse grained (sands, silty sands), while the remainder are fine

grained (clayey sands, sandy and clayey silts, and clays). The majority of the saprolites

obtained from the borings in the slope area are dense silty sands.

Design Criteria and Analyses

SSAR Section 2.5.5.2 presents the design criteria for the slope, as well as an analysis of the

static and dynamic (seismic) stability analysis. The design criteria used for the slope include

the following minimum FSs:

* end of construction-FS=1.4

* long-term static (nonseismic)-FS=1.5

* long-term seismic-FS=1.1

The applicant inspected the slope during the ESP site investigation and found no signs of

distress. In addition, a comparison of recent and old photographs of the site shows that the

condition of the slope is unchanged.

For the static and dynamic analyses of the slope, the applicant used the computer program

SLOPE/W, which is a commercial software product that employs limit equilibrium theory to

compute the FS of earth and rock slopes. For the static analysis, the SLOPE/W program used

the Bishop method of slices. The applicant assumed that the saprolite is predominantly coarse

grained, with a unit weight of 125 pcf, an angle of internal friction (4') of 30 degrees, and an

effective cohesion (c') of 0.25 ksf. The resulting FS for the static analysis is 1.75, which is

above the minimum FS of 1.5 for long-term static stability.

For the seismic slope stability analysis, the applicant used the pseudostatic approach, which

assumes that the horizontal and vertical seismic forces act on the slope in a static manner as a

constant force. Since an actual seismic event would last only seconds, with the peak motions

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W z or fb 0 v as sI

occurring for a small portion of the total duration, the applicant concluded that the pseudostatic

approach is a conservative approach. For the high-frequency earthquake, the applicant used a

peak horizontal acceleration of 0.65g, which is the average peak acceleration in the top 55 ft of

unimproved soil (see SSAR Table 2.5-46). Similarly, the applicant used a vertical peak

acceleration of 0.32g. The app icant stated that the resulting FS is significantly less than 1 .1, -

which is the minimum FS required for seismic slope stability. For the low-frequency -

earthquake, the applicant used a peak horizontal acceleration of 0.26g, which is the average

peak acceleration in the top 55 ft, and a vertical acceleration of 0.13g. The computed FS for

this case is slightly greater than 1.1.

As an alternative to applying the peak acceleration values for the pseudostatic analysis, the

applicant chose to use horizontal accelerations of 0.1 5g and 0.1 Og and a vertical acceleration of

zero. The applicant provided the following argument to support these acceleration values:

-Seed (Reference 186), in the 19t Rankine Lecture, addressed the overconservatism intrinsic in the pseudo-static analysis. He looked at the more

rational approach proposed by Newmark (Reference 187), where the effective

acceleration time-history is integrated to determine velocities and displacements

of the slope. He also examined dams in California that had been subjected to

seismic forces, including several dams that survived the 1906 San Francisco

earthquake. Based on his studies,. he concluded that for embankments that

consist of materials that do not tend to build up large pore pressures or lose

significant percentages of their shear strength during seismic shaking, seismic

coefficients of only 0.15g are adequate to ensure acceptable embankment

performance for earthquakes up to Magnitude M=8.25 with peak ground

accelerations of 0.75g. For earthquakes in the range of M=6.5, Seed

recommends a horizontal seismic coefficient of only 0.1g with a vertical seismic

coefficient of zero.

Since the fabric and interlocking angular grain structure of the Zone IIA saprolite have a low.

susceptibility to pore pressure buildup and liquefaction, the applicant concluded that it would not

lose a significant portion of its shear strength during shaking. In addition, since the controlling

earthquake magnitudes for the ESP site are 5.4 and 7.2, the applicant concluded that using the

acceleration values recommended by Seed was justified. Using horizontal accelerations of

0.10g and 0.15g with a vertical acceleration of zero, the computed FSs are greater than 1.1,

which is higher than the minimum FS for seismic slope stability. In summary, the applicant

stated, "the Seed reductions are considered reasonable and valid, and the slope is considered

to have an adequate factor of safety against failure during the ESP seismic event."

In RAI 2.5.5-1, the staff asked the applicant to provide its basis for concluding that the existing

slope has a low susceptibility to liquefaction and, therefore, concluding that a horizontal

acceleration of 0.1 g is suitable for the slope stability analysis. In its response, the applicant

stated that it revised its previous liquefaction analysis because it is now basing the SSE on the

RG 1.1 65 approach. The applicant's revised liquefaction analysis (see SSAR Section 2.5.4.8)

shows more widespread liquefaction within the Zone IIA saprolitic soils. -However, since this

analysis does not take into account the age, fabric, structure, and mineralogy of the saprolite,

the applicant maintained that any liquefaction would not be widespread. The applicant also

defended its use of 0.IOg and 0.15g as the peak accelerations for the pseudostatic slope

stability analysis. The applicant cited the research of Seed (Ref. 186, SSAR Section 2.5), who

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concluded that, if embankments do not liquefy or lose a significant amount of strength during a

seismic event, they would displace at the crest but typically not fail in the conventional sense.

The applicant stated that the design high-frequency earthquake has relatively low energy

(magnitude 5.4), and therefore an acceleration of 0.10g is adequate. For the low-frequency

earthquake, the applicant used a value of 0.15g for the peak acceleration. The pseudostatic

slope stability analyses run with 0.1 g and 0.1 5g both give FS values greater than 1.1.

The applicant also used the pseudostatic approach recommended by Kramer (Ref. 188, SSAR

Section 2.5), which uses half of the peak acceleration value rather than a set peak value based

on magnitude. Using Kramer's method, for the high-frequency earthquake, the applicant used

a horizontal peak acceleration'value of 0.325g and a vertical peak acceleration of 0.1625g. For

the low-frequency earthquake, the applicant used a horizontal peak acceleration of 0.1 3g and a

vertical peak acceleration of 0.065g. With' these peak acceleration values, the applicant found

that the FS is just below 1.0 for the high-frequency ground motion and greater than 1.1 for the

low-frequency ground motion. Since the FS is below 1.0 using Kramer's method, the applicant

stated that it could not rule of the possibility of some liquefaction in the slope area.

Boring Logs

The applicant drilled two sample borings on or close to the existing 2h:1v slope to the north of

the SWR. Figures 2.5-71 and 2.5-72 in the SSAR reproduce the logs of the two borings.

Compacted Fill

SSAR Section 2.5.5.4 states that the existing 2h:1v slope is a cut slope and does not contain fill

materials in any significant quantity.

Proposed New Slope

SSAR Section 2.5.5.5 states that a new slope may be excavated to the west of the SWR to

accommodate UHSs for the new units. The new slope would be approximately the same height

and would have the same 2h:1v slope as the existing slope. In addition, this proposed new

slope would comprise similar materials as the existing slope. Therefore, the applicant

concluded that the analytical conclusions for the existing slope would apply to the new slope;

the new slope would be stable under seismic and long-term static conditions.

Conclusions

In SSAR Section 2.5.5.6, the applicant stated that, based on the possibility of some liquefaction

in the slope area (existing slope), as well as the marginal results that it obtained using Kramer's

method (Ref. 188, SSAR Section 2.5), it would take measures to ensure the safety of the slope

and the structures that may be located close to the bottom of the slope. The applicant stated

that these measures could include reducing slope steepness, removing and replacing materials

that could lose significant strength during the design earthquake, and ground improvement

measures such as soil nailing, moving structures further from the toe of the slope, and/or

providing walls/barriers to protect those structures.

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2.5.5.2 Regulatory Evaluation

SSAR Section 2.5.5 presents information on the stability of permanent slopes at the ESP site.

The applicant stated in SSAR Section 1.8 that it developed the information regarding slope

stability in accordance with' the guidance presented in Sectiori 2.5.5 of RS-002 and RG 1.70

and that the information is intended to satisfy the requirements of 10 CFR 100.23.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

100.23, which states that the applicant for an ESP must describe the geologic and seismic

conditions of the proposed site necessary to determine site suitability. Section 2.5.5 of RS-002

provides specific guidance concerning the evaluation of information characterizing the stability

of slopes under SSE conditions.

2.5.5.3 Technical Evaluation

The staff's review of SSAR Section 2.5.5 focused on the applicant's analysis of the stability of

an existing slope adjacent to the ESP sit6,'the failure of which might impact future structures

located close toethe slope. The staff reviewed the'applicant's description of the existing slope

characteristics, design criteria and analyses, and proposed new slope and design modifications.

2.5.5.3.1 'Slope Stability Analysis and Design Criteria

The staff focused its review of SSAR Sections 2.5.5.1 through' 2.5.5.6 on the adequacy of the

applicant's slope stability analysis of an existing slope adjacent to the ESP site. In addition, the

staff reviewed the applicant's summary of the slope subsurface conditions, as well as its - '

proposed new slope and potential design modifications to ensure the safety of the slope and of

the structures located close to the bottom of the slope.

To perform the slope stability analysis, the applicant used three different pseudostatic

approaches. For the first approach, the applicant used average peak vertical and horizontal

acceleration values (0.32g and 0.65g), which resulted in FS less thanr 1.1. For the second

approach, the 'applicant used the approach recommended by Seed (Ref. 186, SSAR

Section 2.5), which recommends peak acceleration'values based on- the magnitude of the

earthquake. Using the Seed approach, the applicant originally used peak vertical and

horizontal acceleration values of 0.1Og, in accordance with the magnitudes for the controlling

earthquakes. With these lower peak accelerations, the resulting FS were greater than 1.1,

which is the minimum FS acceptable for seismic slope stability. lnrRAl 2.5.5-1, the staff asked

the applicant to provide its basis for concluding that a horizontal acceleration of 0.19 is suitable

for the slope stability analysis. In response to RAI 2.5.5-1,-the applicant stated that it'revised

the peak horizontal acceleration value to 0.15g, since the controlling earthquake using the'

RG 1.165 approach has a magnitude of 7.2. The pseudostatic slope'stability analyses run with

0.10g and 0.15g both give FS values greater than 1.1. For the third pseudostatic approach, the

applicant used the peak acceleration values recommended by Kramer (Ref. 188, SSAR

Section 2.5), which are half of the average peak acceleration values (0.1 6g and 0.33g). Using

these values the FS is below 1.0 for the high frequency controlling earthquake, implying the

possibility of some liquefaction in the slope area.

The applicant concluded its response to RAI 2.5.5-1 by stating, 'in recognition of the high nearsurface accelerations and the results of the liquefaction analysis, the SSAR will be revised to

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indicate measures that would be taken to ensure the safety of the slope and of the structures

that may be located close to the bottom of the slope." The staff concurs with this decision,

since two of the three pseudostatic liquefaction analysis approaches result in FS less than 1.1.

The staff concludes that, for the purposes of the ESP application, the pseudostatic analyses

used by the applicant are adequate to analyze the stability of the existing slope. However,

because the Zone IIA saprolites are susceptible to liquefaction, and because the existing slope

could change, depending on final plant design and layout, the staff concludes that the COL or

CP applicant should conduct a more detailed dynamic analysis of the stability of the existing

slope and any new slopes resulting from plant construction using the SSE ground motion. This

is COL Action Item 2.5-10.

2.5.5.4 Conclusions

Based on its review of SSAR Section 2.5.5 and the applicant's response to RAI 2.5.5-1,

described above, the staff concludes that the applicant sufficiently analyzed the stability of the

existing slope for the purposes of the ESP application. Because of the susceptibility of the

Zone IIA saprolites to liquefaction, the staff concludes that the COL or CP applicant should

conduct a more detailed dynamic analysis of the stability of the existing slope and any new

slopes using the SSE ground motion. This is COL Action Item 2.5-10. A more extensive

dynamic analysis would be appropriate at the COL or CP stage, since the applicant will have

determined the locations of safety-related structures relative to the existing or new slopes. In

addition, the COL or CP applicant should provide plot plans and cross'sections/profiles of all of

the safety-related slopes and should specify the measures that it will take to ensure the safety

of the slopes and any structures located adjacent to the slopes. This is COL Action

Item 2.5-1 1.

2.5.6 Embankments and Dams

2.5.6.1 Technical Information in the Application

In SSAR Section 2.5.6, the applicant stated that, since Lake Anna would only be used for

normal (i.e., non-safety-related) plant cooling of the new units, it did not reanalyze the North

Anna Dam as part of the ESP applicatiorn. According to the applicant, the North Anna Dam was

designed and constructed to meet the requirements for a seismic Category I structure in

support of the existing NAPS units.

2.5.6.2 Regulatory Evaluation

SSAR Section 2.5.6 states that the applicant did not reanalyze the North Anna Dam since Lake

Anna would only be used for normal plant cooling of the new units. As such, the applicant did

not list any regulatory guidance or cite any regulations as applicable to SSAR Section 2.5.6.

Section 2.5.6 of RG 1.70 describes the necessary information and analysis related to the

investigation, engineering design, proposed construction, and performance of all embankments

used for plant flood protection or for impounding cooling water. Sections 2.4.4 and 2.5.5 in

RS-002 provide similar information and guidance.

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2.5.6.3 Technical Evaluation

Section 2.4.4 of this SER provides the staff's evaluation of potential dam failures; Section 2.5.5

of this SER provides its evaluation of slope stability.

2.5.6.4 Conclusions

Sections 2.4.4 and 2.5.5 of this SER present the staff's conclusions regarding dam failures and

slope stability, respectively.

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3. DESIGN

3.5.1.6 Aircraft Hazards

For an early site permit (ESP) application, the NRC staff reviews the applicant's assessment of

aircraft hazards to 'ensure that the risks associated with aircraft hazards are sufficiently low.'

3.5.1.6.1 Technical Information in the Application

In Section 2.2.2.6 of the SSAR, the applicant presented information concerning airports and

airways in the site vicinity that could affect a nuclear power plant or plants that might be

constructed on the proposed ESP site. The applicant evaluated this information in'SSAR

Section 2.2.3.2.1.

The applicant stated that three airports exist within 15 miles of the proposed ESP site. Two of

the airports are paved civil fields at which one or more aircraft are based, and the other is an'

unpaved private field at which no aircraft are based. None of the airports has commercial

operations.

The closest airport is'the Lake Anna Airport, about 7 miles south-southeast of the proposed

ESP site. According to the applicant, approximately 3640 operations occurred at the field in

2002. The field is occasionally used for practice takeoffs and landings. The other paved field is

the Louisa County Airport, which is about 11 miles west-southwest of the proposed ESP site.

Approximately 6240 operations occurred at the field in 2002. The third airport is Cub Field,

which is about 10 miles south-southwest of the proposed ESP site, and has a few operations'

per year.

The applicant stated that none of these airports has a sufficient number of flight operations per

year to rise above the threshold set forth in Section 3.5.1.6 of Review Standard (RS)-002,

'Processing Applications for Early Site Permits," which would trigger a detailed evaluation of'

potential hazards associated with airport flight operations. Therefore, the applicant did not

include a detailed evaluation of potential hazards associated with airport flight operations.

The applicant stated that one civil airway and three military training routes pass near the

proposed ESP site. The centerline of the civil airway (V223) is about 5.5 miles west of the site,

and the edge of the airway is about 1.5 miles from the site. No traffic data are kept for this

airway. However, the applicant stated that the Federal Aviation Administration (FAA)

characterizes the airway as "not heavily used" and estimates the traffic to be' less than

200 aircraft per day.

The centerlines of the military training routes, which are 10 miles wide, are less than 1 mile

south of the proposed ESP site. The applicant stated that the Oceana Naval Air Station in

Virginia Beach controls these routes. The applicant added that, according to a' knowledgeable

representative of the Navy whom it had contacted, pilots using these routes are instructed to fly

near the edge of the route to avoid the North Anna Power Station (NAPS) and to generally

remain 3 to 4 miles from NAPS. Flights along the routes typically involve one or two'aircraft,

and rarely four aircraft. The applicant stated that the number of flights per year on the military

routes has remained approximately constant, as evidenced by the documented total traffic for

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these three routes over a 3-year period. Specifically, the annual number of flights for these

three routes was 2582, 2348, and 2623 for the years 1991, 1992, and 1993, respectively.

The airways are sufficiently close to the proposed site to warrant detailed evaluations of the

associated potential hazards. In the SSAR, the applicant included detailed evaluations it

performed following the guidance in RS-002, Section 3.5.1.6. The applicant's analysis

concluded that the probability of an aircraft crash on the proposed ESP site from flights along

the V223 airway is 3.45x1 08 per year. Similarly, the applicant's analysis concluded that the

probability of an aircraft crash on the proposed ESP site from flights along the military training

routes is 1.56x1 0-8 per year.

3.5.1.6.2 Regulatory Evaluation

In SSAR Section 1.8, the applicant identified the applicable NRC regulations and guidance

related to the identification and evaluation of hazards associated with aircraft hazards as

Title 10, Part 100, "Reactor Site Criteria," of the Code of Federal Regulations (10 CFR

Part 100), Subpart B; Regulatory Guide 1.70, "Standard Format and Content of Safety Analysis

Reports for Nuclear Power Plants," issued February 1972; and RS-002, Section 3.5.1.6.

Section 2.2.3.2 of the SSAR refers to NUREG-0800, "Standard Review Plan for the Review of

Safety Analysis Reports for Nuclear Power Plants"; however, RS-002 includes the portion of

NUREG-0800 that is referenced. The staff agrees that the foregoing regulations and guidance

apply to this portion of the review. The staff considered the regulatory requirement in 10 CFR

Part 100, Subpart B, in reviewing aircraft hazards.

According to Section 3.5.1.6 of RS-002, the requirement in 10 CFR 100.20, "Factors to be

Considered When Evaluating Sites," that individual and societal risks of potential plant

accidents be low is met if the probability of aircraft accidents having the potential for radiological

consequences greater than the 10 CFR 50.34(a)(1) exposure guidelines is less than about

10'7 per year. The probability is considered to be less than about 10Q7 per year by inspection if

the distances from the site meet all of the following criteria:

1. The site-to-airport distance, D, is between 5 and 10 statute miles, and the projected

annual number of operations is less than 500 D2; or the site-to-airport distance, D, is

greater than 10 statute miles, and the projected annual number of operations is less

than 1000 D2.

2. The site is at least 5 statute miles from the edge of military training routes, including lowlevel training routes, except for those associated with a usage greater than 1000 flights

per year, or where activities (such as practice bombing) may create an unusual stress

situation.

3. The site is at least 2 statute miles beyond the nearest edge of a Federal airway, holding

pattern, or approach pattern.

If the above proximity criteria are not met, or if sufficiently hazardous military activities are

identified, a detailed review of aircraft hazards should be performed. Section 3.5.1.6 of RS-002

provides guidance on performing such a review.

3-2
3.5.1.6.3 Technical Evaluation

The applicant identified three airfields near the proposed ESP site. Two of the three airfields

are described'as public fields,' and the third is identified as a private'field. As noted in

Section 3.5.1.6.1 of this safety evaluation report'(SER), the applicant concluded that none of

the fields has a sufficiently large number of flight operation's to warrant a detailed analysis of the

risk to a plant constructed at the proposed ESP site.-

The staff notes, however, that a landing approach holding pattern for the Louisa County Airport

is relatively close to the ESP site. Depending on the speed of an aircraft on an approach to the

airport, this holding pattern can be less than 2 statute miles from the ESP site. As such, it

would not meet the third criterion described in Section 3.5.1.6.2 of this SER. Failure to meet

this criterion would, under the guidance in RS-002, necessitate a detailed aircraft hazards.

review. After consulting with the FAA, the staff has determined that only about 1 -percent of all

landing approaches to the-Louisa-County Airport involve the use of this particular holding

pattern. Hence, the staff has made an estimate of this hazard by taking into account the above

holding pattern usage fraction, the number of annual airport operations (6240 operations per

year), the effective target area (0.013 square miles (mi2)), and the crash frequency for general

aviation as given in NUREG-0800, Section 3.5.1.6. On this basis, the estimated crash

frequency is about 9.7x1 09 crashes per year.

The staff has confirmed that the applicant identified the public airfields closest to the proposed

ESP site. The next closest public airfield is in Spotsylvania County, more than 20 miles from

the site. The staff did not identify any additional private airfields within 10 miles of the site.

Given the typical number of flight operations per year from private airfields and the size and

type of aircraft that generally use private fields, the staff concludes that a detailed analysis of

risk to a plant at the proposed ESP site from operations at private fields is not necessary.

The applicant identified one airway and three military training routes that pass near or over the

proposed ESP and, using procedures described in RS-002, Section 3.5.1.6, separately

estimated the probability of an aircraft crashing into a plant constructed at the proposed site

from aircraft using the airway or military training routes. The staff has reviewed the applicant's

calculations and finds them to be consistent with the procedures detailed in RS-002.

In calculating the crash probabilities, the applicant used an effective area of 0.013 mi2 for

safety-related structures that might be damaged by a crash sufficient to cause the potential for

radiological consequences in excess of the 10 CFR 50.34(a)(1) criteria. The applicant used

drawings included in the SSAR to estimate this area. The area is somewhat smaller than that

listed for the power block (0.018 m12) in the plant parameter envelope (PPE). The staff

considers the area the applicant used in its calculation to be reasonable. Use of either figure

for the effective area would result in a crash frequency (for all four routes) of less than 10 7 per

year.

Appropriately, the applicant used the crash rates per mile of flight included in NUREG-0800 for

the calculations. The staff concludes that the probability of an accident having the potential for

radiological consequences in excess of the exposure criteria found in 10 CFR 50.34(a)(1) is

less than about 10'' per year.

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11M

3.5.1.6.4 Conclusions

The staff has reviewed the applicant's aircraft hazard analysis using the procedures set forth in

RS-002, Section 3.5.1.6. As set forth above, the staff has independently verified the applicant's

assessment of aircraft hazards at the site and concluded that the probability of an accident

having the potential for radiological consequences in excess of the exposure criteria found in

10 CFR 50.34(a)(1) is less than about 1 '7 per year. In addition, equivalent aircraft traffic in

equal or closer proximity to plant sites reviewed in past NRC licensing actions was, after careful

examination, found to present no undue risk to the safe operation of those plants. Based upon

these considerations, the staff concludes that aircraft hazards do not present an undue risk to

the health and safety of the public from potential construction and operation of one or more new

nuclear plants on the proposed ESP site. Therefore, the staff concludes, with respect to aircraft

hazards, that the proposed site is acceptable for constructing a plant falling within the

applicant's PPE, and that the site meets the relevant requirements of 10 CFR Part 52, "Early

Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power

Plants,' and 10 CFR Part 100.

3-4
11. RADIOLOGICAL EFFLUENT RELEASE DOSE CONSEQUENCES

FROM NORMAL OPERATIONS

11.1 Source Terms

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the information on radiological'.

dose consequences caused by gaseous and liquid effluents that may be released from normal

operation of the plant that was provided by reference in Site Safety Analysis Report (SSAR)

Section 2.3.5.1 and included in the Environmental Report Section 5.4 and Tables 3.1-9, 5.4-10,

and 5.4-11 of the Dominion Nuclear North Anna, LLC (Dominion or the applicant), early site

permit (ESP) application to determine whether site characteristics are such that the radiation

dose to members of the public would be within regulatory requirements.

11.1.1 Technical Information In the Application

The applicant provided information on the radiological impacts on members of the public from -

gaseous and liquid effluents that would be generated as a normal byproduct of nuclear power

operations. The applicant described the exposure pathways by which radiation and radioactive

effluents can be transmitted to members of the public in the vicinity of the site. The estimates

on the maximum doses to the public are based on the available data on the reactor designs

being considered using the plant paramet&r envelope (PPE) approach in which the bounding

liquid and gaseous radiological effluents were used in the evaluation. The applicant evaluated

the impact of these doses by comparing them to regulatory limits.

Using the PPE approach, Dominion provided a list of fission and activation products that may be released as liquid and gaseous effluents from the postulated new units. The applicant

evaluated the impacts from releases and direct radiation by considering the probable pathways

to individuals, populations, and biota near the proposed new units. The applicant also

calculated the highest dose from the major exposure pathways for a given receptor.

If built, the postulated new units at the North Anna ESP site would release liquid effluents intothe waste heat treatment facility (WHTF) through the discharge canals used for the operating units. The applicant considered the following liquid pathways-ingestion of aquatic food;

ingestion'of drinking water; exposure to shoreline sediment; and exposure to water through

boating, swimming, and other activities. -_ '

I .4 . -

Dominion also considered gaseous pathways, including external exposure to the airborne

plume, external exposure to contaminated ground, inhalation of airborne activity, and ingestion

of contaminated agricultural products, in its application.. :-

The applicant calculated the dose to the maximally exposed individual (MEI) fro rriboth the liquid

and gaseous effluent release pathways and calculated a collective whole body dose for the

population within 50 miles (mi) of the North Anna ESP site.

11.1.2 Regulatory Evaluation

NRC regulations require that applicants for an ESP address the characteristics of the proposed

site that could affect the radiation dose to a member of the public from radiological effluents. 'In

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Iret

SSAR Section 1.8.1, the applicant identified the applicable NRC regulations as Title 10,

Section 52.17(a)(1)(iv), of the Code of Federal Regulations (10 CFR 52.17(a)(1)(iv)).

Specifically, this regulation states that an ESP application should describe the anticipated

maximum levels of radiological effluents that each facility will produce. Furthermore, 10 CFR

100.21 (c)(1) requires that radiological effluent release limits associated with normal operation

from the type of facility proposed to be located at the site be met for any individual located off

site. The staff reviewed this portion of the application for conformance with the applicable

regulations.

11.1.3 Technical Evaluation

During normal operation, small quantities of radiological materials are expected to be released

to the environment through gaseous and liquid effluents from the plant.

11.1.3.1 Gaseous Effluents

The applicant calculated the estimated dose to a hypothetical maximally exposed member

of the public from the gaseous effluents using radiological exposure models based on

Regulatory Guide (RG) 1.111, uMethods for Estimating Atmospheric Transport and Dispersion

of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors," issued March

1976, RG 1.109, Revision 1, "Calculation of Annual Doses to Man from Routine Releases of

Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,"

issued October 1977, and the GASPAR II computer program (NUREG/CR-4653,

UGASPAR Il-Technical Reference and User Guide," March 1987).

Section 2.3.5 of this safety evaluation report discusses the derivation of the atmospheric

dispersion parameters used in the applicant's radiological dose assessment.

Dominion calculated the gaseous pathway doses to the MEI using the GASPAR II program at

the nearest site boundary, nearest vegetable garden, nearest residence, and nearest meat cow.

The applicant did not calculate doses from the milk pathway because no milk cows or goats are

located within a 5-mile radius of the ESP site. Table 5.4-7 of the environmental report includes

th6 gaseous effluent releases used to estimate dose to the MEL. These releases, which were

estimated for one unit, considered the advanced boiling-water reactor (ABWR) design to have

an output level of 4300 megawatt thermal (MWt), rather than the certified level of 3926 MWt.

This difference resulted in a slight increase in release rate for those isotopes for which the

ABWR design, as certified, was the bounding condition. Tables 5.4-3 through 5.4-5 of the

environmental report include other inputs to the GASPAR II program, including meat and

vegetable production rates, atmospheric dispersion factors, ground deposition factors, receptor

locations, and consumption factors. Table 5.4-9 of the environmental report presents the

gaseous pathway doses to the MEI calculated by the applicant. The staff performed an

independent evaluation of gaseous pathway doses with similar results.

In Table 1.3-8 of the SSAR, the applicant estimated the radiological dose consequences

caused by gaseous effluents that may be released from normal operation of the plant. The

applicant determined the gaseous radioactive effluent concentrations based on a composite of

the highest activity content of the individual isotopes it anticipated would be released from the

alternative reactor designs under consideration.

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The applicant also provided a bounding gaseous effluent source term to support its compliance

with the gaseous effluent reles1e concentration limits in Table 2 of Appendix B, "Annual Limits

on Intakes (ALls) and Derived Air Concentrations (DACs) of Radionuclides for Occupational

Exposure; Effluent Concentrations; Concentrations for Release to Sewerage," to 10 CFR

Part 20, "Standards for Protection Against Radiation."

11.1.3.2 Liquid Effluents

The applicant calculated the estimated dose to a hypothetical maximally exposed member of

the public from the liquid'effluents using radiological exposure models based on RG 1.109 and

the LADTAP II computer program (NUREG/CR-4013, "LADTAP Il-Technical Reference and

User Guide," April 1986).

Dominion calculated liquid pathway doses using'the LADTAP II program for various activities,

including eating fish and invertebrates caught near the discharge point; drinking water from

Lake Anna; and boating, swimming, and using the shoreline for'recreational purposes.

Table 5.4-6 of the environmental report includes the liquid effluent releases for one new unit

used in the estimate of dose to the MEL. These releases considered the ABWR design to have

an output level of 4300 MWt, rather than the certified level of 3926 MWt. This difference

resulted in a slight increase in release rate for those isotopes for which the ABWR design was

the bounding condition. Tables 5.4-1 and 5.4-2 of the environmental report include other

parameters used as input to the LADTAP II program, including effluent discharge rate, dilution

factor for discharge, transit time to receptor, and impoundment concentration.

The applicant calculated liquid pathway doses to the MEI, including a maximum annual dose to

the total body of 0.013 milliSievert (mSv) (1.3 millirem (mrem)) for the adult. Dominion

calculated the maximum annual dose to the thyroid as 0.013 mSv (1.3 mrem) for the infant and

the maximum annual dose to the liver as 0.017 mSv (1.7 mrem) for the child. The staff

performed an independent evaluation of liquid pathway doses with similar results. The staff

concludes that the applicant has provided a bounding assessment to demonstrate its capability

to comply with the regulatory requirements in 10 CFR Part 20 and Appendix I, "Numerical

Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As

Low as is Reasonably Achievable" for Radioactive Material in Light-Water-Cooled Nuclear

Power Reactor Effluents," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization

Facilities."

11.1.4 Conclusions

The applicant provided adequate information to provide reasonable assurance that it will

control, monitor, and maintain radioactive gaseous and liquid effluents from the ESP site within

the regulatory limits described in 10 CFR Part 20, as well as maintain them at as low as is

reasonably achievable (ALARA) levels, in accordance with the effluent design objectives

contained in Appendix I to 10 CFR Part 50.

As set forth above, the staff has independently verified the adequacy of the applicant's dose

consequence calculations from normal operations. A combined license (COL) or construction

permit (CP) applicant that references an ESP for the North Anna site should verify that the

calculated radiological doses to members of the public from radioactive gaseous and liquid

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effluents for any facility to be built on the North Anna site are bounded by the radiological doses

included in the ESP application and reviewed by the NRC staff as described above. This

includes any changes made to the input parameters used to calculate the radiological doses

(i.e., meteorological data, distance to receptors, and land use data). In addition, detailed

information on the solid waste management system used to process the radioactive gaseous

and liquid effluents will be required. This is COL Action Item 11.1-1.

Based upon these considerations, the staff concludes that radiological doses to members of the

public from radioactive gaseous and liquid effluents resulting from the normal operation of one

or more new nuclear power plants that might be constructed on the proposed ESP site do not

present an undue risk to the health and safety of the public. Therefore, the staff concludes,

with respect to radiological effluent release dose consequences from normal operations, that

the proposed site is acceptable for constructing a plant falling within the applicant's PPE, and

that the site meets the relevant requirements of 10 CFR Part 52, "Early Site Permits; Standard

Design Certifications; and Combined Licenses for Nuclear Power Plants," and 10 CFR

Part 100, "Reactor Site Criteria."

11-4
13. CONDUCT OF OPERATIONS

13.3 Emergency Planning e

The U.S. Nuclear Regulatory C6mmission (NRC) evaluates emergency plans for nuclear power

reactors to determine whether there is-reasonable assurance that adequate protective'

measures can and will be'takbn in the event of a radiological emergency. An early site permit

(ESP) application, pursuant to Title 10, Section 52.17(b), of the Code of Federal Regulations

(10 CFR 52.17(b)), 'rnust identify any physical characteristics unique to the proposed site that

could pose a significant impediment to the development of emergency plans. The application

must also describe the contacts and arrangements the applicant has made with Federal, State,

and local government agencies with emergency planning responsibilities. In addition, the;

application may propose major features of emergency plans, as described in Supplement 2 to

NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power

Plants-Criteria for Emergency Planning in an Early Site Permit Application-Draft Report for

Comment" (hereafter referred to as Supplement 2), issued April 1996, or may propose

complete and integrated emergency plans. - - -

In Section 13.3 of the site safety analysis report (SSAR), the applicant presented the major-!

features of its proposed emergency response plan pursuant to 10 CFR 52.17(b)(2)(i). -Because

the proposed ESP site footprint consists of a portion of the existing North Anna Power Station

(NAPS) site and is located immediately adjacent to NAPS, very little distinction exists between

the NAPS site and the ESP site for purposes of emergency planning. The ESP application

takes advantage of the emergency planning resources, capabilities, and organization that,

currently exist at the NAPS site.

The ESP applicant, Dominion Nuclear North Anna, LLC (Dominion) is an indirect, wholly owned

subsidiary of Dominion Resources, Inc. (Dominion Resources)... Virginia Electric and Power

Company (Virginia Power, formerly VEPCO), which operates the existing nuclear units on the

NAPS site (i.e., North Anna Units 1 and 2), is also a wholly owned subsidiary of Dominion --

Resources. If the COL or CP applicant were to proceed with the development of new reactor:

units at the ESP site, it would enter into an arrangement with Virginia Power to coordinate and

implement an integrated emergency plan, which,' in effect, would extend the existing emergency

planning and preparedness activities to the new reactor unit(s). The related offsite aspects of

emergency planning would remain essentially unchanged. -

The staff, in consultation with the Federal Emergency Management Agency (FEMA), has:-- -

reviewed the applicant's proposed emergency plan, applicable portions of the North Anna

Emergency Plan (NAEP), the Commonwealth of Virginia Radiological Emergency Response

Plan (COVRERP), county radiological emergency response plans (RERPs), responses to

requests for additional information (RAls), and generally available reference materials in

accordance with NRC Review Standard (RS)-002, "Processing Applications for Early Site

Permits," issued May 2004.

Because the applicant has elected to present and seek NRC acceptance of the major features

of emergency plans, the staff's evaluation addresses, in order, the three aspects of such a

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submission. The following identifies each aspect and the section of this safety evaluation report

(SER) in which it is discussed:

* identify physical characteristics that could pose a significant impediment to the

development of emergency plans (SER Section 13.1.1)

* describe contacts and arrangements made with Federal, State, and local government

agencies with emergency planning responsibilities (SER Section 13.3.2)

* propose major features of the emergency plans (SER Section 13.3.3)

The applicant identified Appendix E, "Emergency Planning and Preparedness for Production

and Utilization Facilities," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization

Facilities," as applicable to the major features it proposed. Appendix E, however, applies to the

"major features" option of 10 CFR 52.1 7(b)(2) only to the extent that it requires description of

the "essential elements of advance planning that have been considered" (see Section III of

Appendix E to 10 CFR Part 50). The staff has approved the applicant's identification of

Appendix E as one of the regulatory requirements applicable to the staff's review of the major

features proposed by the applicant. The staff's findings are set forth throughout Section 13.3.3

of this SER, and are limited to those particular portions of Appendix E that the staff considered

during the course of its review of a particular major feature. More importantly, any staff finding

that a proposed major feature complies with a particular requirement of Appendix E is limited to

the description of the major feature approved by the staff in this SER.

Notwithstanding any staff approval of a proposed major feature in this SER, all features of the

emergency plan requiring description pursuant to Appendix E, but which are not described in

the ESP application, will be reviewed in the context of a combined license (COL) or operating

license (OL) application. The staff will review complete and integrated emergency plans

submitted in a COL or OL application to determine whether they comply with such

requirements, as well as the requirements of 10 CFR 50.47, "Emergency Plans."

The staff's evaluation of the proposed major features of the applicant's emergency plans

parallels the major features and planning standards in Supplement 2.

13.3.1 Significant Impediments to the Development of Emergency Plans

13.3.1.1 Technical Information in the Application

In SSAR Section 13.3.2, the applicant stated that the major features emergency plan (i.e.,

Section 13.3 of the SSAR) takes advantage of the emergency planning resources, capabilities,

and organization that Virginia Power has already established and currently maintains at the

NAPS site. In addition, SSAR Section 13.3.2.2 states that the ESP site is adjacent to a

preexisting nuclear facility with existing State and local emergency plans. Hence, the SSAR

relies on and refers to the information contained in these existing plans.

SSAR Section 13.3.2.1 states that the applicant used a preliminary analysis of the evacuation

times, incorporating the evacuation time estimate (ETE) methods recommended in Section II of

Supplement 2 to identify any physical characteristics unique to the ESP site that could pose a

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significant impediment to the development of emergency plans. -This estimate included

seasonal recreational'visitors around Lake Anna and school populations. 'The most recent

ETE,'IEM/TECO1 220,'"Evacuation Time Estimates for the North Anna'Power Station and

Surr undiig nJurisdictions," dated November 2, 2001, -describes the analysis methods and

results. -

SSAR Section 13.3;2.1.2 states that the most'recent ETE for the NAEP is based on Census

2000 data and applies to the ESP site. The total permanent resident population within the

10-mile (mi) plume exposure pathway emergency planning zone (EPZ) is 20,292: The ETE'

considers permanent residents, transients, aid persons in special'facilities, including'school

populations (which are the only institutional populations within th'e 10-mile EPZ). 'Emergency'

'traffic is expected to flow away from the ESP site, and the road network can'adequately

accommodate anticipated vehicular traffic: SSAR Section 13.3.2.2.2.j.3 further states that the

ETE results in evacuation time estimates that'are based on different affected population areas

and weather conditions,- with estimates ranging from 85 tod'105 minutes (min).'

Appendix 10.8 to the NAEP incorporates the November 2001 ETE cited above. The appendix

describes the methods used to obtain current population data and to produce the ETEs, aind it

reports the updated population figures, road network information, and ETEs. The evacuation

scenarios that were modeled were based on peak season nighttime' poplation counts

(representing the worst case), and the analysis noted no significant traffic congestion in any of

the scenarios evaluated.

In addition, the ETE includes maps which sh'owvarious features of the 10-mile EPZ. -Figure-1,

"Map of the Area around North Anna Power Station," of the' ETE, which identifies'the

transportation networks and political boundaries, shows the NAPS site and the 10-mile EPZ

area. Figure'2, 'Map of the Protective'Action Zones for North Anna Power Station," Figure 3,

"Permanent Resident Population Distribution Based on 2000 Census Data by Sector and Ring,"

and Figure 6, "Evacuation Roadway Network," show the political boundaries. Figures'1,2, and

3 also show'the'location of'the NAPS site: Figures 1, 2, 3, and 6 identify the'transportation

networks, topographical features, and political boundaries. Figure 2 shows evacuation -

subareas (i.e., protective action zones (PAZs)). Section 1.2, "Emergency Planning Zone," of

the ETE states the following basis for the PAZs:

Twenty-five zones have been established for the NAPS 10-mile EPZ. To the

extent feasible, the zones were selected based 'on'existing political boundaries to '

enhance direction and coordination' of the public in the affected area. The'

demarcation of the zones are robughly 2, 5, and 10 miles from the nuclear facility.

This permits flexibility and selectivity in application of protective actions. Figure 2

':is a map of the PAZs for NAPS; Attachment 1 contains boundary descriptions of -

the PAZs within the 10-mile emergency planning zones for'NAPS. ;I

In RAI 13.3-9, the staff asked the applicant to specifically state whether it identified any physical

characteristics'uhique to the'proposed ESP site from the ETE or any other source or analysis

that could pose a'significant impediment to the development of emergency plans for the site. In

'its'respb'nse, the applicant stated that it had hot identified any physical characteristics unique to

the North Anna ESP site that could pose a significant impediment to the development of

emergency plans for the site and that the ETE did not identify any areas of congestion during

the evacuation evaluations.

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In SSAR Section 13.3.2, the applicant stated that the major features emergency plan (i.e., SSAR Section 13.3) takes advantage of the emergency planning resources, capabilities, and

organization that Virginia Power has already established and currently maintains at the NAPS

site. In RAI 13.3-3, the staff asked the applicant whether it wished to incorporate applicable

sections of the existing NAEP into the application, to the extent that the NAEP supports the

emergency planning description in the application. In its response, the applicant confirmed that

it had incorporated applicable sections of the existing NAEP into the application.

In RAI 13.3-11, the staff asked the applicant to address whether the increases in population

during the term of an ESP could pose a significant impediment to the development of

emergency plans.. In its response, the applicant stated that the ETE identified no areas of

congestion and that travel time is relatively inelastic with respect to anticipated changes in road

capacity. In SSAR Section 2.1.3, the applicant provided population projections and stated that

any population increase is projected to be gradual over time. Planning and consideration of

new roads or modifications of existing roads and intersections could offset any large influx of

new permanent or transient populations within the 10-mile EPZ.

13.3.1.2 Regulatory Evaluation

In SSAR Section 13.3.1, the applicant stated that SSAR Section 13.3 presents information

required by 10 CFR 52.1 7(b)(1) regarding the identification of potential impediments to

emergency planning. In its review of the application, the staff considered the regulatory

requirements in 10 CFR 52.17(b)(1), which mandate that the applicant for an ESP identify

physical characteristics unique to the proposed site, such as egress limitations from the area

surrounding the site, that could pose a significant impediment to the development of emergency

plans. The staff further considered 10 CFR 52.18, "Standards for Review of Applications,"

which requires consultation with FEMA to determine whether the information required of the

applicant by 10 CFR 52.17(b)(1) demonstrates that no significant impediment to the

development of emergency plans exists. Supplement 2 and RS-002 provide guidance

concerning the review and evaluation of emergency planning information given in an ESP

application.

Supplement 2 defines a significant impediment as a physical characteristic or combination of

physical characteristics that would pose major difficulties for an evacuation or the taking of

other protective actions.- Such unique physical characteristics may be identified by performing a

preliminary analysis of the time for evacuating various sectors and distances within the 1 0-mile

EPZ for transient and permanent populations, noting major difficulties for an evacuation (e.g.,

significant traffic-related delays) or the taking of other protective actions.

According to RS-002, the applicant should address factors, such as the availability of adequate

shelter facilities, local building practices and land use (e.g., outdoor recreation facilities,

including camps, beaches, hunting or fishing areas), and the presence of large institutional or

other special needs populations (e.g., schools, hospitals, nursing homes, prisons) when

identifying significant impediments to the development of emergency plans. Any ETE or other

identification of physical impediments should include the latest population census numbers and

the most recent local conditions. In addition, the applicant should describe the proposed means

for resolving any impediments identified.

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13.3.1.3 Technical Evaluation

In SSAR Section 13.3.2.1.2, the applicant stated that the road network surrounding the NAPS

site, which'includes the ESP site, can adequately accommodate-anticipated vehicular traffic.

This conclusion is based onhthe most recent ETE,'which uses Census 2000 data. SSAR

Section 13.3.2.2.2.j.3 states that the resulting ETEs are based on different population'areas

and weather conditions, and range from 85 to 105 min.

In SSAR Section 13.3.2, the applicant stated, in part, that the major features emergency plan

(i.e., SSAR Section 13.3) takes advantage of the emergency planning resources, capabilities,

and organization that Virginia Power has already established and currently maintains at the

ESP site. In response to RAI 13.3-3, the applicant confirmed that it had incorporated applicable

sections of the existing NAEP into the application, to the extent that the NAEP supports the

emergency planning descriptions in the application. This includes the ETE contained in

Appendix 10.8 to the NAEP. As a result,-the staff reviewed portions of the NAEP as part of its

review of the ESP application and based its evaluation of the emergency planning information

in the application on both SSAR Section 13.3 and relevant portions of the NAEP, including the

ETE.

The ESP site footprint consists of a portion of the NAPS site and is located near the existing

NAPS reactors. The boundary of the ESP site is entirely within the boundary of the existing

NAPS site. The staff has not identified any significant differences between the major features

proposed in the SSAR and the major features discussed in existing plans and relied on in the

SSAR. The staff finds that, for purposes of identifying physical characteristics that could pose a

significant impediment to developing emergency plans, there is no distinction between'the

existing NAPS site and the ESP site. Because the existing NAPS site includes the ESP site,

the staff finds that the applicant's use of the ETE for the NAPS site in the ESP application is

acceptable and appropriate. . -

In RAI 13.3-11, the staff asked the applicant to address possible changes to this determination,

as it relates to the ESP site, including the duration of the ESP itself. In its response, the

applicant stated that the ETE identifies no areas of congestion and that travel time is relatively

inelastic with respect to anticipated changes in road capacity. Further, SSAR Section 21.3

provides population projections and suggests'that population increase will be gradual over time.

Planning and consideration of new roads or modifications of existing roads and intersections

could offset any large influx of new permanent or transient populations within the 1 0-mile EPZ.

In response to RAI 13.3-9, the applicant stated that it had not identified any physical

characteristics unique to the North Anna ESP site that could pose a significant impediment to

the developmnent of emergency'plans for the ESP site, and that the ETE identified no areas of

congestion during the evacuation'evaluation. The ETE, which reflects Census'2000 data,

considers permanent residents, transients, and persons in special facilities,' including school

populations.> Population increases over the duration of the ESP-are projected to be gradual,

and new or modified roads and intersections could offset any large influx of new permanent or

transient populations within the .10-mile EPZ. Accordingly, the staff finds that the applicant's

conclusion that it found no significant impediments is acceptable, and no physicalcharacteristics' unique to the proposed ESP site have been identified that could pose asignificant impediment to the development of emergency plans for the ESP site.

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13.3.1.4 Conclusions

As discussed above, the applicant has shown through use of the ETE that no physical

characteristics unique to the proposed ESP site could pose a significant impediment to the

development of emergency plans. Based on its review as set forth above, the staff concludes

that the information the applicant provided is consistent with the guidelines in RS-002 and

Supplement 2. Therefore, the information is acceptable and meets the requirements of 10 CFR

52.17(b)(1) and 10 CFR 52.18.

13.3.2 Contacts and Arrangements with Local, State, and Federal Agencies

13.3.2.1 Technical Information in the Application

SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with

existing State and local emergency plans. The SSAR, therefore, relies on and refers to the

information contained in these existing plans. The applicant did not identify any significant

differences between the major features of emergency plans proposed in the application and the

major features discussed in existing plans and, therefore, relied on this information in the

application. SSAR Section 13.3.3 lists the 19 Federal, State, and local government agencies

with emergency planning responsibilities in support of NAPS. In addition, the applicant stated

the following:

Dominion provided an overview of the ESP project to DEM [Commonwealth of

Virginia Department of Emergency Management (VDEM)] staff members on

February 20, 2003 and to risk jurisdiction coordinators of emergency

management on March 24, 2003. The NRC licensing process, emergency

preparedness requirements for ESP applicants, and Dominion's schedule for

preparing and submitting this ESP application [for North] Anna were described at

both meetings. During the discussions regarding the ESP process, no

impediment to pursuing an ESP was identified by Commonwealth of Virginia or

risk jurisdiction response organizations.

SSAR Section 1 3.3.2.2.2.a.6 provides a nearly identical statement to the above. SSAR

Section 13.3.2.2.2.a.6 further states that the existing licensed facilities (i.e., North Anna Units 1

and 2) maintain, within the NAEP, letters of agreement with the U.S. Department of Energy

(DOE), Commonwealth of Virginia agencies, and various local agencies.

In RAI 13.3-1, the staff asked the applicant to document its arrangements with Federal, State,

and local government agencies with emergency planning responsibilities that specifically

address the impacts of an additional reactor(s) at the ESP site, in particular, how these

arrangements address any impact that an additional reactor(s) at the North Anna site would

have on government agency emergency planning responsibilities. The staff also asked the

applicant to provide acknowledgment by the agencies of these proposed expanded I

responsibilities (if any). In its response, the applicant provided letters of agreement from the

19 agencies with which Dominion Resources has existing agreements for the NAPS, which had

been revised to specifically acknowledge the agencies' awareness of the ESP application for

the NAPS site. In addition, the letters state that the existing agency arrangements would apply

to a prospective additional reactor(s) at the NAPS site.

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13.3.2.2 Regulatory Evaluation

In SSAR Section 13.3.1, the applicant stated that SSAR Section 13.3 presents information

required by 10 CFR 52.17(b)(3) regarding descriptions of contacts and arrangements that the

applicant has made with Federal, State, and local government agencies with emergency

planning responsibilities. ; '

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(3), which mandate, in part, that an' ESP application describe the contacts and

arrangements made with Federal, State, and local gov`rnment'agencies with' emergency

planning responsibilities. Supplement 2 and RS-002 provide guidance concerning the review

and evaluation of emergency planning information given in an ESP application.

Supplement 2 states that the description of contacts and arrangements should include the

name and location of the organization contacted, the title and/or position of the person(s)

contacted, and the role of the organization' in' emergency planning. The evaluation criteria in

Supplement 2, Section V, provide additional guidance, which applies to the submission of'

emergency plans under the major features option of 10 CFR 52.1 7(b)(2)(i).

According to RS-002, for an operating reactor site, the ESP application should clearly indicate

the impact of applying an existing emergency preparedness program element to the'expanded

use of the site, including addressing any necessary changes to the, program in support of a new

reactor(s). For example, letters of agreement, reflecting contacts and arrangements made with

State and local government agencies with emergency planning responsibilities, might need

revision to reflect the anticipated presence of an additional reactor(s) at the site. Such revised

letters of agreement should reflect any impact an additional reactor(s) would have on the

agencies' emergency planning responsibilities and should include acknowledgment by the

agencies of the proposed expanded responsibilities. The use of separate correspondence

would also be acceptable. If the applicant cannot'make arrangerments with Federal,-State, or'

local government agencies with emergency planning responsibilities, for whatever reason, the

applicant should discuss its efforts to make'such arrangements, along with a description of any

compensatory measures it has taken or plans to take becausb'of the lack of such

arrangements.

13.3.2.3 Technical Evaluation ..

According to SSAR Section 13.3.3, the applicant conducted two meetings with the State'and

the risk jurisdictions (Hanover, Louisa, Orange, Spotsylvania, and Caroline Counties) to provide

an overview of the ESP process 'for the NAPS site.1 The applicant further stated that, during

the meetings, neither the State nor the risk jurisdiction response organizations identified any

impediment to pursuing an ESP.

The applicant has provided current letters of agreement that describe the contacts and

arrangements it has made with Federal, State, and local government agencies with emergency

planning responsibilities and which address their receipt and understanding of the ESP

application for the NAPS site. These letters adequately describe the names and locations of

1Risk jurisdictions are counties, any part of which lie within the 10-mile EPZ.

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the organizations contacted, the titles and/or positions of the persons contacted, and the roles

of the organizations in emergency planning for the ESP site. The letters of agreement also

describe the arrangements for the specific support that would be provided, stating that the

existing arrangements would apply to a prospective additional reactor(s) at the ESP site.

Accordingly, the staff finds that the revised letters of agreement provided in response toRAI 13.3-1 are acceptable. Further, the staff finds that the Dominion presentations to the State

and the risk jurisdictions, combined with the revised letters, adequately reflect an

understanding, acknowledgment, and agreement by offsite agencies of their specific

responsibilities with respect to constructioon and operation of a prospective additional reactor(s)

at the NAPS site under an ESP. Sections 13.3.3.2, 13.3.3.3, 13.3.3.4, 13.3.3.7, 13.3.3.10,

13.3.3.11, and 13.3.3.13 of this SER provide additional descriptions of contacts and

arrangements in support of the NAPS site that are relevant to the application.

13.3.2.4 Conclusions

As discussed above, the applicant has provided an acceptable description of contacts and

arrangements made with Federal, State, and local government agencies with emergency

planning responsibilities. Based on its review as set forth above, the staff concludes that the

information the applicant provided is consistent with the guidelines in RS-002 and

Supplement 2. Therefore, the information is acceptable and meets the requirements of 10 CFR

52.17(b)(3).

13.3.3 Major Features of the Emergency Plans

13.3.3.1 Emergency Planning Zones

13.3.3.1.1 Technical Information in the Application

SSAR Section 13.3.2 states that the proposed emergency plan takes advantage of the

emergency planning resources, capabilities, and organization that Virginia Power has already

established and currently maintains at the NAPS site. The applicant would extend the existing

emergency planning and preparedness activities to include the proposed new unit(s). SSAR

Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with existing

State and local emergency plans. The SSAR, therefore, relies on and refers to information

contained in these existing plans. There are no significant differences between the major

features proposed in the application and the major features discussed in existing plans and

relied on in the application.

SSAR Section 13.3.2.2.1 states that the applicant has developed the emergency plan assuming

a plume exposure pathway EPZ of about 10 miles in radius (10-mile EPZ) and an ingestion

pathway EPZ of about 50 miles in radius (50-mile EPZ). The 10-mile and 50-mile EPZs

identified in the ESP application are the same as those in the NAEP.

SSAR Section 13.3.2.2.1 further states that the size of these areas is subject to change if

warranted by later analyses, design-specific factors, and legislation or regulatory initiatives. In

SSAR Section 13.3.4,,the applicant stated that the possible application of analyses performed

subsequent to NUREG-75/014, "Reactor Safety Study: An Assessment of Accident Risk in

U.S. Commercial Nuclear Power Plants," issued October 1975 (known as the WASH-1 400

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report), design-specific factors, arid legislative or regulatory initiatives may affect the size of the

10-mile and 50-mile EPZs.

Section 5.4.6 of the NAEP identifies Louisa and Spotsylvania Counties as directly involved in -

the NAEP, since they include the majority of the area within the 10-mile EPZ. NAEP Table 5.3

lists the counties and cities within the 50-mile EPZ. NAEP Section 6.3, "Protective Actions,".

states that no' hospitals, prisons, or nursing homes currently exist within the 10-mile EPZ

(shown in NAEP Figure 6.1).' Appendix 10.8 to the NAEP incorporates' the ETE by reference.:

ETE Secti6n '12, "Emergency Planning Zone," describes the 25 PAZs that the NAPS licensee

has established within the 10-mile EPZ. In"demarcating these zones, the-NAPS licensee used

prominent physical features, either natural (e.g., rivers) or manmade (e.g., roads) to make the.

PAZs readily comprehensible to the area's residents in the event of a radiological emergency.

The demarcations of the zones are roughly 2, 5, and 10 miles from the nuclear facility, which

permit flexibility and selectivity in the application of protective actions.

ETE Section 4.4, "Estimates for Special Facilities," states that the only special facilities located

within 10 miles of the NAPS site are the schools identified in ETE Table 7, "School Population

and Transportation'." ETE Table 7 lists seven schools, with a total day population of 6471 ETE

Section 3.0, "ETE Data and Methodology," indicates that the applicant defined the evacuation

network based on the information documented in and provided through the Dominion

Resources public outreach program, which includes calendars distributed by the company and

information available on the company's Web-site.

13.3.3.1.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and it considered

the guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria-applicable to a major features emergency plan., -

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i) and 10 CFR 52.18. In addition,'the staff considered the regulatory requirements

in 10 CFR 50.33(g), 10 CFR 50.47(c)(2), and Sections I, III, and IV of Appendix E to 10 CFR - -

Part 50 in its review of the size and configuration of the EPZs.yUnder 10 CFR-52;17(b)(2)(i), an

applicant for an ESP may propose rnajor features of the emergency plans for NRC review and

approval, in consultation with FEMA, in the absence of complete and integrated emergency

plans. Under 10 CFR 52.18, after consultation with FEMA, the NRC will determine whether the

major features of emergency plans submitted under 10 CFR 52.17(b)(2)(i) are acceptable..

RS-002 and Supplement 2 provide guidance concerning the review and evaluation of

emergency planning information given in an ESP application. Supplement 2 also provides

specific evaluation criteria for the major features of emergency plans, including those which

apply to determining the size and configuration of the EPZs.

Section lll.Aof Supplement 2 states that an ESP applicant choosing the option of proposing

major features of the e'rngency plans'sho'6d give special emphasis to the exact size of the

EPZs. Gen6rally, the 1 0mie 'and 50-mile EPZs consist of an area about 10 miles and 50 miles

in radius, respectively. Applicants'should determine the exact size and configuration of the

EPZs with respect to local erergency response needs and capabilities, since the EPZs can be

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affected by conditions such as demography, topography, land characteristics, access routes,

and jurisdictional boundaries.

13.3.3.1.3 Technical Evaluation

SSAR Section 13.3.2 states that the ESP emergency plan takes advantage of the existing

NAEP and that the applicant would extend the NAEP to include the proposed new unit(s). As

such, this extension would include the existing NAPS 10-mile and 50-mile EPZs. The ESP'site

footprint consists of a portion of the NAPS site and is located near the existing NAPS reactors.

The boundary of the ESP site is entirely within the boundary of the existing NAPS site.

Therefore, the staff finds that, for the purposes of determining the exact size and configuration

of the EPZs in relation to local emergency response needs and capabilities, no distinction

between the NAPS site and the ESP site exists. As such, the staff finds that use of the existing

NAPS 1 0-mile and 50-mile EPZs for the ESP site is appropriate and acceptable. The ESP

application, the NAEP (including calendars distributed to the public), and the ETE reflect the

existing NAPS 10-mile and 50-mile EPZs.

SSAR Sections 13.3.2.2.1 and 13.3.4 state that the size of the EPZs may be subject to change

as a result of design-specific factors and legislative or regulatory initiatives. The staff did not

consider the possibility of change in the size requirements for the 1 0-mile and 50-mile EPZs

essential to its review. Rather, the staff applied current requirements. A COL or OL applicant

should address any such policy or regulatory changes, as well as design-specific matters, and

the staff will determine compliance with the requirements in these areas during a COL or OL

review.

As stated in NAEP Section 6.3, no hospitals, prisons, or nursing homes are located within the

1 0-mile EPZ. ETE Section 3.0 further states that the applicant defined the evacuation network

based on information documented in calendars distributed as part of a public outreach program.

The calendars provide an area map and a listing of PAZs and evacuation assembly centers

(EACs), which is consistent with the information in the application and the ETE.

ETE Section 1.2 states that the PAZs established within the 1 0-mile EPZ use prominent

physical features, either natural or manmade, to outline the PAZ boundaries. In addition, the

applicant selected the PAZs based on existing political boundaries. The staff, through its

review of the ETE, did not identify any 1 0-mile EPZ boundaries that run through'the middle of

schools or hospitals, or that arbitrarily carve out small portions of government jurisdictions. As

such, the staff finds that the size and configuration of the 1 0-mile and 50-mile EPZs reflect local

emergency response needs and capabilities, as they are affected by conditions such as.
10 CFR 50.33(g), 10 CFR 50.47(c)(2), 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and Sections l, IlIl,

and IV of Appendix E to 10 CFR Part 50, insofar as'it describes the essential elements of

advanced planning that have been considered for the emergency planning zones, as set forth

above.

13.3.3.2 Assignment of Responsibility-Organization Control (Supplement 2, Major Feature A)

13.3.3.2.1 Technical Information in the Application

SSAR Section 13.3.2.2.2.a identifies organizations that are intended to be part of the overall

emergency response organization (ERO). This section describes the primary responsibilities

for the risk jurisdiction response organizations, the Commonwealth of Virginia, the Federal

Government, and private sector organizations. -As stated in SSAR Section 13.3.2.2.2.a.1, the -

elected officials of local governments have the' responsibility for radiological emergency

response within their jurisdictions. The existing county RERPs apply to radiological -

emergencies within the localities caused by events'at the NAPS site and would apply to events

at the ESP site. SSAR Sectionr 1 3.3.2.2.2.a.5 as well as the COVRERP and county RERPs

also address the emergency response functions and responsibilities. The RERPs detail the

legal bases for these authorities.

SSAR Section 13.3.2.2.2.a.2 states that the Commonwealth of Virginia's organization for

responding to radiological emergencies is based on normal government structures and

channels of communication. The Governor, in the role of Director of Emergency Management,

directs the emergency response through the State coordinator of emergency management.

The State coordinator of emergency management coordinates the overall response, and the

Virginia Department of Health (VDH) provides technical advice and assistance on radiological

accident assessment, protective action, radiological control, and radiological monitoring.-

SSAR Section 1 3.3.2.2.2.a.3 states that, in the event an emergency classification is made

pursuant to the emergency action levels (EALs), Dominion would make notifications, as - -I

described in SSAR Section 1 3.3.2.2.2.e. Further, Dominion personnel would maintain contact

with the NRC to ensure that the Federal Government has access to accurate information about

and an assessment of the emergency. SSAR Section 13.3.2.2.2.c describes the details of

Federal assistance.

SSAR Section 13.3.2.2.2.a.4 states that Dominion would obtain support from the cognizant

architect/engineer, the nuclear steam' supply system vendor,' and other consultants and

vendors, as appropriate,' to respond during the emergency and recovery operations.

Experienced personnel with indepth expertise in plant design, engineering, and construction

would be involved to aid in solving critical technical problems. The applicant stated that a COL

or CP applicant would identify these consultants and vendors, as necessary, in the COL or CP

application. Private sector response may also include radiological laboratories and other

facilities and organizations, as described in' SSAR Section 1 3.3.2.2.2.c.'

SSAR Section 13.3.2 states that the major features emergency plan takes advantage of the

emergency planning resources, capabilities, and organization that Virginia Power has already

established and currently maintains at the NAPS site. NAEP Section 5.3, "Augmentation of

Onsite Emergency Organization," and Section 5.4, "Coordination with Participating Government

Agencies," identify specific Federal, State, and local agencies and private sector organizations

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iEs

that are either directly involved, in emergency response in support of the NAPS site or can be

called upon to provide assistance. NAEP Figure 5.4, "Station to Support Group Interface

Following LEOF Activation," shows functional interfaces.

SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with

existing State and local emergency plans. The SSAR, therefore, relies on and refers to the

information contained in these existing plans. No significant differences exist between the

major features proposed in the application and the major features discussed in existing plans

and relied on in the application.

The COVRERP and county RERPs identify the response organizations for the jurisdictions.

Appendix 1, "Task Assignments," to the COVRERP provides a detailed listing of specific tasks

that various Federal, State, and local agencies and organizations would be responsible for in a

radiological emergency. Section X, Volume 1, of the "Commonwealth of Virginia Emergency.

Operations Plan," and Annex I-A, "Task Assignments," to Volume II of the 'Commonwealth of

Virginia Emergency Operations Plan-Peacetime Disasters," provide additional responsibilities.

The VDEM would coordinate requests by Dominion for support services from these agencies

and organizations.

Section l.A, "Authorities," of the COVRERP lists the legal bases of authority as

(1) Commonwealth of Virginia Emergency Services and Disaster Law of 1973, Title 44,

Chapter 3.2, Code of Virginia, as amended, and (2) Radiation Control Act, Title 32.1, Chapter 6,

Article 8, Code of Virginia. The county RERPs also list these two legal bases, in addition to

their respective local enabling ordinances, which provide for the development of local

emergency operation plans and support organizations.

SSAR Section 13.3.2.2.2.a.6 states that the existing licensed facilities (i.e., North Anna Units 1

and 2) maintain letters of agreement with various Federal, State, and local organizations. All

the organizations listed in SSAR Section 13.3.2.2.2.a.6 have submitted updated letters of

agreement which acknowledge the ESP application and describe contacts and arrangements

pertaining to the concept of operations for the various agencies and organizations.

13.3.3.2.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.A of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

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includirig those which apply to major feature A, 'Assignment of Responsibility-Organization

Control."

Major feature A calls for the applicant to identify EROs, including functions and responsibilities

for major elements of response, and the legal bases for State and local authorities. The

application should also describe contacts and arrangements between agencies and other

support organizations having a response role within the EPZs, and it should include any written

letters of agreement. -

13.3.3.2.3 Technical Evaluation

SSAR Section 13.3.2.2.2 identifies Federal, State, local, and private agencies and

organizations that the applicant intends to be part of the overall ERO, as well as detailed

functions and responsibilities for the major elements of emergency response for each agency

and organization. The NAEP,'COVRERP, and county RERPs supplement this information with

additional details regarding specific emergency responsibilities. The staff finds that this

description is adequate because it identifies the applicable response organizations and provides

detailed descriptions concerning their various response capabilities.

The staff reviewed the COVRERP and county RERPs and finds that they include references to

the specific acts, codes, or statutes that form the legal bases for their respective authorities.

SSAR Section 13.3.2.2.2.a.6 lists the various Federal, State, and local organizations that have

submitted updated letters of agreement in support of the NAPS site,-which includes the ESP

site. Accordingly, the staff finds that these letters of agreement are adequate. Sections 13.3.2,

13.3.3.3, 13.3.3.4, 13.3.3.7, 13.3.3.10,13.3.3.11, and 13.3.3.13 of this SER describe contacts

and arrangements pertaining to the concept of operations developed among Federal, State,

and local agenrcies and other support organizations having an emergency response role within

the EPZs.

13.3.3.2.4 Conclusions

As discussed above, the applicant has identified the EROs, including the functions and

responsibilities for major elements of response, and the legal bases for State and local

authorities. In addition, the applicant has described contacts and arrangements among the - agencies and other support organizations having a response role within the EPZ. Based on its

review, the staff concludes that the proposed major feature A is consistent with the guidelines in

RS-002 and Supplement 2.' Therefore,'this feature is acceptable and meets the requirements

of 10 CFR52.17(b)(2)(i),10 CFR 52.18, and Sections il and IV.A of Appendix E to 10 CFR

Part 50, insofar as it describes the essential elements of advanced planning that have been -

considered for organization control, as set forth above. -

13.3.3.3 Onsite Emergency Organizations (Supplement 2, Major Feature B)

13.3.3.3.1 Technical Information in the Application -

SSAR Figure 13.3-3 illustrates the interfaces for the functional areas of emergency activity. :In

addition, SSAR Section 13.3.2 states that the applicant's emergency plan takes advantage of

the emergency planning resources, capabilities, and organization that Virginia Power has

already established and currently maintains at the NAPS site. The applicant stated that it would

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'II

extend the existing emergency planning and preparedness activities to the proposed new

unit(s). SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear

facility with existing State and local emergency plans. The SSAR, therefore, relies on and

refers to the information contained in these existing plans. No significant differences exist

between the major features proposed in the application and the major features discussed in

existing plans and relied on in the application.

NAEP Section 5.4, "Coordination with Participating Government Agencies," provides further

details associated with the-existing interfaces for functional areas of emergency activity and

includes applicable group interface block diagrams in NAEP Figures 5.3 and 5.4.

SSAR Section 13.3.2.2.2.b.2 states that the existing units (i.e., North Anna Units 1 and 2)

maintain agreements for police; firefighting, rescue squad, medical, and hospital services and

that these agreements would apply to the ESP site. Appendix 10.1 to the NAEP contains

letters of agreement with various Federal, State, and local organizations. As discussed in

Section 13.3.2 of this SER, the staff asked the applicant, in RAI 13.3-1, to explain how the

existing arrangements address any impact that an additional reactor(s) at the site would have

on government emergency planning responsibilities. In its response, the applicant provided

letters of agreement, which had been revised to specifically acknowledge an awareness by

support agencies of the ESP application for the NAPS site, and to state that the existing agency

arrangements would apply to a prospective additional reactor(s) at the NAPS site.

13.3.3.3.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.A of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for the major features of emergency

plans, including those which apply to major feature B, "Onsite Emergency Organizations."

Major feature B calls for the applicant to identify interfaces between and among the onsite

functional areas of emergency activity, local services support, arid State and local government

response organizations, including the services to be provided by local agencies.

13.3.3.3.3 Technical Evaluation

The applicant identified the interfaces for the functional areas of emergency activity in SSAR

Figure 13.3-3, which depicts a block diagram connection between the onsite station facilities

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and the offsite Federal, State, and local EROs. In addition to the block diagram illustration, the

applicant gave detailed descriptions throughout SSAR Section 13.3.2.2.2 of the functional

interfaces and support that various Federal,'State, and local entities would provide.

SSAR Section 1 3.3.2.2.2.b.2-states that the existing units (i.e.; North Anna Units 1 and 2)

maintain agreements for police, firefighting, rescue squad, medical, and hospital services and

that these agreements would apply to the'ESP site'.' In addition, SSAR Section 1 3.3.2.2.2.a.6

states that these letters of agreement are maintained within the NAEP.

The staff reviewed the NAEP and found that NAEP Section 5.4 gives further details associated

with the'existing interfaces for the functi6nal areas of emergency response, including various

related services that would be provided. In addition, NAEP Figures 5.3 and 5.4 provide

comparable block diagrams which illustrate'these functional interfaces. The staff finds that this

information adequately identifies the interfaces between and among the onsite functional areas

of emergency activity, local services support, and State and local government response

organizations. ' -

The staff also reviewed the existing letters of agreement in Appendix 10.1 to the NAEP, which

provide additional descriptions of specifidc cpabilities and various onsite and offsite

organizational interfaces. As discussed in Section 13.3.2 of this SER, the letters of agreement

were updated to reflect that the existing arrangements would apply to adprospective additional

reactor(s) at the NAPS site, consistent with the application. Accordingly, the staff finds that the

information given in SSAR Section'13.3.2.2.2, the NAEP, and the updated letters of agreement

adequately identify the services to be provided by local agencies for handling emergencies,

including a description of the arrangements for such services.

13.3.3.3.4' Conclusions

As discussed above, the applicant has identified the interfaces between and among the onsite

functional areas of emergency activity, local services support, and State and local government

response organizations for the ESP site. In addition, the applicant has identified the services

*and described the arrangements to be provided by various local agencies, and it has submitted

adequate letters of agreement. Based on its'review, the staff concludes that the proposed

major feature B is consistent with the guidelines in RS-002 and Supplement 2. Therefore, this

feature is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections il 'and IV.A of Appendix E to 10 CFR Part 50, insofar as it'd6scribes the essential..

elements of advanced planning that have been considered for the onsite ERO, as set forth

above.

13.3.3.4 Emrergency Response Support and Resources (Supplement 2, Major Feature C)

13.3.3.4.1 Technical Information in thenApplication ! ' 

SSAR Section 1 3.3.2.2.2.c states that'circurnstances prompting the implementation of an

emergency response may necessitate augmentation of Dominion's resources. -Dominion may,-

request such'assistance froin'the'Federal Government, radiological laboratories, and nuclear or

other facilities and organizations.

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SSAR Section 13.3.2.2.2.c.1 states that the Federal Response Plan (FRP) provides the

mechanism for coordinating the delivery of Federal assistance and resources to augment

efforts of State and local governments overwhelmed by a major disaster or emergency. The,

FRP supports implementation of the Robert T. Stafford Disaster Relief and Emergency

Assistance Act (42 U.S.C. § 5121, et seq.), as well as individual agency statutory authorities,

and supplements other Federal emergency operations plans developed t6 address specific

hazards. The U.S. Department of Homeland Security has primary responsibility for

coordinating Federal emergency preparedness, planning, management, and disaster

assistance functions, including the establishment of Federal disaster assistance policy.

In addition, the Federal Radiological Emergency Response Plan (FRERP) outlines the Federal

Government's concept of operations for responding to radiological emergencies. This plan also

describes Federal policies and planning considerations which form the basis for the FRERP

concept of operations and agency-specific Federal response plans. The FRERP also specifies

the authority and responsibility of each Federal agency that may have a significant role in such

emergencies. Under the provisions of the FRERP, DOE may respond to a State or lead

Federal agency request for assistance by dispatching a radiological assistance program (RAP)

team. If the situation warrants more assistance than a RAP team can provide, DOE would alert

or activate additional resources. These resources may include the establishment of a Federal

Radiological Monitoring and Assessment Center (FRMAC) to be used as an on-scene

coordination center for Federal radiological assessment activities.

NAEP Section 5.4.7, "Federal Radiological Monitoring and Assessment Center (FRMAC)

Operations Plan," states that the FRMAC may be activated when a major radiological'

emergency exists. The Federal Government would respond when a State, other government

entity with jurisdiction, or a regulated entity requests Federal support. The station emergency

manager, recovery manager, or corporate response manager may request FRMAC assistance

directly or through the NRC (as lead Federal agency).

SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with

existing State and local emergency plans. The SSAR, therefore, relies on and refers to the

information contained in these existing plans. No significant differences exist between the

major plan features proposed in the application and those discussed in existing plans and relied

on in the application.

COVRERP Section VII, "Organization," states that Federal response teams represented in the

emergency operations facility (EOF), State emergency operations center (EOC), and/or other

locations would support the State organization. Additional Federal assistance may be obtained

through the State EOC from (or through) DOE, the NRC, and FEMA. Section l.E, "Department

of Emergency Management," of Appendix 1 to the COVRERP states that VDEM would notify all

other State agencies and support organizations which have emergency task assignments

identified in the COVRERP. In addition, VDEM would request assistance from the Federal

Government in accordance with the FRERP. Section II, "Federal Agencies," of Appendix 1 to

the COVRERP provides further detailed descriptions of available Federal resources, as well as

the procedures for requesting assistance. -The county RERPs state that local requests for

Federal assistance would be made through the State EOC. In addition, the county RERPs

identify the facilities and organizations that would provide assistance in an emergency and the

positions that are responsible for contacts and arrangements with other organizations.

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SSAR Section 13.3.2.2.2.c.2 identifies the radiological count laboratory resources that are

available through the Commonwealth of Virginia to respond to emergencies at the NAPS site.

This section also provides estimated travel times to the NAPS site for each laboratory. If

necessary, additional resources could be obtained through'purchase agreements with private

institutions. The'following list is consistent with NAEP Section 5.3.2, "Vendor and Contractor

Support":

* The University of Virginia, Charlottesville, Virginia (45 min)

* Virginia Commonwealth Laboratories, Richmond, Virginia'(75 min)

* Medical College of Virginia, Richmond, Virginia (75 min)

* Newport News Shipbuilding & Drydock, Newport News, Virginia (3.5 hours)

* VDH Radiological Health Program Mobile Laboratory (60 min)

COVRERP Section VII.C states that VDEM coordinates the overall emergency response, while

VDH (through the Bureau of Radiological Health (BRH)) provides technical advice and

assistance on radiological exposure control and radiological mbnitoring. 'Appendix 4,

"Emergency Response," to the COVRERP states in Section'll, "Operational Concepts and

Procedures," that, when notified, BRH initiates accident assessment to provide guidance'and

assistance to the local government and the State EOC. BRH would perform accident

assessment, monitoring, and sample collection.

Appendix 5, 'Accident Assessment," to the COVRERP states that the State Radiological

Emergency Response Team (RERT) has a mobile laboratory which can be operational onsite

within 3 hours of notification and is capable of 24-hour operation. The mobile lab would be -

positioned at one of the staging areas located near the nuclear station. Personnel from the

nuclear facility or a Federal agency may supplement the RERT. Local governments would

conduct radiological monitoring in accordance with their county RERPs and report the results to

the EOF.

SSAR Section 13.3.2.2.2.c.4 addresses contacts and arrangements for assistance from the

various response organizations. Personnel within the EOF would coordinate'outside''

assistance, which would include interfaces with all levels of government, private sector

response organizations, and other commercial nuclear operators. In addition to prearranged

support, contacts and arrangements for assistance from Federal Government, radiological

laboratories, and nuclear or other facilities and drganizations'could be requested, if

circumstances prompting the implementation of an' emergency response necessitated

augmentation of Dominion's resources.

NAEP Section 5.3, "Augmentation of Onsite Emergency Organization," states that assistance

may be requested fr m any organization 'deemed necessary to mitigate the conditions causing

the emergency, and Appendix 10.1, "Letters of Agreement," to the NAEP lists participating

agencies and support services, with whom emergency support services have been negotiated.

Appendix 10.1 ito the NAEP contains letters of agreement for two of the five listed radiological

laboratory resources '(i.e., the Medical College of Virginia Hospitals and Physicians/Virginia

Commonwealth University (MCVHNCU) a'nd VDH). '

The letter of agreement for the MCVHNCU states that the "Radiation Emergency

Plan-MCVHNCU-Virginia Power" outlines its 24-hour services in greater detail:

Appendix 10.9 to the NAEP references'the February 16, 2000, revision of the plan. This plan

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I 11M

addresses the capabilities for providing medical care for radiation emergencies in the central

Virginia region and supports the Dominion Resources nuclear reactor stations in the event of

occupational or major accidents; this would include the ESP site. In addition, the letter of

agreement lists specific services that would be provided, upon verification of an emergency at

the ESP site, and includes treatment of injured and radioactively contaminated patients, monitoring and counting equipment for the detection and analysis of radioactivity or radiation,

and decontamination supplies.

The letter of agreement with VDH outlines its commitment to respond to any radiological

emergency at NAPS, with VDEM serving as lead agency for the Commonwealth under the

framework of the COVRERP. As reflected on the VDH Web site, the Radiological Health

Program administered by VDH has'an RERT equipped with field instrumentation for monitoring radiation and a mobile laboratory for performing laboratory analysis, so that a rapid assessment

of a radiological incident can be made and appropriate recommendations provided to State and

local officials. The Radiological Health Program maintains a 24-hour duty officer who is

available to respond to any radiological incident or to request additional resources, if needed.

The Radiological Health Program's emergency preparedness activities are coordinated with

VDEM, which is responsible for the coordination of the State's response and the State

emergency plan.

SSAR Section 1 3.3.2.2.2.i addresses contacts and arrangements for assistance associated

with accident assessment; SSAR Section 13.3.2.2.2.1 provides contacts and arrangements for

medical and public health support. In addition, consistent with the application, the NAEP

addresses contacts and arrangements with vendor and contractor support in NAEP

Section 5.3.2, local services support in NAEP Section 5.3.3, and participating government

agencies in NAEP Section 5.4. Sections 13.3.2, 13.3.3.2, 13.3.3.3, 13.3.3.10, and 13.3.3.13 of

this SER also describe contacts and arrangements made with emergency response support

organizations.

SSAR.Section 13.3.2.2.2.c identifies radiological laboratories and their general capabilities and

expected availability to provide radiological monitoring and analyses services during an

emergency. In RAI 13.3-4, the staff asked the applicant to clarify the listing of radiological

count laboratory resources in SSAR Section 13.3.2.2.2.c.2, in regard to whether additional

resources exist beyond the five listed that could be obtained on an as-needed basis. In

addition, the staff asked the applicant to identify the general capabilities and expected

availability to provide radiological monitoring'and analyses services during an emergency in

support of the ESP site for (1) the University of Virginia, Charlottesville, Virginia, (2) Virginia Commonwealth Laboratories, Richmond, Virginia, and (3) Newport News Shipbuilding &

Drydock, Newport News, Virginia. In its response, the applicant stated that the listing of private institutions is a sampling of relatively nearby sources of assistance and that, if such assistance

should be needed, it would be procured in a timely manner from any available source.

In addition, the applicant stated that the University of Virginia has a level-one trauma center'and

teaching hospital. Its Office of Environmental Health and the Radiation Safety manages all'

aspects of the use of radioactive materials and radiation-producing equipment. The Virginia Commonwealth Laboratories provide analytical testing services and may be called on to

respond to various health and environmental emergencies in Virginia. Its Bureau of Analytical Services performs analytical testing for State regulatory, environmental, and public health

programs. It also has laboratories that can analyze water, sediment, tissue, air, soil, and other

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samples for the presence of metals and radiation. Finally, Newport News Shipbuilding & Dry

Dock is the nation's sole desigri6r, builder, and refueler of nuclear-powered aircraft carriers. It

has the necessary staff and facilities to support radiological surveys, monitoring, and analysis

functions; it has provided services to more than half of the country's nuclear utilities.

In RAI 13.3-14(a), the staff asked the applicant for more information regarding the availability

and capability of laboratories referred to in the State and local emergency plans. The applicant

responded to this RAI in its submittal dated October 20,.2004. The applicant stated that these

capabilities are outlined in Appendix 17.5 to the VDH Radiological Health Program's plan, which

addresses 24-hour availability, with the use of a large and small mobile lab in addition to fixed

facilities at the Division of Consolidated Laboratory Services.

13.3.3.4.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.1 7(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan..;

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections 1II, IV.A, IV.B, and IV.D of Appendix E to .10 CFR

Part 50. Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of

the emergency plans for NRC review and approval, in consultation with FEMA, in the absence

of complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with

FEMA, the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply to major feature C, 'Emergency Response Support and

Resources."

Major feature C calls for the applicant to describe contacts and arrangements for requesting

Federal assistance, as well as assistance from radiological laboratories and nuclear or other

facilities and organizations. The application should also identify the general capabilities and

expected availability of radiological monitoring and analysis services.

13.3.3.4.3 Technical Evaluation

SSAR Section 13.3.2.2.2.c describes the basic Federal emergency response plans that could

be called upon to assist the licensee, as well as those of the State and local governments.

SSAR Section 13.3.2.2.2.c.3 addresses assistance from other facilities and organizations,

including Dominion Resources and its subsidiaries, Virginia Power and Dominion, and the

Institute of Nuclear PowerOperations. The Surry Power Station in Virginia and the Millstone

Power Station in Connecticut can also provide assistance. In addition, Federal agencies and

various radiological laboratories, as identified in SSAR Section 13.3.2.2.2.c, can provide

assistance. NAEP Sections 5.3.2, 5.3.3, and 5.4 also identify sources of assistance in an

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emergency. Section 13.3.2 of this SER discusses the associated description of contacts and

arrangements made with response organizations.

In RAI 13.3-14(a), the staff asked for information regarding the availability and capability of

laboratories referred to in State and local emergency plans. The staff identified the

consideration of this information as Open Item 13.3-1. The staff reviewed the applicant's

response dated October 20,'2004, and finds it acceptable. Therefore, Open Item 13.3-1 is

resolved. The staff finds that the applicant has adequately described the provisions. that exist

for requesting emergency response support and resources.

13.3.3.4.4 Conclusions

As discussed above, the applicant has described provisions for requesting Federal assistance,

and it has identified nuclear and other facilities and organizations that can be relied on to

provide assistance in an'^emergency, including the general capabilities and availability of

radiological laboratories. In addition', the applicant has described the contacts and

arrangements made with the response organizations.- Based on its review, the staff concludes

that the proposed major feature C is consistent with the guidelines in RS-002 and

Supplement 2. Therefore, this feature is acceptable and meets the requirements of 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.B, IV.C, IV.D, and IV.E of Appendix E to

10 CFR Part 50, insofar as it describes the essential elements of advanced planning that have'

been considered for emergency response support and resources, as set forth above.

13.3.3.5 Emergency Classification System (Supplement 2, Major Feature D)

13.3.3.5.1 Technical Information in the Application

SSAR Section 13.3.2.2.2.d states that the applicant would. use an emergency classification

scheme with the four classifications listed below in the event of an emergency. The applicant

would use EALs to determine when and what type of protective measures should be considered

within and outside the NAPS site boundary to protect health and safety. The applicant stated

that the COVRERP and local government RERPs would provide an emergency classification

level scheme consistent with that established by Dominion, as required by 44 CFR 350.5(a)(4).

This scheme includes the following classifications:

* notification of unusual event

* alert

* site area emergency

* general emergency

SSAR Section 13.3.2 states that the emergency plan takes advantage of the emergency

planning resources, capabilities, and organization that Virginia Power has already established

and currently maintains at the NAPS site. The applicant would extend the existing emergency

planning and preparedness activities to include the proposed new unit(s). SSAR

Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with existing

State and local emergency plans. The SSAR, therefore, relies on and refers to the information

contained in these existing plans. No significant differences exist between the major features

proposed in the application and the major features discussed in existing plans and relied on in

the application.

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COVRERP Section VII.A, uEmergency Classification Levels for Nuclear Facilities," and the

county RERPs provide an emergency classification scheme which is consistent with the four

classifications listed above. With regard to specific EALs, SSAR Section 13.3.2.2.2.d.1 states

that the COL or CP applicant would propose site-specific EALs in its COL or CP application and

that the COL or'CP applicant would discuss and agree to the EALs with the Commonwealth of

Virginia and local government authorities. The COL or CP applicant would then submit the

EALs to the NRC for approval.

13.3.3.5.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents,

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements of 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.C of Appendix E to 10 CFR Part 50.

Under 1O CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under -

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for the major features of emergency

plans, including those which apply to major feature D, 'Emergency Classification System."

Major feature D calls for the applicant to establish a standard emergency classification scheme

that is consistent with Appendix 1 to NUREG-0654/FEMA-REP-1. Major feature D also calls for

the State and local organizations to establish an emergency classification scheme that is

consistent with that proposed by the applicant. . -

13.3.3.5.3 Technical Evaluation

As stated in SSAR Section 13.3.2.2.2.d, the staff finds that the applicant would use an

emergency classification scheme consisting of the four classifications required by 44 CFR

350.5(a)(4). Based on its review, the staff finds that these four proposed emergency

classifications are consistent with those in Appendix 1 to NUREG-0654/FEMA-REP-1. The

staff also finds that the emergency classification schemes established by the State in - -

COVRERP, Section VII.A, and by the local organizations in the county RERPs are consistent

with that proposed by the applicant.

13.3.3.5.4 Conclusions

As discussed above,- the'applicant has specified a standard emergency classification scheme,

which is consistent with that set forth in Appendix 1 to NUREG-0654/FEMA-REP-1, and with

those established by the State and local EROs. Based on its review, the staff concludes that

the proposed major feature D is consistent with the guidelines in RS-002 and Supplement 2.

Therefore, this feature is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i),

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1XWf

10 CFR 52.18, and Sections III and IV.C of Appendix E to 10 CFR Part 50, insofar as it

describes the essential elements of advanced planning that have been considered for the

emergency classification system, as set forth above.

13.3.3.6 Notification Methods and Procedures (Supplement 2, Major Feature E)

13.3.3.6.1 Technical Information in the Application

SSAR Section 1 3.3.2.2.2.e describes the bases for notifying response organizations.

Reference is made to SSAR Section 1 3.3.2.2.2.d, which states that the initial classification

and declaration of an emergency class would be in accordance with the four categories of

an emergency classification scheme, which is consistent with Appendix 1 to

NUREG-0654/FEMA-REP-1. The normal process for alerting, notifying, and mobilizing the

ERO is multifaceted, including alarms, announcements, pagers, telephones, and online

messages. The applicant would make subsequent notifications, including providing specific

information pertaining to the emergency, to the Commonwealth of Virginia and the NRC and

would activate the Emergency Response Data System (ERDS). 2 Site personnel at NAPS, -

including security personnel and/or personnel from the Virginia Department of Game and Inland

Fisheries, would alert individuals within the NAPS exclusion area.3

In SSAR Section 13.3.2.2.2.e, the applicant further stated that the Commonwealth of Virginia

and local authorities, with the assistance of the Virginia State Police (VSP), would alert the

public within the 10-mile EPZ. The sounding of the alert and notification system (ANS) sirens

already installed around the NAPS site is the primary method of alerting the public. The

applicant stated that the existing ANS would support the new units. Other alerting methods

might include telephone communications; television and radio communications via the

emergency alert system (EAS) stations, public address systems, bullhorns from patrol cars,

and personal contacts.' The applicant also stated that written, preplanned messages would

be consistent with the emergency classification level scheme in Appendix 1 to :

NUREG-0654/FEMA-REP-1. The messages would give instructions on the nature of the

emergency and information concerning the recommended protective action, sheltering, thyroidblocking potassium iodide (KI), or evacuation.

SSAR Section 13.3.2 states that the emergency plan takes advantage of the emergency

planning resources, capabilities, and organization that Virginia Power has already established

and currently maintains at the NAPS site. The applicant would extend the existing emergency

planning and preparedness activities to include the proposed new unit(s). SSAR

2The ERDS is a direct, near real-time electronic data link between the licensee's onsite

computer system and the NRC Operations Center that provides for the automated transmission

of a limited data set of selected parameters (see Section VI.1 of Appendix E to 10 CFR

Part 50).

3The exclusion area refers to that area surrounding the reactor in which the reactor

licensee' has the authority to determine all activities, including exclusion or removal of personnel

and property from the area (see 10 CFR 50.2, "Definitions"). For purposes of the NAEP, the

area within 5000 feet (ft) of the former North Anna Unit 3 containment is defined as the NAPS

exclusion area (see NAEP Section 6.3.2).

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Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with existing

State and local emergency plans. The SSAR, therefore, relies on and refers to the information

contained in these existing plans. No significant differences exist between the major features

proposed in the application and the major features discussed in existing plans and relied on in

the application. ..- w- -

COVRERP Section Vill.C, "Notification and Warning," states that the notification and warning

process is based on the four emergency classifications (i.e., notification of unusual event, alert,

site area emergency, and general emergency). Section ll.B, "Procedures," of Appendix 3 to the

COVRERP describes procedures for notifying State agencies and risk jurisdictions, which are

then responsible for mobilizing emergency personnel according to task lists. The document

also provides authority for direct notification, should the Virginia EOC be unreachable. The

county RERPs describe the bases for notifying, alerting, and mobilizing emergency responders.

Appendix 1 to the county RERPs contains a detailed procedure of notification and mobilization

actions for emergency response personnel.

Section II.C, 'Public Alerting and Warning," of Appendix 3 to the COVRERP describes

procedures for public alerting and notifying. Primary responsibility for public alert and

notification resides with the State. This section also describes the process for notifying

transient populations and special facilities, including backup notification methods. The EAS

would be the primary method of providing public instruction.

Sirens do not cover Orange County and parts of the other risk jurisdictions. Section III.G, "Alert

and Waming Means," of the Orange County RERP describes the alert and notification

procedures that sheriff deputy cruisers (equipped with loudspeakers) would perform, backed up

by EAS broadcasts and telephone notifications. According to the RERP, State and local

officials would provide instructions using EAS broadcasts. In addition, State and local officials

would make special announcements to the three largest population centers by fax, telephone,

and EAS broadcasts, with internal route alerting by local police.

Section VIII.D of the Louisa County RERP describes the public alert and notification methods.

Primary alerting is by the emergency siren system in place for the NAPS site. Louisa County

can initiate its emergency alert sirens. Local television and radio stations that are part of the

EAS would provide notification and instruction. Appendix 2 to the Louisa County RERP

contains the procedure for the public information officer to release emergency instructions using

the EAS stations. The remaining county RERPs are similar to that for Louisa County.

NAEP Section 6.0, "Emergency Measures," Section 6.1, "Activation of the Emergency Plan,"

Section 6.3, "Protective Actions," and Section 7.6, "Early Warning System," provide additional

information concerning the bases and methods for communicating with response organizations

and the public.

13.3.3.6.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplenent 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan. The

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I I 1110

staff finds that the applicant identified the regulatory requirements and guidance applicable to

the proposed major features of emergency plans for an ESP application.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.D of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in ESP applications.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply to major feature E, "Notification Methods and Procedures."'

Major feature E calls for the applicant to describe the mutually agreeable bases for notifying

response organizations, consistent with the emergency classification scheme in Appendix 1 to

NUREG-0654/FEMA-REP-1, including the method for alerting, notifying, and mobilizing

personnel. The application should also describe the administrative and physical means for

notifying and promptly instructing the public within the 10-mile EPZ.

13.3.3.6.3 Technical Evaluation

SSAR Section 13.3.2.2.2.e.1 states that notifications to the Commonwealth of Virginia and risk

jurisdictions would be in accordance with SSAR Section 13.3.2.2.2.d, which lists the four

emergency classifications of notification of unusual event, alert, site area emergency, and

general emergency. The COVRERP and county RERPs all use the same four emergency

classifications, which are consistent with those in Appendix 1 to NUREG-0654/FEMA-REP-1.

The staff finds that each organization has described mutually agreeable bases for the

notification of response organizations and that each is consistent with the emergency

classification scheme in Appendix 1 to NUREG-0654/FEMA-REP-1.

SSAR Section 13.3.2.2.2.e.2 states that the normal process for alerting, notifying, and

mobilizing the EROs includes, but is not limited to, alarms, announcements, pagers,

telephones, and online messages. Section l!.B of Appendix 3 to the COVRERP states that the

facility operator would notify local governments within the 10-mile EPZ and the Virginia EOC by

the Insta-Phone. The staff finds that the COVRERP and county RERPs provide detailed

notification procedures and that this information adequately describes the methods for alerting,

notifying, and mobilizing emergency response personnel.

As stated in SSAR Section 13.3.2.2.2.e, the staff finds that Dominion would rely on the

already-installed ANS around the NAPS site to support the new units, and the Commonwealth

of Virginia and risk jurisdictions have ultimate responsibility for warning the public. While

sounding the ANS sirens remains the primary method of alerting the public, other alerting

methods may include telephone, television and radio (via the EAS stations), public address

systems, bullhorns from patrol cars, and personal contact. The COVRERP and the county

RERPs provide procedures for public alerting and notifying. The staff finds that this information

adequately describes the administrative and physical means for notifying and promptly

instructing the public within the 10-mile EPZ.

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l l l1
13.3.3.6.4 Conclusions

As discussed above, the applicant has described the mutually agreeable bases for notifying

response organizations, which is consistent with that set forth in Appendix 1 to

NUREG-0654/FEMA-REP-1,-and includes the method for alerting, notifying, and mobilizing;

personnel. In addition, the applicant has described the administrative and physical means for

notifying and promptly instructing the public within the 1 0-mile EPZ. Based on its review, the

staff concludes that the proposed major feature E is consistent with the guidelines in RS-002

and Supplement 2. Therefore, this feature is acceptable and meets the requirements of

10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.D of Appendix E to 10 CFR

Part 50, insofar as it describes the essential elements of advanced planning that have been

considered for notification methods and procedures, as set forth above.

13.3.3.7 Emergency Communications (Supplement 2, Major Feature F)

13.3.3.7.1 Technical Information in the Application

SSAR Section 13.3.2.2.2.f states that Dominion would provide the means for prompt

communications with the Commonwealth of Virginia, risk jurisdictions, and Federal Government

EROs; the means to alert and activate the ESP site ERO; and arrangements for communicating

with medical support facilities. The ESP site ERO would be alerted for activation by-way of

multiple communications methods (e.g., plant alarms and/or announcements, pagers,

telephones, online messages). -Dominion would maintain the capability of notifying both the

Commonwealth of Virginia and the risk jurisdictions within 15 min after declaring an emergency.

NAEP Section 7.2.2.4, "Dedicated NRC Communications," states that separate telephone lines

are dedicated for communications with the NRC, including the following:

* Emergency Notification System (ENS)

* Health Physics Network (HPN)

* Reactor Safety Counterpart Link (RSCL)

* Protective Measures Counterpart Link (PMCL)

* ~ERDS

SSAR Section 1 3.3.2.2.2.f.5 states that the ESP site can communicate with the hospital service

described in SSAR Section 13.3.2.2.2.1. The ESPsite would also be able to communicate with

an ambulance by use of an ultra-high frequency (UHF) radio or mobile telephone, and the

ambulance can communicate with the hospital by way of the hospital emergency and

administrative radio (HEAR) system or mobile telephone. -

NAEP Section 6.4.3, 'Medical Transportation," states that the station can communicate with

MCVH. In addition, Appendix 10.9, "Radiation Emergency Plan-MCVH/VCU-Virginia Power,"

to the NAEP states in Section VII.C, 'In Route Communications During Transportation to

MCVH,- that the Department of Emergency Medicine at MCVH has three systems for.

communicating with incoming ambulances (i.e., the HEAR system, coronary observation radio, -

and cellular telephone).

SSAR Section 13.3.2.2 states that the ESP-site is adjacent to a preexisting nuclear facility with

existing State and local emergency'plans. The SSAR, therefore, relies on and refers to the

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I urn

information contained in these existing plans. No significant differences exist between the

major features proposed in the application and the major features discussed in existing plans

and relied on in the application.

Section I.A, "Notification and Warning," of Appendix 3 to the COVRERP describes provisions

for communications between the NAPS site and the State. Insta-Phone (a dedicated hot-loop

system) would serve as the primary means of notification, which would permit simultaneous

notification of the Virginia EOC and the local governments within the 1 0-mile EPZ. Radio,

commercial telephones, and facsimile machines would serve as a backup. Local governments

within the 50-mile EPZ would be notified using the Virginia Criminal Information Network, with

commercial telephone as backup. The county RERPs also specify these same types of

communication systems.

Appendix 9, "Communications," to the COVRERP states that the primary means of

communication between the Virginia EOC and the Federal EROs would be commercial

telephone. The FEMA Federal national radio system or national warning system would be used

as a backup. Appendix 9 to the COVRERP also describes the State methods for alerting and

activating emergency response personnel.

COVRERP Section VIII.C, "Notification and Warning," states that, when notified by the NAPS

site, the Virginia EOC and the local governments would take actions as outlined at Tab A to

Appendix 4, "Emergency Response Procedures," and in local government RERPs. The Virginia

EOC would notify BRH, other State agencies assigned emergency tasks in the COVRERP, and

the affected local governments,' as appropriate. Each State organization is responsible for

activating its personnel in accordance with the organization's procedures and the classification

level. The local government EOCs or communications centers would notify local government.

officials and supporting organizations, and carry out emergency responsibilities and implement.

procedures in accordance with the local government RERPs. The county RERPs describe

procedures for activating emergency personnel. These procedures primarily describe

responsibilities for activating emergency personnel, rather than specifically covering the means

for activation.

Tab C to Appendix 9, Emergency Medical Communications," to the COVRERP describes the

radio communication capabilities of ambulances, hospitals, and other medical support activities

that would respond to a nuclear facility. These include hospital-to-ambulance, hospital-tohospital, and EOC-to-hospital communication methods. Additionally, VDEM command vehicles

are equipped for radio communication on the Virginia medical frequencies. Communications

are also available from the Louisa County Sheriff to the University of Virginia Hospital and

MCVH. The Virginia EOC can also directly contact the University of Virginia and MCVH by way

of radio. The county RERPs describe communication capabilities, consisting of commercial

and dedicated telephone lines, as well as local government radios.

In RAI 13.3-5, the staff asked the applicant to describe the specific provisions for

communications with contiguous'State and local governments within the 10-mile and 50-mile

EPZs and with Federal EROs. In addition, the staff asked the applicant to describe the extent

to which it would use existing site communications. In its response, the applicant stated that

the NAEP describes provisions for communications at the plant site as they currently exist,

which include an Insta-Phone hot loop between the licensee, the Virginia EOC, and the risk

jurisdiction warning points. In addition, there is a direct automatic ring-down circuit between the

13-26
licensee and the Virginia EOC, as well as both private branch exchange and off-premises

exchange access to the public switched network. -While existing site communications may be

used to support a new unit(s) constructed at the ESP site, the applicant stated that it is

premature to identify the specific extent to which'these capabilities Might be used in support of

new units at the ESP site,- siricebquivalent or superior'means may become available as a result

of technological advancements in the future. Thus, without specifying the technology at the

ESP stage, the applicarit stated that it would ensure that a means, compliant with regulatory

requirements, would be provided for communicating with contiguous State and local

governments within the 10-mile and 50-mile EPZs, as well as with Federal EROs.

13.3.3.7.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the informhati6n presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidanice in Supplement 2. 'SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections 11I, IV.D, and IV.E of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA" in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning'information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply.to rmajor feature F, "Emergency'Communications.'

Major feature F calls for the applicant to identify communication provisions with State and local

governments within the EPZs, with Federal EROs, and with'fixed and mobile medical support

facilities. The application should also describe provisions for alerting and activating emergency

personnel.

13.3.3.7.3 Technical Evaluation

Section IILA of Appendix 3 to the COVRERP states that the dedicated hot-loop Insta-Phone

system would serve as the primary means of notification and would permit simultaneous ;

notification of the Virginia EOC and the local governments within the 10-mile EPZ. Radio,

commercial telephones, and facsimile machines would serve as a backup. Local governmentswithin the 50-mile EPZ would be notified tising the Virginia Criminal Information Network with,

commercial telephone as backup. NAEP Section 7.2.2.4 states that separate dedicated

telephone lines with the NRC exist, including the ENS, HPN, RSCL, PMCL, and ERDS. In,-,-

response to RAI 13.3-5, the applicant stated that existing site communications may be used to

support the new units,'and equivalent or superior means might also'be used if they become,

available'as a result of future technological advancements.' Appendix 9 to the COVRERP

states'that the primary means of communications between the Virginia EOC and the Federal

EROs would be commercial telephone and that the FEMA Federal national radio system or

national warning system would be used as a backup. SSAR Section 13.3.2.2.2.f states that the

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[I

ESP site ERO would be alerted for activation by way of multiple communications methods (e.g.,

plant alarms and/or announcements, pagers, telephones, online messages).

SSAR Section 13.3.2.2.2.f.5 states that the ESP site can communicate with hospital services,

as well as an ambulance, by use of an ultra-low frequency radio or mobile telephone. The

ambulance can communicate with the hospital by way of the HEAR system or mobile

telephone. In addition, NAEP Section 6.4.3 states that the Department of Emergency Medicine

at MCVH has three systems for communicating with incoming ambulances (i.e., the HEAR

system, coronary observation radio, and cellular telephone).

Because the above descriptions cover the appropriate EROs and identify primary and backup

means of communications, the staff finds that the applicant provided adequate descriptions of

provisions for communications with the State and local governments, with Federal EROs, and

with fixed and mobile medical support facilities. In addition, the staff finds that the use of the

existing site communications for the ESP site is acceptable, to the extent that it would be

expanded to incorporate relevant aspects of a proposed new reactor design in a COL or OL

application. The staff will determine the adequacy of such incorporation during a COL or OL

review. The staff did not consider the availability of equivalent or superior means of

communications as a result of future technology advancements to be required for a major

features review and, as such, did not review it. A COL or OL applicant will address any'such

technological advancements, and the staff will determine compliance with the requirements in

this area during a COL or OL review.

13.3.3.7.4 Conclusions

As discussed above, the applicant has identified communication provisions with State and local

governments within the EPZs, with Federal EROs, and with fixed and mobile medical support

facilities. In addition, the applicant has described provisions for alerting and activating

emergency personnel. Based on its review, the staff concludes that the proposed major

feature F is consistent with the guidelines in RS-002 and Supplement 2. Therefore, this feature

is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections 1II, IV.D, and IV.E of Appendix E to 10 CFR Part 50, insofar as it describes the

essential elements of advanced planning-that have been considered for emergency

communications, as set forth above.

13.3.3.8 Public Education and Information (Supplement 2, Major Feature G)

13.3.3.8.1 Technical Information in the Application

SSAR Section 13.3.2.2.2.g states that Dominion would implement 'an emergency information

program for the public and the news media. Dominion would coordinate its public information

efforts with the Commonwealth of Virginia and local authorities to ensure that the public is

informed by using the best means available.

SSAR Section 13.3.2.2.2.g.1 states that Dominion Resources provides information annually

describing the emergency notification process and actions that should be taken in the event of

an emergency to the public within the NAPS site 1 0-mile EPZ. This information includes the

following:

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* educational information on radiation

* contact points for obtaining additional information

* protective measures (e.g., evacuation routes and relocation centers, sheltering,

respiratory protection, radioprotective drugs)

* 'special needs of the handicapped and the transient population

In'addition, SSAR Section 13.3.2.2.2.g.1 states that Dominion intends to rely on the program

that Virginia Power has already established for informing the public in the area surrounding the

ESP site. It would coordinate its public information efforts with the Commonwealth of Virginia

and local authorities to ensure that the public is informed by using the best means available

(e.g., telephone books, utility bill inserts, public postings, and periodic publications, such as

brochures and calendars).

SSAR Section 13.3.2.2.2.g.2 states that Dominion Resources offers an annual program to

acquaint the news media with emergency plans, information concerning radiation, and points of

contact for release of public information in an emergency. Dominion intends to rely on the

Virginia Power program for informing the media in the area surrounding the ESP site.

SSAR Section 13.3.2 states that the emergency plan takes advantage of the emergency

planning resources, capabilities, and organization that Virginia Power has already established -

and currently maintains at the NAPS site. The applicant would extend the existing emergency

planning and preparedness activities to include the proposed new unit(s); 'SSAR

Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with existing

State and local emergency plans. The SSAR, therefore, relies on and refers to the information

contained in these existing plans. No significant differences exist between major features

proposed in the application and the major features discussed in existing plans and relied on in

the application.

NAEP Section 8.8, "Informing the Public," states that Dominion would distribute public -

information to ensure coverage within the 10-mile EPZ. The company would also establish a

telephone system for addressing rumors, announce'the telephone numbers over the EAS, and

invite individuals within the 1 0-mile EPZ to call collect.

Appendix 8, "Public Information," to the COVRERP describes the Commonwealth's coordination

with Dominion-Resources regarding public information, stating that VDEM would lead the

coordination efforts with Dominion on nonemergency public information and education. The

State would assist local governments with their radiological information programs, as requested

by the emergency services coordinator.'-These actions would be coordinated with the VDEM

regional coordinator. The county RERPs' in Louisa,'Hanover, Caroline, and Spotsylvania

Counties all coordinate with Dominion Resources and VDEM in disseminating such

nonemergency information.

Appendix 8 to the COVRERP also indicates that Dominion would offer news media 2

representatives annual briefings on emergency response plans and would provide them with

other information regarding nuclear facilities in the Commonwdealth.' The county RERPs in

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,3

Louisa, Hanover, Caroline, and Spotsylvania Counties all mention local coordination in these

annual briefings to the news media.

In RAls 13.3-14(b) and 13.3-14(c), the staff asked the applicant to describe the periodic

program in Orange County for informing members of the public about how they will be notified

and what actions they should take during an emergency. The staff also asked the applicant to

describe its program for periodic, nonemergency briefings for the media. The applicant

responded to these RAls in its submittal dated October 20, 2004. The applicant stated that, on

an annual basis, the Commonwealth of Virginia provides the population within the 10-mile EPZ

an emergency planning information calendar with instructions to follow in case of an emergency

at the power station. The calendar includes information regarding sirens and EAS radio and

television stations for the area.

The applicant further stated that the Orange County public information officer or representative

would brief assembled news media hourly, on the hour, or as the situation would dictate, either

in the Board of Supervisors meeting room or the adjacent hallway media briefing area, using

the ingestion pathway map. The public information officer would also monitor radio newscasts

and scan local newspapers to determine whether information is accurately disseminated to the

public, and take necessary corrective action (see Appendix 2 to the Orange County RERP).

13.3.3.8.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance of Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.D, IV.E, and IV.F of Appendix E to

10 CFR Part 50. Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major

features of the emergency plans for NRC review and approval, in consultation with FEMA, in

the absence of complete and integrated emergency plans. Under 10 CFR 52.18, after

consultation with FEMA, the NRC will determine whether the major features of emergency plans

submitted under 10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide

guidance concerning the review and evaluation of emergency planning information given in an

ESP application. Supplement 2 also provides specific evaluation criteria for major features of

emergency plans, including those which apply to major feature G, "Public Education and

Information."

Major feature G calls for the applicant to describe a program to provide information to the public

and news media on a periodic basis. The program should address how the applicant would

notify the public, including what actions they should take in an emergency, and the applicant's

means for acquainting the news media with emergency information.

13.3.3.8.3 Technical Evaluation

As stated in SSAR Section 13.3.2.2.2.g, the NAEP, the COVRERP, and county RERPs,

Virginia Power has established a program for providing information to the public and news

13-30
media for the NAPS site. Doriiinion would rely on this prograrm for the area surrounding the

ESP-site. SSAR Section 13.3.2.2.2.g.1 lists the'type of inforrmiati6nrthat Dominion would

provide to the public, and SSAR Section 1 3.3.2.2.2.g.2 describes the type of information that

Dominion would provide to the news media. The staff finds that both lists are consistent with

NAEP Section 8.8, which applies to the current NAPS site, as well as the COVRERP and

county RERPs. In addition, Appendix 8 to the COVRERP and the county RERPs describe the'

coordination with Dominion Resources and with each other relating to emergency notification

and public information efforts and local coordination by the counties in annual news media

briefings.

In RAls i 33-1 4(b) and 13.3-14(c), the staff asked for information regarding the method for

providing information to the public in Orange County and the applicant's program for periodic,

nonemergency briefings of the media. The'staff identified the consideration of this information

as Open Item 13.3-2. The staff reviewed the applicant's responses in their submittal dated

October 20, 2004, and find them acceptable. Therefore, Open Item 13.3-2 is resolved.-

The staff finds that'the EROs have described an adequate program to provide a coordinated

dissemination of information to the public on a periodic basis, including how they will be notified

and what their actions shouild be in an emergency.. In addition, the staff finds that the

organizations have an adequate program for acquainting the news media on a periodic basis

with emergency plans, information concerning radiation, and points of contact for the release of

public information in'an emergency.

13.3.3.8.4 Conclusions

As discussed above, the applicant has described a program to provide'information to the public

and news media on a periodic basis'and which addresses public notification and emergency

actions.' Based on its review, the staff concludes that the proposed major feature G is

consistent with the guidelines in RS-002 and Supplement 2. Therefore, this feature isacceptable and meets the requirements of 1OCFR 52.17(b)(2)(i), 10 CFR 52.18,- and

Sections II, IV.B, IV.D, IV.E, and IV.F of Appendix E to 10 CFR Part 50, insofar as it describes

the essential elements of advanced planning that have been considered for public education

and information, as set forth above.

13.3.3.9 Emergency Facilities and Equipment (Supplement 2, Major Feature H)

13.3.3.9.1 Technical Information in the Application,

SSAR Section 13.3.2.2.2.h.1 states that Dominion would make provisions for a technical

support center (TSC) located near the control room. Personnel reporting to the TSC would'

provide plant management and technical support to the control room staff during emergency,.

conditions. The TSC would have technical and data displays .and plant records available to

assist in the detailed analysis and diagnosis of abnormal plant conditions. It would serve as the

primary onsite communications c6nter for the 'plant during an-emergency.

SSAR Section 1 3.3.2.2.2.h.2 states that Dominion would provide for'an operational support

center (OSC) assembly area, separate from the control room and the TSC. SSAR

Section 1 3.3.2.2.2.h.3 states'that Dominion would provide for an EOF to manage the overall

licensee emergency response, including-coordination with Federal, State, and risk jurisdiction

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to

officials, organization of.radiological and environmental assessments, and determination of

recommended public protective actions. The EOF would have technical and data displays and

plant records available to assist in the diagnosis of plant conditions. The EOF would serve as

the primary offsite communications center for the plant during an emergency.

SSAR Section 13.3.2:2 states that the ESP site is adjacent to a preexisting nuclear facility with

existing State and local emergency plans. The SSAR, therefore, relies on and refers to the

information contained in these existing plans. No significant differences exist between the

major features proposed in the application and the major features discussed in existing plans

and relied on in the application. SSAR Section 13.3.2.2.2.h.4 states that the State and risk

jurisdictions have established EOCs for use in directing and controlling emergency response

functions. COVRERP Section I1.C describes the establishment of the State EOC and its

functions, noting that the State would coordinate the offsite emergency operations from the

Virginia EOC (staffed 24 hours a day, 7 days a week) and respective local government EOCs.

The county RERPs describe the establishment, location, and function of the local EOCs.

SSAR Sections 13.3.2.2.2.h.1 and 13.3.2.2.2.h.2 provide brief, general statements from the

criteria presented in NUREG-0696, "Functional Criteria for Emergency Response

Facilities-Final Report," issued February 1981, for the TSC, OSC, and EOF, but do not give

specific facility- or equipment-related information.

In RAI 13.3-8, the staff asked the applicant to discuss the extent to which it intended the

application to address evaluation criteria V.H.1 and V.H.2 of Supplement 2 for the TSC, OSC,

and EOF, including the criteria of NUREG-0696. In addition, the staff asked the applicant to

state whether Dominion intends to use the existing TSC, OSC, and EOF, which support North

Anna Units 1 and 2, for the ESP site. If so, the applicant should provide information consistent

with evaluation criteria V.H.1 and V.H.2 of Supplement 2. In its response, the applicant stated

that the COL or CP applicant would make provisions for emergency facilities and equipment for

the TSC, OSC, and EOF that would satisfy the functions described in SSAR

Sections 13.3.2.2.2.h.1 through.13.3.2.2.2.h.2. The applicant noted that additional information

addressing the NUREG-0696 criteria is not necessary or appropriate at the time of the ESP

application and that a COL or CP application would include a description of the TSC and

descriptions of the conceptual designs for an OSC and EOF. Since the TSC, OSC, and EOF

details would differ based on the reactor design selected at the COL or CP stage, the applicant

has not yet decided whether to use the existing facilities to support the new unit(s).

Subsequently, in its submittal dated March 3, 2005, the applicant withdrew its request that

major feature H be evaluated as part of the North Anna ESP application.

13.3.3.9.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.B, and IV.E of Appendix E to 10 CFR Part 50.

13-32
Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which are applicable to major feature H, "Emergency Facilities and Equipment."

Major feature H calls for the applicant to describe a TSC, onsite OSC, and EOF, in accordance

with the criteria of NUREG-0696. The following are the general guidance criteria from

NUREG-0696 for these facilities: - -

* The TSC is an onsite facilitylocated close to the control room that shall provide plant

management and technical support to the reactor operating personnel located in the

control room during emergency conditions. It shall have technical data displays and

* plant records available to assist in the detailed analysis and diagnosis of abnormal plant - conditions and any significant release of radioactivity to the environment.- The TSC shall

be the primary communications center for the plant during an emergency.

* The OSC is an onsite assembly area separate from the control room and the TSC

where licensee operations support personnel shall report in an emergency. There shall

be direct communications between the OSC and the control room, and between the

OSC and the TSC, so that the personnel reporting to the 05C can be assigned to duties

in support of emergency operations. -

* --The EOF is a near-site support facility for the management of overall licensee

emergency response (including coordination with Federal, State, and local officials),

coordination of radiological and environmental assessments, and determination of

recommended public protective actions. The EOF shall have appropriate technical data

displays dnd plant records to assist in the diagnosis of plant conditions to evaluate the

potential or actual release of radioactive materials to the environment.

In addition, major feature H calls for the application to describe an EOC for each offsite

organization, for use in directing and controlling response functions.

13.3.3.9.3 Technical Evaluation

In SSAR Sections 13.3.2.2.2.h.1 through 1 3.3.2.2.2.h.2, the applicant offered a slightly revised

statement of the general guidance criteria from NUREG-0696 for the TSC, OSC and EOF,.

when compared to that provided above. In order for the NRC staff to determine whether major

feature H is acceptable, the applicant must address the adequacy of the facilities and related

equipment in support of emergency response and address, with specificity, facility and

equipment features, such as location, size, structure, function, habitability, communications,

staffing and training, radiological monitoring, instrumentation, data system equipment, power

supplies, technical data and data systems,- and record availability and management. The staff

identified the consideration of this information as Open Item 13.3-3. On March 3, 2005, the

applicant withdrew its request that major feature H be evaluated as part of the North Anna ESP

application. Based on this withdrawal, Open Item 13.3-3 is resolved.

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13.3.3.9.4 Conclusions

As discussed above, the applicant has withdrawn its request that major feature H be evaluated

as part of the North Anna ESP application. Based on this withdrawal, as set forth above, the

staff reached no conclusion regarding the acceptability of major feature H.

13.3.3.10 Accident Assessment (Supplement 2, Major Feature I)

13.3.3.10.1 Technical Information in the Application

SSAR Section 13.3.2.2.2.i.1 states that the existing NAPS meteorological monitoring system

has the capability to collect data for making near real-time predictions of atmospheric effluent

transport and diffusion. The data would be accessible in the new unit's control room, TSC, and

EOF. The applicant would also make suitable meteorological information available to the State,

as described in SSAR Section 13.3.2.2.2.e. SSAR Section 13.3.2.2.2.f describes

communications with the State, risk jurisdictions, and Federal Government EROs.

The National Oceanic and Atmospheric Administration (NOAA) is the primary agency within

the U.S. Department of Commerce responsible for providing assistance to Federal, State, and

local organizations in responding to a radiological emergency under the provisions of the

FRERP, as described in SSAR Section 13.3.2.2.2.c. Within NOAA, the National Weather

Service is the primary source of weather data, forecasts, and warnings for the United States.

Section 13.3.3.4 of this SER discusses the FRERP.

NAEP Section 7.3.3, "Meteorological Monitoring," states that the station's meteorological

monitoring system provides the capability for predicting atmospheric effluent transport and

diffusion. The system consists of a primary and a backup tower. Dominion Resources chose

the tower locations to represent regional conditions. Instruments located at these towers

provide data to the meteorological information and dose assessment system (MIDAS) via the

plant computer system, which is transmitted to both the NAPS control room and Dominion

Resource's weather center at Innsbrook, Virginia. NAEP Table 7.2, "Meteorological Monitoring

System Parameters," lists the parameters measured, and all meteorological data are available

by means of a dial-up link at meteorological operations in Richmond, Virginia.

SSAR Section 13.3.2.2.2.i.2 states that Dominion would use field monitoring to obtain offsite

radiological data within the 10-mile EPZ, and Dominion would coordinate field monitoring

activities from the EOF with VDH, under the provisions of the COVRERP. SSAR

Section 13.3.2.2.2.i.3 states that Dominion and the State would rely on DOE for airborne

radioactive plume tracking under the provisions of the FRERP, as described in SSAR

Section 13.3.2.2.2.c.

NAEP Section 7.3.2, "Radiological Monitoring," also addresses the capabilities and resources

for field monitoring within the 10-mile EPZ. It states that Dominion would use both fixed and

portable radiation monitoring equipment to perform dose assessments. It would use air

samplers and thermoluminescent dosimeters (TLDs) to obtain offsite data. In addition, the

State has TLD monitoring points located around the NAPS site, which serve to verify data.

NAEP Figures 7.1 and 7.2 identify dosimetry and air sampler locations within the 10-mile EPZ.

13-34
- - -

NAEP emergency plan implementing procedure (EPIP)-4.01, "Radiological Assessment

Director Controlling Procedure," provides guidance for conducting dose assessment, source

term determination, atmospheric diffusion factor determination, monitoring team activities,

personnel monitoring and decontamination, monitoring of onsite facilities, evacuation,

respiratory protection, sampling and sample analysis, and use of the MIDAS computer model.

The NAPS maintains fixed laboratory equipment to'support sampling analysis and monitoring,

including reading TLDs. The equipment includes multichannel analyzers, proportional counters,

a tritium analyzer, and whole body counters.

SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with

existing State and local emergency plans.; The SSAR, therefore, relies on and refers to the

information contained in these existing'plans. No significant differences exist between major

features proposed in the application and the major features discussed in existing plans and

relied on in the application.

The State response organization is based on normal government structures and channels of

communications. The State coordinates overall response, and BRH provides technical advice

and assistance on radiological accident assessment and radiological fielding monitoring. Upon

declaration of an alert (or higher) emergency class, -VDEM would notify VDH, and BRH would

implement its response procedures in accordance with the COVRERP. Appendix 5, "Accident

Assessment," to the COVRERP states that an RERT, composed of personnel from State

agencies and supplemented by personnel from the nuclear facility and Federal agencies, would

perform State radiological assessment activities. The RERT would operate from the State

EOC. Depending on the release parameters, the State does not anticipate full Federal

participation until after the emergency phase, at which time it would rely on DOE to help

develop information on the deposition of radioactive materials.

State field teams would coordinate their activities with utility and county teams and would obtain

area radiation dose rates, as well as air and environmental samples. The county RERPs

describe local responsibilities during a radiological emergency at NAPS. These include

providing personnel and equipment, as needed, to supplement BRH field monitoring. The State

has a mobile radiological laboratory to perform rapid sample assessment. The Division of

Consolidated Laboratories will make available the services of additional radiological

laboratories, and the State has access to Federal radiological field monitoring resources under

the provisions of the FRERP. SSAR Section 13.3.2.2.2.c discusses the FRERP, with regard to

locating and tracking the airborne radioactive plume. Section 13.3.3.4 of this SER discusses

additional accident assessment capabilities and resources. Sections 13.3.2, 13.3.3.2, 13.3.3.4,

and 13.3.3.13 of this SER describe contacts and arrangements in support of accident

assessment. - -

In RAI 13.3-14(d), the staff asked the applicant for additional information concerning the

assumptions in the application and assumptions in the COVRERP regarding reliance on DOE

for airborne radioactive plume tracking, In its response dated October 20, 2004, the applicant

stated the following:

Dominion and the'Commonwealth of Virginia rely on the Departmient'of Energy

for airborne radioactive plume tracking under provisions of the FRERP. Under

provisions of the Federal Radiological Emergency Response Pla'n, DOE may

respond to a state or LFA [Lead Federal Agency] request for assistance by

13-35
"U2

dispatching a Radiological Assistance Program (RAP) team. The DOE Regional

Coordinating Office with responsibility for the geographic area where the

Dominion ESP site is situated is the Oak Ridge Operations Office in Oak Ridge,

Tennessee. The DOE Radiological Assistance Plan, Region 2, includes the

states of Arkansas, Louisiana, Mississippi, Missouri, Tennessee, and West

Virginia; the Commonwealths of Kentucky, Virginia and Puerto Rico; and the

U.S. Virgin Islands. If the situation requires more assistance than a RAP team

can provide, DOE will alert or activate additional resources. These resources

may include the establishment of a Federal Radiological Monitoring and

Assessment Center (FRMAC) to be used as an on-scene coordination center for

federal radiological assessment activities. The FRMAC is charged with defining

and monitoring the. radiological impact of a nuclear or radiological release.

Because the effects of radiological contamination may last beyond an immediate

emergency, FRMAC serves as a coordination point for radiological monitoring,

assessment, evaluation, and reporting activities for the area surrounding a

radiological incident, including decontamination, recovery, and long-term

environmental monitoring. The FRMAC provides for the coordinated

management of federal technical response activities related to a radiological

emergency. It has three primary goals:

* Assisting the Commonwealth of Virginia and LFA with personnel,

equipment, and technical resources, as needed.

* Collecting offsite environmental radiological data.

* Providing to the involved Commonwealth of Virginia agencies and local

and federal agencies collected offsite environmental radiological data and

related assessments.

A Federal Radiological Monitoring Assessment Center advance party can be

expected at the site within 6 to 14 hours following the order to deploy, depending

on the availability of airports near the Dominion ESP site. Richmond

International Airport (RIC) is a major commercial facility and is within about an

85-minute drive from the Dominion ESP site. Smaller airports located within

about an hour of the site may also be used.

13.3.3.10.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance of Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.B of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

13-36
the NRC will determine whether the major features of emergency plans submitted under - -

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply to major feature I, "Accident Assessment.".

Major feature I calls for the applicant to describe the methods, systems, and equipment for

assessing and monitoring actual or potential offsite consequences of a radiological emergency

condition. The applicant should also describe the capability and resources associated with

acquiring meteorological information and performing field monitoring, and contacts and

arrangements with offsite organizations (including Federal and State'resources).

13.3.3.10.3 Technical Evaluation

SSAR Section 13.3.2.2.2.i.1 states that the existing NAPS meteorological monitoring system -

has the capability to collect data for making near real-time predictions of atmospheric effluent

transport and diffusion. The'data would be accessible in the new unit's control room,-TSC, and

EOF.' The applicant would make suitable meteorological information available to the State. In -

addition, NOAA provides assistance to Federal, State, and local organizations in responding to

a radiological emergency under the provisions of the FRERP. The staff finds that this

information adequately describes the contacts and arrangements for acquiring and evaluating

meteorological information, including making the data available to the State. - -

SSAR Section 1 3.3.2.2.2.i.2 states that Dominion would use field monitoring to obtain offsite

radiological data, and it would coordinate field monitoring activities from the EOF with VDH,

under the provisions of the COVRERP. SSAR Section 13.3.2.2.2.i.3 states that Dominion and.

the State Would rely on DOE for airborne radioactive plume tracking under the provisions of the

FRERP. NAEP Section 7.3.2 states that Dominion would use both fixed and portable radiation

monitoring equipment to perform dose assessment and would use air samplers and TLDs to

obtain offsite data. The equipment includes multichannel analyzers, proportional counters, a

tritium analyzer, and whole body counters.

The State has TLD monitoring points located around the NAPS site, which would serve to verify

data from the site, and a mobile radiological laboratory to perform rapid sample assessment.

The State Would coordinate overall response, and BRH would provide technical advice and

assistance on radiological'accident assessment and radiological field monitoring. State field

teams would coordinate their activities'with utility and county teams and would obtain area

radiation dose'rates, as well as air and environmental samples. County responsibilities would

include providing personnel and equipment, as needed, to supplement BRH field monitoring.

The State also has access to Federal radiological field monitoring resources under the

provisions of the FRERP.

In RAI 13.3-14(d), the staff asked the applicant for information on the assumptions in the

application and in the COVRERP regarding'reliance on DOE for airborne radioactive plume

tracking. The staff identified the consideration of this information as Open Item 13.3-4. The

staff reviewed the applicant's r6sponse in their submittal dated October 20, 2004, and finds it

acceptable. Therefore, Open Item 13.3-4 is resolved. The staff finds that the applicant has,

adequately described contacts and arrangements with responsible agencies and organizations

in support of accident assessment activities.

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13.3.3.10.4 Conclusions

As discussed above, the applicant has described adequate methods, systems, and equipment

for assessing and monitoring actual or potential offsite radiological consequences of a

radiological emergency condition at the ESP site, including associated contacts and

arrangements. Based on its review, the staff concludes that the proposed major feature I is

consistent with the guidelines in RS-002 and Supplement 2. Therefore, this feature is

acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections III, IV.A, IV.B, IV.C, IV.D, and IV.E of Appendix E to 10 CFR Part 50, insofar as it

describes the essential elements of advanced planning that have been considered for accident

assessment, as set forth above.

13.3.3. 11 Protective Response (Supplement 2, Major Feature J)

13.3.3.11.1 Technical Information in the Application

SSAR Section 13.3.2.2.2.j.1 states that the existing emergency assembly areas that support

NAPS would also support a new reactor(s) constructed on the ESP site. If evacuation of onsite

individuals is necessary, Dominion would direct evacuees to either the primary or secondary

remote assembly area (RAA), depending on specific radiological and environmental conditions.

SSAR Figure 13.3-4 depicts the onsite evacuation routes, RAAs, and State EACs. Evacuees

would use personal vehicles for transportation. Dominion would survey evacuees for

contamination following events involving a release and would decontaminate them, if

necessary, before releasing them from the RAA.

In RAI 13.3-6, the staff asked the applicant to clarify the availability of transportation to

emergency assembly areas for onsite individuals who do not have their personal vehicle

available onsite. In' its response, the applicant stated that those individuals would travel as

passengers in personal vehicles driven by others, which is the approach currently implemented

for the existing NAPS site.

NAEP Section 6.3.1, 'Offsite Criteria for the 10 Mile Emergency Planning Zone," states that

Dominion Resources has established evacuation zones, routes, and relocation centers in the

event that an evacuation is recommended and publishes this information in brochures

distributed by the State. NAEP Section 6.3.2, "Onsite Criteria for the Exclusion Area," states

that in the event of an onsite evacuation, radiation monitoring teams would be dispatched to the

appropriate RAA. Evacuees using personal vehicles would proceed to either the primary or

secondary RAA. NAEP Figure 6.2, which is identical to SSAR Figure 13.3-4, identifies the

RAAs.

SSAR Section 13.3.2.2.2.j.2 states that the senior Dominiion representative would recommend

initial offsite protective actions to the State within 15 min of declaring a general emergency,

based on plant conditions. The State and risk jurisdictions would notify the public and

implement the appropriate protective measures. Followup protective action recommendations

(PARs) from the NAPS site would be based on current meteorological data and dose

projections. The applicant stated that this guidance is based on NUREG-0654/FEMA-REP-1,

Supplement 3, "Criteria for Preparation and Evaluation of Radiological Emergency Response

Plans and Preparedness in Support of Nuclear Power Plants-Criteria for Protective Action

Recommendations for Severe Accidents-Draft Report for Interim Use and Comment," issued

13-38

* I l lI
July 1996, and U.S. Environmental Protection Agency (EPA) 400-R-92-001, "Manual of

Protective Action Guides and Protective Actions for Nuclear In`-cid6nts," issued May 1992.

NAEP Section 6.3, "Protective Actions," further states that, for the existing North Anna units,

specific PARs'are tied to'p!ant and meteorological conditions. IAn EPIP, specifically designed to

meet the-1 5-min PAR to the State, includes these recommendations. The initial PAR for any

event'classified as a general emergency would be to evacua6te in all directions out to 5 miles.

Dominion would declare a site area emergency when offsite doses are projected to exceed

0.001 Sv (0.1 rem) total effective dose equivalent (TEDE), or 0.005 Sv (0.5 rem) thyroid

committed dose equivalent (CDE). A general emergency would be declared when offsite

protective action guidelines (PAGs) of 0.01 Sv (1.0 rem) TEDE and/or 0.05 Sv (5.0 rehm) thyroid

CDE are projected to be exceeded because of a'direct radiation or inhalation hazard, or when

nonradiological conditions exceed general emergency EALs. v - '

In RAI13.3-7, the staff asked the applicant to describe the mechanism for recommending

protective actions to the appropriate State and local authorities,'iricluding how EALs would be

used to determine PARs (e.g., sheltering, evacuation, use of KI), consistent with -

EPA 400-R-92-001. In addition, the staff asked the applicant to describe how it would give

those recommendations to the appropriate State and local authorities, and how it would give

changes to, or termination of, PARs to State and local authorities. In its response, the applicant

stated that, in the event of a radiological emergency, the plant staff would analyze conditions'

and classify the event using the EALs developed pursuant to Appendix E to 10 CFR Part 50. In

most cases, the initial PAR would be made without the benefit of dose assessment results (i.e.,

based on plant conditions). Evacuation decisions would be based on dose projections or offsite

monitoring results exceeding evacuation dose thresholds of 0.01 Sv (1 rem) TEDE or 0.05 Sv

(5 rem) thyroid CDE.' -A recommendation by Dominion for the State to issue KI to the general

public would be based on reaching a projected dose of 0.05 Sv'(5'rem) thyroid CDE at or - -

beyond the NAPS site boundary. PAR revisions would consider actions taken in response to

previous PARs. Dominion would formally communicate initial PARs and any changes directly to

the State EOC using a dedicated automatic ring-down circuit, with'a commercial telephone as

backup. The State would make a protective action decision and notify the affected populace,

as described in SSAR Section 13.3.2.2.2.e.3. Dominion would discuss termination of PARs

with the State before issuance to ensure that PAR termination would 'not adversely affect offsite

response actions. '

In its response to RAI 13.377, the applicant fuirther stated that 10 CFR 50.47(b)(1 0),

Supplement 3,to NUREG-0654/FEMA REP-1i and EPA' 400-R-92-001 contain the current - -

Federal guidance relating to PARs. How6ever, the guidance in Supplement 3 -mnay change. -As

such, the applicant stated that it responded to this RAI with'the understanding that, in the

context of the North-Anna ESP application,'Federal guidance may change before it would'' ,

become applicable. '

SSAR Section 13.3.2.2.2.j.3 states thatfthe ETE applies to the ESP site;-and that ETEs based

on different affected population areas and weather conditions range fr (m 85 to 105 min. -SSAR

Section 13.3.2.2.2.j.4 states that the ETE includes maps showing the site and the 10-mile EPZ,

transportation'networks and evacuation routes, topographical features, political boundaries, and

thePAZs. In addition, population information is presented in 2-mile, 5-mile, and 10-mile ring

and 16-sector format, as well as by PAZ. Sectiorn'13.3.3.6 of this SER discusses the means for

13-39
I- - Irm

notifying the resident and transient population, while Section 13.3.1 of this SER provides

additional information regarding the ETE.

SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with

existing State and local emergency plans. The SSAR, therefore, relies bn and refers to the

information contained in these existing plans. No significant differences exist between major

features proposed in the application and the major features discussed in existing plans and

relied on in the application.

For the NAPS site, NAEP Section 6.3.1, "Offsite Criteria for the 10 Mile Emergency Planning

Zone (EPZ)," states that State and local officials are responsible for warning the public within

the 1 0-mile EPZ and that the State Department of Police would assist them. The early warning

system sirens serve as the primary method for warning the public. Other warning methods may

include telephone, television and radio EAS stations, public address systems, patrol car

bullhorns, and personal contact. -Either the State or county would release written preplanned

messages to the media, which would provide protective action instructions. The COVRERP

states that the local governments have the responsibility to educate their citizens on possible

radiological hazards, emergency notification, evacuation routes, assembly points, and other

protective measures.

COVRERP Section VII.D.1.a states that the State and neighboring local governments would

provide onsite assistance as requested and as mutually agreed to with the facility operator.

Similarly, the Louisa County RERP states that the county would also provide required, mutually

agreed-upon assistance.

The COVRERP and county RERPs contain maps that show the EPZ, PAZs (where evacuation

or sheltering would be implemented), and evacuation routes. They also contain tables that

show the population distribution in the counties and in the PAZs. The plans also list the EACs

(i.e., relocation centers). Each county RERP contains information concerning the transportation

of either transportation-dependent or special needs populations in their counties. State assets

would be available as backup; if needed. The only institutionalized populations are those in

schools in Louisa and Spotsylvania Counties. Public school buses would provide transportation

from the affected school(s) to-the designated EACs. In addition, the counties would use school

buses to evacuate other segments of the population without access to private transportation.

For the roadways, the local sheriffs' departments are responsible for manning the traffic and

access control points during and following an accident. Both the COVRERP and county RERPs

list these points. Private vehicles would be the primary means of transportation during an

evacuation. School buses, law enforcement vehicles, and ambulances would supplement these

vehicles, as needed. The county RERPs for Caroline, Hanover, Louisa, and Spotsylvania

Counties provide the means for dealing with potential impediments to using evacuation routes.

The State and local plans list the EACs, which are at least 15 miles from the ESP site.

Appendix 8, "Evacuation Assembly Center Procedures," to the county RERPs provides the

means for registering and monitoring evacuees at the EACs. The COVRERP and county

RERPs designate evacuation as the primary protective action. Tab A of Appendix 6 to the

COVRERP. considers other factors, not addressed in the county RERPs, such as shelter

availability, meteorological conditions, ETEs and risks, projected and actual doses, and plant

13-40
conditions. Except for Orange County, the local plans list sheltering as an option but do not

provide guidance for when sh6ltering should be considered.

The COVRERP and county RERPs contain information concerning the use of KI by emergency

workers. The COVRERP states that the State health director is responsible for authorizing

emergency workers to use KI. Appendix 6 to the county RERPs provides details for

implementing the KI decision for emergency workers. The COVRERP also states that

individuals responsible for the care of institutionalized persons would be responsible for their

protection; including the use of KI. The county RERPs do not consider the use of KI by

institutionalized persons, since evacuation and sheltering actions would make KI use

unnecessary.

In RAls 13.3-14(e), (f), (g), and (h), the staff asked the applicant for additional information

concerning use of the Patrick Henry High School, agreements for assistance from offsite

agencies, description of measures for dealing with potential impediments to use of evacuation

routes, and when sheltering should be considered.'- The applicant responded to these RAIs in

its submittal dated October 20, 2004. The applicant stated that Patrick Henry High School is

the secondary EAC for Hanover County and a primary host school for Louisa County school

children. In the event that North Anna is required to send station evacuees to the school, the

licensee would request permission in advance, and Dominion would provide resources to assist

with the monitoring and decontamination of site evacuees.

The applicant further stated that the existing letters of agreement, which address evacuation

assistance, contain the agreements for assistance from offsite agencies. Law enforcement

agencies would provide traffic control on Commonwealth roads. Both VSP and Louisa County

Sheriff's Office routinely train and exercise with Dominion emergency planners. In Orange

County, no routes exist that would experience any significant congestion during evacuation, and

appropriate actions have been identified for adverse weather conditions. In regard to

sheltering, a protective action decision would be made at the State EOC after local

recommendations are considered, and a conference call would be held to include all

jurisdictions in the PARs.

In RAI 13.3-15, the staff asked the applicant for additional information concerning the ETE

regarding road capacities and travel times, traffic control, worst-case scenario, persons without

vehicles, schools,' working people, evacuation confirmation, projected demography, and

computer modeling of the population. In addition, the staff asked the applicant for figures or

maps that showed various characteristics of the'area surrounding the ESP site. 'In its response

to this RAI, dated October 20, 2004, the applicant provided the requested figures or maps and

stated, in part, the following:

* The ETEs do not explicitly depend on the implementation of the emergency response

traffic control procedures outlined in the counties' RERPs. It is expected that ETEs

would n'ot increase because of their implementation. - i

* The ETE study required no explicit assumptions regarding the timing or implementation

of traffic control measures by local EROs. Local emergency management agencies use

ETEs to develop traffic control and traffic management plans to facilitate the evacuation

process.

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I Ire

Traffic controls in a network can limit user equilibrium if those traffic controls force some

vehicles to take routes with longer travel times. The purpose of the traffic control points

described in the counties RERPs is not to force vehicles to take a particular route with a

longer travel time but to maintain reasonable traffic flow. Drivers would be generally

free to choose their own route based on available routes.

* The ETE study was intended to consider general evacuation scenarios resulting from a

radiological event at NAPS. The ETEs are intended to be based on general bad

weather conditions. Bad weather in the area around NAPS was assumed to be

predominately related to snow and ice. To accommodate the impact of bad weather on

the ETEs, the speed limits were reduced by 40 percent. This effectively reduced the

road capacities by about 25 percent.

* In regard to the assumption of a car occupancy factor of 2.5, the average household

size for the five counties surrounding the NAPS is 2.56. It is assumed that families

would evacuate together in most situations. Additionally, most planners estimate that to

evacuate, each household would take an average of 1.3 to 1.5 vehicles (or about 2 to

2.5 people per vehicle).

* The nuclear emergency information calendars distributed in each of the counties inform

the public to assist friends and neighbors without transportation. In addition, local

government vehicles would transport persons without their own means of evacuation;

members of the immediate family or friends (if possible) would evacuate nonambulatory

persons; and those requiring transportation would be identified (before or at the time of

the emergency), and transportation would be provided. It is assumed that neighbors or

relatives would evacuate the majority of the population needing transportation.

* Although county RERPs identify bus routing for pickup of nonauto-owning populations,

they also encourage any nonambulatory persons to evacuate with members of the

immediate family or friends, if possible. Similarly, the nuclear emergency information

calendars encourage people without transportation to make plans to ride with a

neighbor.

* The evacuation of school children is implicitly represented in the composite traffic

loading curve. The superintendent of schools would provide buses and other vehicles

with drivers for assisting in an evacuation of the public and school students. If school

children had not been returned to their homes before an evacuation order, they would

be taken to an EAC under adult supervision.

* Schools can typically be expected to respond significantly faster than the general

population. As a result of routine fire drills and other emergency drills performed at

schools, response times are typically much better for school populations than for

general populations. Schools have demonstrated the ability to load buses and start

evacuation within 10-20 min following a warning and directions to do so from local

emergency management.

* The time needed to confirm evacuation depends on the method of confirmation

employed. County RERPs and the nuclear emergency information calendar provide

some information on conducting such confirmation, such as placing the 'We Have Been

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Notified" card (from the back of the calendar) in a window or door facing the street, or

tying a towel to a door or mailbox.

* The composite traffic loading curve used for the ETE analysis is based on the data

collected during evacuations executed in response to large-scale chemical spills. This

curve explicitly incorporates the time required for communication of the warning to the

public and the time required for an individual to respond to the warning.

* The ETE analysis used the Evacuation Simulation Model, the core component of the

Oak Ridge Evacuation Modeling System, to establish the ETEs. The composite traffic

loading curve used for the ETE incorporates the time required for communication of the

warning to the public and the time required for an individual to respond to the warning

once received. The mobilization tim e distribution is based on data from actual

emergency evacuations and, hence, does not implicitly account for most of the common

activities performed by individuals in preparation for evacuation.

* The underlying assumption regarding the applicability of the Rogers' mobilization curves

in the ETE study is that public perception of radiological emergencies differs from the,

actual characteristic of such an event. The alarm that would be associated with social

response in a radiological emergency makes the use of Rogers' mobilization curves

prudent for the ETE study.

13.3.3.11.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.- -

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.B, and IV.D of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted underI

10 CFR 52.17(b)(2)(i) are acceptable." RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply to major feature J, "Protective Response.'

Major feature J calls for the applicant to describe protective actions for the 1 0-mile EPZ for the

public and emergency workers,--including evacuation routes, transportation, and handling

evacuees. The application should identify guidelines for the choice of protective actions,

consistent with Federal guidance, as well as the bases and mechanisms for recommending

protective actions to State and local authorities. -The application should describe each

organization's concept for implementing protective actions and describe contacts and

arrangements with offsite agencies. In addition, the applicant should prepare an ETE for the

10-mile EPZ.

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ILE

13.3.3.11.3 Technical Evaluation

In SSAR Section 13.3.2.2.2.j.1, the applicant stated that onsite individuals would be evacuated,

using personal vehicles for transportation, to either the primary or secondary RM, depending

on specific radiological and environmental conditions. SSAR Figure 13.3-4 shows the separate

locations of the RAAs and State EAC, and the associated evacuation routes. The RAAs are

located in separate directions from the ESP site, and the State EAC provides a third location.

The staff finds that the RAAs and State EAC are suitable because they provide adequate

alternative offsite evacuation locations in-the event of inclement weather, high traffic density,

and specific radiological conditions.

The staff finds that SSAR Section 13.3.2.2.2.j.2 adequately describes a mechanism for

recommending protective actions to the appropriate State and local authorities. The application

states that the senior Dominion representative would be responsible for making initial and

followup PARs and that EPA 400-R-92-001 would serve as the basis for such

recommendations. The staff did not consider the possibility of a change to the Federal

guidance relating to PARs'germane to its review of the SSAR. Rather, the staff applied current

requirements. A COL or OL applicant should address any such changes, and the staff will

determine compliance with the requirements in this area during a COL or OL review.

The staff found that the EACs are at least 15 mi from the ESP site and that the registration and

monitoring of evacuees would be conducted in accordance with the EAC procedure, contained

in the county RERPs. In addition, the staff found that the COVRERP and county RERPs

designate evacuation as the primary protective action and that Tab A of Appendix 6 to the

COVRERP considers other factors, such as shelter availability, meteorological conditions, ETEs

and risks, projected and actual doses, and plant conditions.

The COVRERP and county RERPs state that the State and local governments would provide

onsite assistance, as requested and as mutually agreed to with NAPS. The revised letters of

agreement, discussed in Section 13.3.2 of this SER, address such mutually agreed-upon

assistance.

The staff finds that the application, the NAEP, the COVRERP, and county RERPs provide maps

(or lists)'that adequately illustrate population distribution around the site, evacuation areas,

evacuation' routes, shelter areas, and "relocation centers in host areas. The staff finds that the

proposed means for notifying all-segments of the resident and transient population are

adequate because the primary method for warning the public is through the use of the early

warning'system sirens', with additional notification capabilities through the use of telephones,

television and radio EAS stations, public address systems, patrol car bullhorns, and personal

contact. The warnings would consist of preplanned messages, which provide specific

protective action instructions. Individuals responsible for the care of institutionalized persons

would also be responsible for their protection, including sheltering, evacuation, and the use of

KI. The State health director would authorize the use of KI by emergency workers and

institutionalized persons.

In RAls 13.3-14(e)-(h), the staff asked for information concerning the use of Patrick Henry High

School, agreements for assistance from offsite agencies, measures for dealing with potential

impediments to use of evacuation routes, and consideration of sheltering. The staff identified

the consideration of this information as Open Item 13.3-5. The staff reviewed the applicant's

13-44
responses in their submittal dated October 20, 2004, and find them acceptable. Therefore,

Open Item 13.3-5 is resolved.

In RAI 13.3-15, the staff asked for additional information regarding issues relating to the ETE.

The staff identified consideration of this information as Open Item 13.3-6. 'The staff reviewed

the applicant's response in their submittal dated March 3, 2005, and finds it acceptable.'

Therefore, Open Item 13.3-6 is resolved.

The staff finds that the applicant has adequately described a range of protective actions for the

plume exposure pathway'EPZ for the public and emergency workers,'and protective actioris for

the ingestion exposure EPZ. In addition, the staff finds that the guidelines for the choice of

protective actions are consistent with Federal'guidance and are appropriate to the locale.

Section 13.3.2 of this SER discusses the associated description of contacts and drrangements

made with offsite agencies with emergency planning responsibility.

13.3.3.11.4 Conclusions

As discussed above, the applicant has described a range of protective actions for the plume

exposure' pathway EPZ for public and emergency workers, includini guidelines for the choice of

protective actions that are consistent with Federal guidance, and protective actions for the

ingestion exposure pathway EPZ. -Based on its review, the staff concludes that the proposed

major feature J is consistent with the guidelines in RS-002 and Supplement 2. Therefore, this

feature is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections III, IV.A, IV.B, IV.D, and IV.E of Appendix E to 10 CFR Part 50, insofar as it describes

the essential elements of advanced planning that have been considered for accident

assessment, as set forth above.

13.3.3.12 Radiological Exposure Control (Supplement 2, Major Feature K)

13.3.3.12.1 Technical Information in the Application

SSAR Section 13.3.2.2.2.k.1 states that Dominion would maintain doses to emergency

response personnel within the limits of 10 CFR Part 20, "Standards for Protection Against

Radiation," under normal operating conditions, and that these personnel may, because of

necessity, receive a once-in-a-lifetime exposure to contamination and radiation up to the

10 CFR Part 20 annual limits, not including accumulated occupational exposure.

SSAR Section 13.3.2.2.2.k.2 states that the existing NAPS radiological protection and onsite

contamination control procedures would apply to the ESP site, or future radiological protection

procedures would address these functions. SSAR Section 13.3.2.2.2.k.3 states that

emergency workers at the ESP site would receive direct reading'and permanent rec6rd

dosimeters, and Dominion would maintain dose records in accordance with'the existing NAPS

radiological protection pro edures or future rpadiological protectiorprcedures.

The guidelines for emergency exposure limits are consistent with EPA 400-R-92-001. SSAR

Section 13.3.2.2.2.k.4 states that approval from the erirgeicy coordinator is necessary for

planned exposures greater than the 10 CFR Part 20 annual limits. Under limited

circumstances, exposure limits greater than 5 times the 10 CFR Part 20 annual limits may be

allowed, but only to certain volunteers.

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It!2

NAEP Section 5.2.1.1, "Station Emergency Manager," states that the station emergency

manager, who ultimately reports to the recovery manager, has the responsibility for managing

and directing emergency operations during the course of the emergency, including the

authorization of emergency exposure limits. NAEP Section 6.4.1, "Emergency Exposure

Limits," states that station emergency manager approval is necessary for planned exposures

greater than the 10 CFR Part 20 annual limits. The guidelines for emergency exposure limits,

which are specified in the NAPS EPIPs, are consistent with EPA dose limits for workers

performing emergency services.

In RAI 13.3-10, the staff asked the applicant to clarify who authorizes exposures greater than

the 10 CFR Part 20 annual limits.. In its response, the applicant stated that the NAPS station

emergency manager functions as the emergency coordinator for the NAPS and can authorize

emergency workers to receive doses in excess of the 10 CFR Part 20 limits. In addition, the

applicant stated that a COL orOCP application would provide a description of the onsite

emergency organization. While the applicant has made no decisions regarding organizational

details for the prospective new reactors, it stated that it intends no substantial differences

between the NAEP and SSAR Section 13.3.

NAEP Section 6.4.2, "Decontamination and First Aid," states that the NAPS health physics

procedures and EPIPs specify levels of permissible radioactive contamination for workers and

equipment. Personnel must take actions when levels for equipment or areas exceed the limits

established in the health physics procedures. Any detected personnel contamination would

initiate appropriate evaluation and decontamination, in accordance with these procedures. An

EPIP also provides for the monitoring of vehicles and personnel at the RAAs.

SSAR Section 13.3.2.2.2.k.5 states that Dominion would provide adequate supplies for

personnel decontamination and make provisions for decontamination, as specified in the

existing units' radiological protection procedures or as addressed in future procedures. Health

physics personnel can perform decontamination at the existing units or the ESP site, RAA, or

Patrick Henry High School. SSAR Section 13.3.2.2.2.j.1 states that decontamination agents

and supplies are available at the NAPS site and can be transported to the RAAs to provide

decontamination capabilities. Injured and contaminated persons would be decontaminated to

the extent achievable or transported to the hospital, as described in SSAR Section 13.3.2.2.2.1.

SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with

existing State and local emergency plans. The SSAR, therefore, relies on and refers to

information contained in these existing plans. No significant differences exist between major

features proposed in the application and the major features discussed in existing plans and

relied on in the application.

Appendix 6, "Radiological Exposure Control," to the COVRERP.'states that BRH would issue

self-reading pocket dosimeters and TLDs to emergency workers who enter the affected area.

In addition, pocket dosimeters, chargers, and TLDs are prepositioned in each risk and host

jurisdiction. Local government has the primary responsibility for radiation exposure control, with

State agencies providing technical advice and guidance. The State has accepted the EPA

PAGs, and the COVRERP provides a variety of protective actions that are consistent with the

PAG limits.

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Radiation exposure control for emiergency workers is accom plished by several means, including

continuous monitoring and limiting radiation exposures. In the initial stages of an incident, BRH

would use a default exposure control ratio (or dose conversion multiplier) to factor in internal

exposure that is not measurable with a pocket dosimeter. BRH would adjust an initial exposure

control ratio, which is based on a default accident source term, if accident assessment indicates

that a change is necessary to reflect actual conditions. The emergency workers would divide

the pocket dosimeter readings by the exposure control ratio to determine their reporting, turn

back, and lifesaving levels. The county RERPs give specific instructions regarding the -

issuance of personal dosimetry. -

Appendix 6 to the COVRERP provides exposure limits for emergency workers and specifies

reporting, turn back, and lifesaving levels. The emergency worker exposure limits and

exposure control ratio in the county RERPs are consistent with those in the COVRERP. The

EOC radiological officer must authorize an emergency worker to exceed the established limits.

If the assignment is critical and a replacement is unavailable,-the EOC radiological officer may

authorize a higher dose, up to the lifesaving level.

The State performs radiological decontamination at the EACs.- Appendix 6 to the COVRERP

provides general instructions relating to monitoring and decontamination of evacuees and ' '

emergency workers. In addition, Appendix 10, 'Decontamination, Re-Entry, and Return," to the

COVRERP specifies action levels for determining the need for decontamination and describes

the means for decontamination of people, vehicles, livestock, structures, crops, soil, and anyother surfaces that are contaminated with radioactive material. The county RERPs include

procedures for monitoring and decontamination that are consistent with the COVRERP. The

State would transport individuals who cannot be decontaminated below prescribed action levels

to a medical facility that can handle radiologically contaminated patients.

In RAI 13.3-14(i), the staff asked the applicant for additional information regarding the

decisionmaking guidance and authority in the State and local plans for authorizing emergency

workers to exceed EPA exposure limits. In RAI 13.3-14(j), the staff also asked the applicant for

additional information regarding measures to ensure that the use of the exposure control ratio

does not result in emergency workers exceeding EPA exposure limits.- In its response to these

RAls dated October 20, 2004, the applicant stated that VDHIBRH would provide authorization,

when needed, for any state emergency worker to exceed the 0.15 Sv (15 rem) TEDE turnback

level during an emergency. In addition; the applicant addressed the exposure control ratio, -

consistent with that described above. -

13.3.3.12.2 Regulat6ry Evaluation;

SSAR Section 13.3.2.2 presents the major features of the applicant's -emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in':

accordance with 10 CFR 52.1 7(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a majorlfeatures emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.B, and IV.E of Appendix E to 10 CFR

Part 50. Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of

the emergency plans for NRC review and approval, in consultation with FEMA, in the absence

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I I IlII

of complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with ;

FEMA, the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.1 7(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply to major feature K, "Radiological Exposure Control."

Major feature K calls for the applicant to describe an onsite radiation protection program and

the means for determining and controlling radiological exposures to emergency workers and

volunteers (onsite and offsite), including a decision chain for authorizing exposures in excess of

EPA dose limits. The application should also describe specific action levels and the means for

radiological decontamination of personnel (including personnel wounds), vehicles, equipment,

supplies, and possessions.

13.3.3.12.3 Technical Evaluation

In SSAR Section 13.3.2.2.2.k.1, the applicant stated that it would maintain the emergency

worker dose limits within the limits of 10 CFR Part 20 and that these limits are consistent with

EPA 400-R-92-001. In addition, the existing (or future) NAPS radiological protection and onsite

contamination control procedures would apply to the ESP site. The staff finds that the use of

the existing NAPS radiological protection and onsite contamination procedures for the ESP site

is acceptable, to the extent that they would be expanded to incorporate relevant aspects of a

proposed new reactor design in a COL or OL application. The staff will determine the adequacy

of such incorporation during a COL or OL review. The staff did not consider the applicability or

adequacy of future radiological protection and onsite contamination procedures to be required

for a major features review and, as such, did not review it. A COL or OL applicant will address

any such future procedures, and the staff will determine compliance with the requirements in

this area during a COL or OL review. The staff further finds that the application adequately

describes the guidelines for dose limits and the onsite radiation protection program for the ESP

site.

The applicant stated that emergency workers at the ESP site would receive direct reading and

permanent record dosimeters, and it would maintain dose records in accordance with the

existing NAPS radiological protection procedures. State and local emergency workers would

also receive self-reading pocket dosimeters and TLDs, in accordance with the COVRERP and

county RERPs. The State and counties would determine State and local emergency worker

doses through the use of radiation exposure record forms. While the local governments have

the primary responsibility for radiation exposure control, BRH would provide technical oversight

and authority to permit exposures in excess of the EPA dose limits. The staff finds that this is

acceptable because it adequately describes how each organization would determine the doses

received by emergency personnel, including how they would acquire and distribute dosimeters.

With regard to authorizing emergency workers to incur exposures in excess of the EPA dose

limits, the applicant stated in SSAR Section 13.3.2.2.2.k.4 that approval from the emergency

coordinator is necessary for planned exposures greater than the 10 CFR Part 20 annual limits.

NAEP Section 6.4.1 states that such approval would come from the NAPS station emergency

manager, who would function as the emergency coordinator.

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Both the COVRERP and county RERPs address the authority for State and local emergency

workers to incur exposures in excess of the EPA dose limits. The EOC radiological officer

should provide authorization to exceed the turnback level, which is determined through the use

of pocket dosimeter readings and an exposure control ratio. BRH may adjust the exposure

control ratio to reflect actual conditions. ,;

For radiological monitoring and decontamination, the staff finds that the existing units'

radiological protection procedures adequately address the action levels and means for the - --

decontamination of ESP site personnel and equipment. The COVRERP and county RERPs,

together, also adequately describe action levels and the specific means for decontamination.

The staff did not consider the extent to which future radiological protection procedures would

address radiological protection and onsite contamination control functions, as stated in SSAR

Section 13.3.2.2.2.k.2, to be essential to its review and, therefore, did not evaluate this

possibility.

In RAls 13.3-14(i) and 13.3-140), the staff asked for information concerning guidance and

authority on decisions to authorize emergency worker exposure exceeding EPA limits and

measures to ensure that the use of the exposure control ratio does not cause exposures to

exceed EPA limits, respectively. The staff identified the consideration of this information as

Open Item A13.3-7. The staff reviewed the applicant's responses in their submittal dated

October 20, 2004, and finds them acceptable. Therefore, Open Item 13.3-7 is resolved.

The staff finds that the applicant has adequately described guidelines on dose limits and an

onsite radiation protection program. In addition, the staff finds that the applicant has

adequately described how the EROs would acquire and distribute dosimeters, determine:

emergency personnel doses, authorize exposures in excess of the EPA dose limits, and

conduct radiological decontamination.

13.3.3.12.4 Conclusions

As discussed above, the applicant has described the means for controlling radiological

exposures to emergency workers in an emergency. Based on its review, the staff concludes

that the proposed major feature K is consistent with the guidelines in RS-002 and

Supplement 2. Therefore, this feature is acceptable and meets the requirements of 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.B, and IV.E of Appendix E to 10CFR

Part 50, insofar as it describes the essential elements of advanced planning that have been

considered for radiological exposure control, -as set forth above.

13.3.3.13 Medical and Public Health Support (Supplement 2, Major Feature L) -

13.3.3.13.1 Technical Information in the Application

SSAR Section 13.3.2.2.2.1 states that the applicant would make contacts and arrangements for

medical services for contaminated injured individuals and that the existing arrangements for the

use of the MCVH facilities in Richmond, Virginia, would apply to the ESP site. In the event of a

13-49
I'll

need for its support, Dominion would call ahead to MCVH to alert it to activate its radiation

emergency plan.4

SSAR Section 13.3.2.2.2.1.1 further states that MCVH has developed its own radiation

emergency plan, which is designed to provide medical care in the case of a radiation

emergency. MCVH also supports the NAPS site in the event of occupational or major

accidents, including contaminated personnel. In addition, the plan establishes a specialized

area of the hospital for treatment with appropriate health physics functions and implements a

coded system to alert hospital team members. The MCVH has radiation monitoring equipment,

dosimetry, and protective clothing available, and, based on the quality of the facilities at MCVH,

the NRC has accepted the absence of arrangements for a backup hospital. The NAEP

includes the MCVH radiation emergency plan as Appendix 10.9.

SSAR Section 13.3.2 states that the emergency plan takes advantage of the emergency

planning resources, capabilities, and organization that Virginia Power has already established

and currently maintains at the NAPS site. The applicant would extend the existing emergency

planning and preparedness activities to include the proposed new unit(s). SSAR

Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with existing

State and local emergency plans. The SSAR, therefore, relies on and refers to information

contained in these existing plans. No significant differences exist between major features

proposed in the application and the major features discussed in existing plans and relied on in

the application.

Attachment 1 to Tab D of COVRERP Appendix 4 states that Mary Washington Hospital and

Riverside Hospital serve as backup hospitals for MCVH and would accept radiation exposure

patients. Tab D also lists additional hospitals that have radiological response capabilities and

would accept radiation exposure patients. The county RERPs also list several hospitals.

SSAR Section 13.3.2.2.2.1.2 further states that the COVRERP contains a list of public, private,

and military hospitals and other medical service facilities within the Commonwealth of Virginia

that can provide medical support for any contaminated or injured individual. Attachments 1 and

2 to Tab D of COVRERP Appendix 4 contain this information and include the name, location,

type of facility, capacity, and radiological capabilities. The COVRERP and Sections 13.3.2,

13.3.3.4, and 13.3.3.10 of this SER address the contacts and arrangements pertaining to

hospital and medical services. As discussed in Section 13.3.2 of this SER, Dominion updated

the letters of agreement to reflect that the existing arrangements would apply to a prospective

additional reactor(s) at the NAPS site, consistent with the application.

In RAI 13.3-14(k), the staff asked the applicant for additional information regarding a

description in the COVRERP of the capabilities of local and backup hospital and medical

services. In its response to this RAI dated October 20, 2004, the applicant stated that the

primary hospital, MCVH, provides 24-hour emergency department coverage and that the

maximum number of patients would depend on the availability of hospital facilities and beds. In

addition, the backup hospital, Mary Washington Hospital, also provides 24-hour emergency

department coverage.

4Medical College of Virginia HospitalsNirginia Commonwealth University (MCVHNCU),

"Radiation Emergency Plan-Virginia Power," January 14, 2003

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13.3.3.13.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 1 3.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.B, and lV.E of Appendix E to 10 CFR

Part 50. Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of

the emergency plans for NRC review and approval, in consultation with FEMA, in the absence

of complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with

FEMA, the NRC will determine whether the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of the emergency planning information given in an' ESP'application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply to major feature L, "Medical and Public Health Support."'

Major feature L calls for the applicant to describe contacts and arrangements made for medical

services for contaminated injured individuals, as well as to develop lists indicating the locations

and capabilities of emergency medical s6evices facilities. '

13.3.3.13.3 Technical Evaluation

As stated in SSAR Section 13.3.2.2.2.1.1, arrangements currently exist with MCVH in

Richmond, Virginia, in support of the NAPS site and include application of the MCVH plan.

Section I, "Introduction," of the MCVH plan states that it is designed to provide medical care for

either a major or minor radiation emergency in the central Virginia region; ~'iIn addition the 

MCVH plan supports Virginia Power's nuclear reactor stations in the event of occupational

and/or major accidents. Section VII, "Radiation'Emergency Response," of the MCVH states

that the MCVHN/CU Department of Emergency Medicine area is equipped to treat as many as

four coritaminated patients at one time, depehdirig upon the degree of emergency medical care

needed. - - ;

Tab D to COVRERP Appendix 4 states that MCVH would act as the primary hospital for an

individual who is both contaminated and injured. In addition, it provides a detailed list of backup

hospitals. The countyRERPs also list several hospitals. In RA! -13.3-1 4(k),- the staff asked for -

information concerning the COVRERP descripti6n'' of local and backup hospital and medical

services capabilities. The staff identified the consideration of this information as Open

Item 13;3-8. The staff reviewed the applicrnt's response in their submittal dated October 20,

2004, and finds it acceptable. Therefore, Open Item 1 3.3:8 is resolved.- '

The staff concurs with the applicant's statement in SSAR Section' 13.3.2.2.2.1.1 that the NRC

has accepted the absence' of arrangements for a backup hospital, based on the quality of the

facilities at MCVH. -For'the'NAPS site, the NRC'concluded in-Section Lof Appendix B to

Supplement 11 to NUREG-0053, "Safety Evaluation Report Related to the Operation of North

Anna Power Station, Unit 2," issued August 1980, that VEPCO did not have arrangements for a

backup hospital in the local area. However, based on the quality of the facilities at the MCVH,

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Itl

the staff found that this arrangement was acceptable. The staff reviewed the current MCVH

plan and finds that it includes a listing in Appendix IX of hospitals that have indicated that they

have a radiological emergency response capability and would accept radiation accident victims.

This list includes the name, location, type of facility, capacity, and special radiological

capabilities. The MCVH plan also describes the contacts and arrangements.

The staff reviewed the existing letters of agreement in Appendix 10.1 to the NAEP and finds

that the letter of agreement with MCVH provides a detailed description of 'contacts and

arrangements between the applicant and MCVH relating to medical services in support of the

NAPS site. As discussed in Section 13.3.2 of this SER, Dominion' updated the letters of

agreement to reflect that the existing arrangements would apply to a prospective additional

reactor(s) at the NAPS site, consistent with the application.

The staff finds that the applicant has adequately described the contacts and arrangements

made for local and backup hospitals, including the capability for the evaluation of radiation

exposure and uptake, as well as provided lists of locations and capabilities.

13.3.3.13.4 Conclusions

As discussed above, the applicant has described the contacts and arrangements for medical

services for contaminated injured individuals, including local and backup hospital and medical

services having the capability for evaluation of radiation exposure and uptake. Based on its

review, the staff concludes that the proposed major feature L is consistent with the guidelines in

RS-002 and Supplement 2. Therefore, this feature is acceptable and meets the requirements

of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.C, and IV.E of Appendix E to

10 CFR Part 50, insofar as it describes the essential elements of advanced planning that have

been considered for medical and public health support, as set forth above.

13.3.3.14 Radiological Emergency Response Training (Supplement 2, Major Feature 0)

13.3.3.14.1 Technical Information in the Application

In SSAR Section 13.3.2.2.2.o the applicant stated that it intends to rely on the existing Nuclear

Power Station Emergency Preparedness Training (NPSEPT) Program Guide to provide the

framework for conducting specialized initial training and periodic retraining for Dominion

personnel at any new unit(s) that might be constructed on the ESP site.

The NPSEPT Program Guide contains the curriculum design and describes program

management, implementation, evaluation, documentation, and training for, personnel

designated to fill ERO positions. Emergency preparedness training that is not given by the

nuclear emergency preparedness (NEP) staff is conducted pursuant to supporting department

training program guidance. Procedures provide that the NEP staff verify that this departmental

training is consistent with the provisions of the NPSEPT Program Guide. These training

programs, taken collectively, establish the initial training and retraining provisions for the

existing units' ERO positions. NEP personnel, other than those designated to develop training

programs, independently verify that the training specified by the NPSEPT Program Guide is

accomplished.

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SSAR Section 1 3.3.2.2.2.o states that Dominion would incorporate specific training

requirements for ERO personnel supporting a new reactor(s) into the NPSEPT Program Guide

and would include specialized initial training and periodic retraining. Dominion would provide

specific training for the following emergency response categories:

* response organization coordinators

* accident assessment personnel

* ~personnel performing radiological monitoring and analysis

* police, security, and firefighting personnel

* first aid and rescue personnel

* local support services personnel

* medical support personnel

* communicators

In addition, NAEP Section 8.3.3, "Emergency Response Personnel Training," states that

personnel designated to fill interim, primary, or'alternate emergency response positions would

receive training in accordance with the NPSEPT Program Guide. NAEP Table 8.1, "Emergency

Preparedness Training," lists select emergency response positions, along with an overview of

the training provided. Dominion may award equivalency credit for training sessions based on

an individual's knowledge of the subject matter.

SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with

existing State and local emergency plans. The SSAR, therefore, relies on and refers to the

information contained in these existing plans. No significant differences exist between major

features proposed in the-application and the major features discussed in existing plans and

relied on in the application.

Appendix 12, "Training and Exercises," to the COVRERP states that the licensee will provide

site-specific emergency'response training to State and local officials and to local emergency

units that may be called upon to provide assistance in the event of an emergency. The licensee

will invite offsite agencies to participate in annual drills held at the nuclear facility. VDEM will

coordinate and provide an ongoing training program for instructing State and local personnel to.

perform necessary emergency functions. VDEM will offer all State and local emergency

response personnel comprehensive training through the Radiological Emergency Response.

Preparedness Program on an annual basis. Federal agencies with radiological emergency

responsibilities will provide training to State and local officials within their areas of

responsibilities. The county RERPs note that the counties, in conjunction with the State, will

participate in and provide training to involved organizations and individuals.

Appendix 12 to the COVRERP further states that various personnel (e.g., police, firefighters,

first aid, and rescue personnel) will achieve proficiency in their primary skills through recognized

ongoing training programs'during their professional development. They will acquire unique

radiological emergency response'skills through in-house training programs and programs

presented by the licensee and State agencies. State agency and local department heads will

train State and county personnel responsible for the transmission of emergency information and

instructions. Training will consist of notification form use, verification procedures, 7

recordkeeping, and filing of messages. Training programs will be continuous.

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_IIX

In RAI 13.3-14(l), the staff asked the applicant for additional information regarding a description

in the COVRERP of the program for qualifying State and local directors/coordinators of

emergency response. In its response to this RAI dated October 20, 2004, the applicant stated

that, as reflected in Appendix 12 to the COVRERP, VDEM provides an ongoing training

program for instructing State and local personnel to perform emergency response functions.

The RERP annually offers training to all State and local emergency response personnel. This

program includes basic response information, as well as job-specific training. The RERP

maintains a detailed database, which consists of courses completed by individuals within the

last 5 years.

13.3.3.14.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to 10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states that Supplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III and IV.F of Appendix E to 10 CFR Part 50.

Under 10 CFR 52.17(b)(2)(i), an applicant for an ESP may propose major features of the

emergency plans for NRC review and approval, in consultation with FEMA, in the absence of

complete and integrated emergency plans. Under 10 CFR 52.18, after consultation with FEMA,

the NRC will determine whether the major features of emergency plans submitted under l

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply to major feature 0, "Radiological Emergency Response Training."

Major feature 0 calls for the applicant to describe a radiological emergency response training

program for personnel who would implement the RERPs.

13.3.3.14.3 Technical Evaluation

In SSAR Section 13.3.2.2.2.o, the applicant stated that the NPSEPT Program Guide would

provide the framework for conducting specialized initial and periodic retraining for Dominion

personnel at the new units. The staff reviewed NAEP Section 8.3, "Training of Station

Personnel," and Section 8.4, "Training of Offsite Support Personnel," and they are consistent

with the information provided by the applicant in SSAR Section 13.3.2.2.2.o. In addition, the

COVRERP and the county RERPs are also consistent with SSAR Section 13.3.2.2.2.o, as well

as with the NAEP.

In RAI 13.3-14(I), the staff asked the applicant for information concerning the COVRERP

description of the program for qualifying State and local directors/coordinators of emergency

response. The staff identified the consideration of this information as Open Item 13.3-9. The

staff reviewed the applicant's response in their submittal dated October 20, 2004, and finds it

acceptable. Therefore, Open Item 13.3-9 is resolved. The staff finds that the applicant has

adequately described a training program for instructing and qualifying personnel who will

implement radiological emergency response plans and that the description also addresses

providing for specialized initial training and periodic retraining.

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l l lI
13.3.3.14.4 Conclusions -".-- r!. _ -

As discussed above, the applicant has described a radiological emergency response training

program for those who may be called on to assist in an emergency, including a training

program for instructing and qualifying personnel who would implement the radiological - -

emergency response plans. In addition, the applicant has described specialized initial training

and periodic retraining. Based on its review, the staff concludes that the proposed major

feature 0 is consistent with the guidelines in RS-002 and Supplement 2. Therefore, this feature

is acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections III, IV.A, and IV.F of Appendix E to 10 CFR Part 50, insofar as it describes the

essential elements of advanced planning that have been considered for radiological emergency

response training, as set forth above.

13.3.3.15 Responsibility for the Planning Effort-Development, Periodic Review, and

Distribution of Emergency Plans (Supplement 2, Major Feature P)

13.3.3.15.1 Technical Information in the Application

SSAR Section 1 3.3.2.2.2.p states that the responsibility for the planning effort resides with the

Virginia Power NEP department. The overall authority and responsibility for maintaining

emergency preparedness, as well as program implementation associated with the existing -

NAPS site, would be extended to include the ESP site. Individuals responsible for the planning

effort would be afforded training commensurate with their duties and existing knowledge, skills,

and abilities. This may include site-specific training and external training from the Emergency

Management Institute (EMI), National Emergency Training Center, Harvard School of Public

Health, and Nuclear Energy Institute (NEI).

The Virginia Power senior vice president for nuclear operations and chief nuclear officer have

the overall authority for maintaining emergency preparedness. The senior vice president for

nuclear operations is responsible for program implementation, and the vice president for

nuclear support services is responsible for program maintenance. The NAPS site vice

president is responsible for NAPS site emergency preparedness. The director of nuclear

protection services and emergency preparedness is responsible for maintaining emergency.-

preparedness at the NAPS, developing the ESP site major features emergency plan, and

coordinating the plan with other response organizations. The SSAR states that the applicant

would extend responsibility for NAPS emergency preparedness to include the ESP site.

With regard to updating emergency plans and agreements, SSAR Section 13.3.2.2.2.p.4 states

the following: .dFollowing approval of the emergency planning information in the Dominion ESP

site Major Features Emergency Plan, there is no requirement to update the plan

or its supporting-organization agreements until after an operating license is --

issued. Dominion would update the emergency planning information as

necessary in a COL application. Any changes that represent a decrease in the - . -

effectiveness of the previously approved information with respect to the

standards of 10 CFR 50.47(b) or requirements of 10 CFR 50, Appendix E, would

be specifically identified and addressed.

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Ir l

SSAR Section 13.3.2.2.2.p.5 states that the COL applicant would prepare the ESP site

emergency plan as part of its application. Upon issuance, the COL applicant would forward the

emergency plan and approved changes to organizations and appropriate'individuals with responsibility for its implementation. The COL applicant would mark revised pages to show where changes have been made, and it would date or mark the pages with a revision number

associated with an effective date.

The SSAR provides a table of contents, which includes emergency planning information

contained in Part 2 of the application. SSAR Table 13.3-2 provides the appropriate cross-reference to the Supplement 2 criteria.

SSAR Section 13.3.2.2 states that the ESP site is adjacent to a preexisting nuclear facility with existing State and local emergency plans. The SSAR, therefore, relies on and refers to the information contained in these existing plans. No significant differences exist between major features proposed in the application and the major features discussed in existing plans and

relied on in the application.

Appendix 12, "Training and Exercises," to the COVRERP states that individuals within State agencies charged with radiological'emergency response planning will undergo training to qualify them in the essential elements of radiological response planning necessary to deal with the offsite effects of an accident at a nuclear facility. Training will emphasize the development of State and local plans that meet current Federal guidelines. VDEM will supervise continuous' training and will send key planners to the radiological emergency planning course at EMI.

COVRERP Section Xl, "Execution," states that the State coordinator of emergency management has overall authority and responsibility for radiological emergency response planning. This includes developing and updating the plans and coordinating them with other

response organizations. The county RERPs state that the county director or emergency services coordinator has overall authority and responsibility for radiological emergency response planning in the county. The counties, in conjunction with the State, will participate in, and provide training to, the county director or emergency services coordinator.

COVRERP Section Xl also notes that the State coordinator of emergency management will maintain, review, update, and certify the COVRERP annually. The State will periodically review letters of agreement, at a minimum of every 2 years. Responsible officials from State agencies and local governments will recommend appropriate improvements or changes at any time to the State coordinator of emergency management. The State will forward the COVRERP, along with approved amendments, to all organizations and individuals responsible for implementation. Revised pages will be dated and marked to show where changes have been made. The COVRERP has a specific table of contents and is cross-referenced to the NUREG-0654/FEMA-REP-1 criteria. Each county will review its plan and procedures annually and will distribute them to individuals and organizations responsible for their implementation. The county RERPs have a record of changes at the beginning of the plans, with revision dates

on each page. In addition, they include a specific table of contents and cross-reference to the

NUREG-0654/FEMA-REP-1 criteria.

In RAI 13.3-13 and RAls 13.3-14(m), (n), and (o), the staff asked the applicant for additional information regarding cross-references to Supplement 2, as well as a description of the training program and review/update of the RERP and agreements for Orange County. In its response

13-56
to these RAls dated October 20, 2004, the applicant stated that VDEM provides initial training

':and retraining for the emergency services coordinator and other emergency services related

personnel (i.e., EOC support staff). The Orange County RERP maintains a record of change,

and training and exercises are conducted to assure the adequacy and update of the plan on a

biennial basis. The applicant also provided a cross-reference to Supplement 2.

13.3.3.15.2 Regulatory Evaluation

SSAR Section 13.3.2.2 presents the major features of the applicant's emergency plan. The

applicant stated that it prepared the information presented in SSAR Section 13.3.2.2 in

accordance with 10 CFR 52.17(b)(2)(i) and Appendix E to '10 CFR Part 50, and considered the

guidance in Supplement 2. SSAR Section 13.3.2.2.2 states thatfSupplement 2 presents

planning standards and evaluation criteria applicable to a major features emergency plan.

In its review of the application, the staff considered the regulatory requirements in 10 CFR

52.17(b)(2)(i), 10 CFR 52.18, and Sections III, IV.A, IV.F, and IV.G of Appendix E of 10 CFR

Part 50. -Under 10 CFR 52.1 7(b)(2)(i), an applicant for an ESP may propose major features of

the emergency plans for NRC review and approval, in consultation with FEMA, in the absence

of complete and integrated emergency plans. -Under 10 CFR 52.18, after consultation with

FEMA, the NRC will determine whether-the major features of emergency plans submitted under

10 CFR 52.17(b)(2)(i) are acceptable. RS-002 and Supplement 2 provide guidance concerning

the review and evaluation of emergency planning information given in an ESP application.

Supplement 2 also provides specific evaluation criteria for major features of emergency plans,

including those which apply to major feature P, 'Responsibility for the Planning Effort:

Development, Periodic Review, and Distribution of Emergency Plans." ' -

Major feature P calls for the applicant to describe the development, review, distribution, and

update of emergency plans. The application should also designate an emergency planning

coordinator for each organization and identify (by title) individuals with emergency planning

responsibility. In addition, the application should describe training for those responsible for the'

planning effort.

13.3.3.15.3 Technical Evaluation

The application describes, by title, the individuals with overall authority and responsibility for

radiological emergency response planning.- This description includes the develop hnt and

update of plans and coordination with other response organizations. SSAR '

Section 1 3.3.2.2.2.p identifies the director of nuclear protection services and emergency

preparedness as the person responsible for emergency planning for the ESP site. The ' COVRERP identifies the State coordinator of emergency management, and the county RERPs

identify either the county director or emergency services coordinator.

For the applicant, training includes site-specific training and external training from organizations

such as EMI, the National Emergency Training Center, the Harvard School of Public Health,

and NEI. State emergency planners will receive continuous training on the essential elements

of radiological response planning and will be sent to the radiological emergency planning

course at EMI. County planners will receive training from the county, in conjunction with the

State.

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SSAR Section 13.3.2.2.2. p.5 states that the COL applicant will forward approved plan changes

to appropriate organizations and individuals and mark and date updates; COVRERP Section Xl

indicates that the State updates its plan annually and periodically reviews the letters of

agreement (at least every 2 years). The State and local governments can make recommended

updates at any time and will forward them to all organizations and individuals responsible for

implementation. Local governments will review the county RERPs annually and distribute the

updated plans and procedures. The COVRERP and county RERPs, which contain a table of

contents, will be dated and marked to show where changes have been made.

In Section 13.3.2.2.2.p.4 of the SSAR, the applicant stated that no requirement exists to update

the emergency plan or its~supporting organization agreements until after an operating license is

issued. The regulations in 10 CFR 52.79(d) currently do not require such updating in a COL

application. Therefore, a COL application could propose an emergency plan incorporating

emergency preparedness information approved in an ESP without updating. Nonetheless, to

the extent that emergency preparedness information approved in an ESP is no longer current

when a COL application incorporating that information by reference is submitted pursuant to

10 CFR 52.79, "Contents of Applications; Technical Information," that information will need to

be updated. The staff will not approve emergency plans proposed in a COL application under

10 CFR 52.79(d) if such plans are based upon obsolete or superceded information. The nature

and depth of the staff review of the updated information may vary depending on the nature of

the update. In all cases, any changed information would be subject to challenge in the COL

proceeding. While updating of previously approved emergency preparedness information is not

currently required, the Commission has proposed to add a provision in 10 CFR Part 52, "Early

Site Permits; Standard Design Certifications; and Combined Licenses for Nuclear Power

Plants," to require such updating, as discussed in the Notice of Proposed Rulemaking for

10 CFR Part 52 (Federal Register, Vol. 68, p. 40026). The staff will determine compliance with

the requirements in this area during a COL application review based on the regulations in effect

at that time. In addition, the applicant stated in SSAR Section 13.3.2.2.2.p.4 that "[amny

changes that represent a decrease in effectiveness of the previously approved information with

respect to the standards of 1 0 CFR 50.47(b) or requirements of 10 CFR 50, Appendix E, would

be specifically identified and addressed." The staff did not consider this information essential to

its review and, therefore, did not evaluate it.

In RAI 13.3-13 and RAls 13.3-14(m)-(o), the staff asked for information concerning crossreferences to Supplement 2, as well as a description of the training program and review/update

of the RERP and agreements for Orange County. The staff identified the consideration of this

information as Open Item 13.3-10. The staff reviewed the applicant's responses in their

submittal dated October 20, 2004, and finds them acceptable. Therefore, Open Item 13.3-10 is

resolved. The staff finds that the applicant has adequately described the responsibilities for

emergency plan development, review and distribution, and for the training of emergency

planners.

13.3.3.15.4 Conclusions

As discussed above, the applicant has described the responsibilities for plan development and

review and for distributing and updating emergency plans. In addition, the applicant has

identified those responsible for the planning effort and has described the training that they

receive. Based on its review, the staff concludes that the proposed major feature P is

consistent with the guidelines in RS-002 and Supplement 2. Therefore, this feature is

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-

acceptable and meets the requirements of 10 CFR 52.17(b)(2)(i), 10 CFR 52.18, and

Sections Ill, and IV.A, IV.F, and IV.G of Appendix E to 10 CFR Part 50, insofar as it describes

the essential elements of advanced planning that have been considered related to the

responsibility for the planning effort, including the development, periodic review, and distribution

of emergency plans, as set forth above.

13.6 Industrial Security

The NRC staff reviewed the physical security aspects of the ESP application to determine

whether site characteristics are such that adequate security plans and measures can be

developed.

13.6.1 Technical Information In the Application

In Section 13.6 of the SSAR, the applicant stated that it would extend the protected area of the

existing Units 1 and 2 at NAPS to accommodate any new units constructed on the ESP site:

The applicant stated that the site characteristics are such that the applicable NRC regulations,

guidance documents, and orders can be met. -The-applicant based this conclusion-on the size

of the NAPS site, which is sufficiently large to provide adequate distances between vital areas

and the probable location of a security boundary.

In RAI 13.6-1, the staff asked the applicant to describe how the ESP plant parameter envelope

(PPE) and surrounding terrain features will provide at least 360 ft of distance (as specified in

Regulatory Guide (RG) 4.7, Revision 2, "General Site Suitability Criteria for Nuclear Power

Stations," issued April 1998) between vital equipment/structures and physical protection

components (e.g., protected area barriers and isolation zones). In its response, the applicant

stated that the protected area and related isolation zone would be constructed to comply with

the requirements of 10 CFR 73.55(c), and that the protected area barrier would be of sufficient

size to support the security response strategy timelines.

Section 13.6 of the SSAR states that Dominion has a security program in place for the existing

units and notes that the program complies with the NRC's "Order for Interim Compensatory

Measures," dated February 25, 2002, regarding waterborne threats. The SSAR further

concludes that Dominion anticipates that it will continue to meet those requirements in the event

that it adds new units to the site. Section 13.6 also states that the COL-application would

address final design features for the new units' power blocks and supporting buildings,-as

appropriate, to ensure adequate site security. Finally, SSAR Section 13.6 concludes that no

security hazards are created from nearby hazardous material facilities.

Section 2.2.2.7 of the SSAR describes pipelines that are of potential concern.

13.6.2 Regulatory Evaluation

In Sections 1.8 and 13.6 of the SSAR, the applicant identified 10 CFR 100.21(f) and

10 CFR 73.55, "Requirements for Physical Protection of Licensed Activities in Nuclear Power

Reactors Against Radiological Sabotage," as the applicable regulations and noted that RG 4.7,

Revision 2, provides applicable guidance. 'The staff reviewed this portion of the application for

13-59
conformance with the applicable regulations, and considered the corresponding regulatory

guidance as identified above.

The NRC regulations require that applicants for an ESP address characteristics of the proposed

site that could affect security. Specifically, 10 CFR 52.17, uContents of Applications," requires

that site characteristics comply with 10 CFR Part 100, "Reactor Site Criteria"; 10 CFR 100.21 (f)

states that site characteristics must be such that applicants can develop adequate security

plans and measures. In RG 4.7, Revision 2, the NRC provides amplifying guidance and notes

that 10 CFR 73.55 describes physical protection requirements for nuclear power plants.

Review Standard (RS)-002, "Processing Applications for Early Site Permits," notes that the

NRC staff has provided guidance to the first three prospective ESP applicants in three

substantially identical letters (ADAMS Accession No. ML030980003 for the Dominion

application). RS-002 adds that these letters should be used for review guidance for the ESP

applications to which they apply. Specifically, the Dominion letter requested that the ESP

application discuss certain characteristics as they relate to implementing a physical security

plan for a postulated facility. In addition, the letter stated that the applicant should consider the

interim compensatory measures (ICMs) imposed on power reactors by Order dated

February 25, 2002, and the design-basis threat for reactors which was issued by Order dated

April 29, 2003. However, RS-002 also notes that the NRC's security orders referenced in the

letter are, by their nature, subject to modification depending on changes in the terrorist threat.

The security orders do not form part of the licensing basis of the ESP and are not imposed as

conditions of prospective permits. The security review of ESP applications is based on the -

requirements of 10 CFR Part 100 and 10 CFR Part 73, "Physical Protection of Plants and

Materials," or other applicable existing regulations.

13.6.3 Technical Evaluation

The staff reviewed the application and responses to its RAIs and examined aspects of the

application during an onsite visit. The proposed ESP site is located on the shore of Lake Anna

in Louisa County, Virginia, near two licensed nuclear power reactors (North Anna, Units 1 and

2) owned by Virginia Electric and Power Company, an affiliate of the applicant. The NAPS site

is defined by a 5000-ft radius circle originating from the center of the partially constructed, but

now abandoned, North Anna Unit 3 (see Figure 1.2-4, note 3, in the application). The ESP PPE

(site footprint) that bounds the prospective location for any new nuclear power reactors that

might be constructed on the proposed ESP site is located directly west of the existing NAPS

protected area and no closer than 800 yards to the site boundary.

Using the criteria set forth in 10 CFR 100.21 (f), the staff identified and considered various

characteristics of the site that could affect the establishment of adequate security plans and

measures. The staff considered pedestrian land approaches, vehicular land approaches,

railroad approaches, water approaches, potential "high-ground" adversary advantage areas,

nearby road transportation routes, nearby hazardous materials facilities, nearby pipelines, and

culverts that could provide a pathway into the protected area.

With respect to pedestrian approaches, the staff found that various figures in the application

(e.g., Figure 1.0-1) identify the applicant's PPE (within which all safety-related structures would

be located if one or more reactors were to be constructed there). In RAI 13.6-1, the staff asked

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the applicant to identify its plans to address the guidance in RG 4.7, Revision 2, which specifies

that an applicant provide a rminimum of 360 ft between protected area barriers and vital areas to

allow for appropriate barriers, detection equipment, isolation zones, and vehicle barriers to

protect vital equipment. In its response, the applicant stated that protected area barriers would

be separated from vital area barriers, and be of sufficient size to support the security response

strategy timelines. The staff concluded that the distance from planned locations of vital

equipment and structures (which might be located anywhere in the PPE (ESP site'footprint)

because a design is not specified at the ESP stage) to the planned 'protected area boundary

can be made sufficiently large so that holders of a COL or construction permit (CP) could -

appropriately locate delay barriers, isolation zones, detection equipment, and vehicle barriers to

protect vital equipment and structures.

With respect to water approaches, the staff noted that vital equipment for the existing NAPS

units is sufficiently far from Lake Anna that restrictions to lake access are not required. The

need for such restrictions for any new units would depend on the design of the units and their

location on the ESP footprint (PPE). The site configuration would not present any significant

impediments to development of such restrictions.

With respect to vehicular land and railroad approaches, the staff identified existing roads,-rail

spurs, and site terrain features. The staff concluded that the location of existing roads and site

terrain features does not preclude the establishment of adequate vehicle control measures to

(1) prevent the use of a land vehicle to gain unauthorized proximity to vital areas and (2) protect

against a vehicle bomb. The staff based its conclusion on the fact that the location of the

existing vehicle checkpoint, which could be used for vehicular control to the ESP site, has

adequate standoff distance from the PPE to mitigate vehicle-bomb overpressure effects.

Further, the staff confirmed during a site visit that the terrain features on all borders of the site

are amenable to the implementation of a vehicle barrier system.

With respect to threats posed by deliberate vehicle explosions on nearby transportation routes,

the staff noted that, in SSAR Section 2.2.3.1.1, the applicant analyzed a gasoline tanker

explosion involving 8500 gallons of gasoline detonated on Virginia Highway 652 at a point

1.5 miles from the proposed site. The staff performed an independent calculation for the tanker

explosion and found different results than the applicant's because the applicant did not take into

account the 240 percent (mass) equivalence for substances subject to vapor-phase explosions

(see RG 1.91, Revision 1, "Evaluations of Explosions Postulated to Occur on Transportation

Routes Near Nuclear Power Plants," issued February 1978). Nevertheless, the staff's analysis

reached the same conclusion as the applicant, that such an event would not result in an

overpressure of greater than 1 pound per square inch (psi) at the site boundary. The pressure

threshold for human eardrum rupture is 5 psi, which is the first point of human incapacitation

(see U.S. Army Technical Manual 5-1300, "Structures to Resist the Effects of Accidental

Explosions,' issued November 1990). A peak positive overpressure of 1 psi is a conservative

threshold below which no significant damage would be expected for systems, structures, and

components of concern (RG 1.91, Revision 1). The applicant did not identify any other

hazardous materials transported on the nearby roadways.

With respect to nearby hazardous materials facilities and nearby pipelines, the staff found that

the distances to those facilities and pipelines and the materials identified associated with them

are of such a nature that they do not pose an impediment to the development of adequate

security plans or measures.

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The staff examined the overall site terrain with respect to features (including existing manmade

features, such as culverts, as well as natural features) that potential adversaries could use to

their advantage. The features that exist at the ESP site do not preclude the establishment of

adequate security plans and measures.

Considering RG 4.7, special measures may be needed to support the security response

strategy timelines requirements of 10 CFR 73.55(c). Since the exact locations and design of

barriers is not known at the ESP stage, the staff identified a COL action item for the COL or CP

applicant to provide specific designs for protected area barriers to support the security

response strategy timelines. This is COL Action Item 13.6-1.

13.6.4 Conclusions

As set forth above, the staff examined the site characteristics with respect to their potential to

affect the establishment of adequate security plans and measures. The staff examined

pedestrian, vehicle, and water approaches, including existing culverts, nearby hazardous

materials facilities, nearby pipelines, nearby railroad lines, and other transportation routes, as

well as terrain features. Based on the above evaluation, the staff concludes that the ESP site

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

and measures for a reactor(s) that it might construct and operate on the ESP site.

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15. ACCIDENT ANALYSES

15.1 Technical Information in the Application

In Chapter 15, "Accident Analyses," of the site safety analysis report (SSAR), the applicant

analyzed and provided the radiological consequences of design-basis accidents '(DBAs) to

demonstrate that new nuclear units could be sited at the proposed early site permit (ESP) site

without undue risk to the health and safety of the public, in compliance with the requirements of

Title 10, Section 52.17, "Contents of Applications," of the Code of Federal Regulations (10 -CFR

52.17) and 10 CFR Part 100, "Reactor Site Criteria." The applicant did not identify a parti6ular''

reactor design to be considered for the proposed ESP site.. Instead, the applicant developed a

set of reactor DBA source term parameters using surrogate reactor characteristics. -The -

applicant used these parameters in conjunction with site characteristics for accident analysis

purposes to assess the suitability, of the proposed ESP site. These plant parameters

collectively constitute a plant parameter envelope (PPE).

The applicant developed a PPE using seven reactor designs-five water-cooled reactors and

two gas-cooled reactors-though it used source terms for only two of these designs as inputs to

its DBA analyses. The water-cooled reactors included in the PPE were (1) a version of the - Westinghouse Advanced Plant .1000 (API000), (2) the certified General Electric'Advanced'

Boiling-Water Reactor (ABWR), (3) the Atomic Energy of. Canada Advanced CANDU Reactor.

(ACR-700), (4) the General Electric Economic and Simple Boiling-Water Reactor' (ESBWR),

and (5) the Westinghouse-led International Reactor Innovative and Secure (IRIS) reactor. The

ACR-700 is light-water cooled but heavy-water moderated. The two gas-cooled reactors were

(1) the General Atomics Gas Turbine Modular Helium Reactor (GT-MHR) and (2) the'Pebble

Bed Modular Reactor (PBMR). The applicant stated that the PPE values are not intended to be

limited to these reactor designs but rather to provide a broad overall outline' of a design concept

and to include other potential reactor designs if they fall within the pairameter values provided in

the PPE.

In selecting DBAs for dose consequence analyses, the applicant focused on two light-water

reactors (LWRs), the certified ABWR and a version of the AP1 000,1 to serve as surrogates'.

The applicant stated that it selected these two reactor designs because they are (or are based

on) previously certified standard designs and have recognized bases for postulated accident

analyses; Using source terms developed from these'two designs, the a'plicant performed and'

provided radiological consequence analyses for the following DBAs:

* pressurized-water reactor (PWR) main steamline break

* PWR feedwater system pipe break

* locked rotor accident:-

* reactor coolant pump shaft break,. -

* PWR rod ejection accident -

As discussed later in this section, the applicant referenced a version of the APi 000

design available at the time it submitted its ESP application. Westinghouse subsequently

revised the AP1O000'design before the U.S. Nuclear Regulatory Commission (NRC) staff's- - - issuance of a final safety evaluation report (SER) for the AP1000 design certification.

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* boiling-water reactor (BWR) control rod drop accident

* failure of small lines carrying primary coolant outside containment

* PWR steam generator tube failure

* BWR main steamline break

* PWR and BWR loss-of-coolant accidents (LOCAs)

* fuel-handling accident

The applicant presented the dose consequence assessment results in SSAR Chapter 15.

Table 15.4-1, uSummary of Design Basis Accident Doses," provides a'summary of the

postulated radiological consequences of the DBAs identified above at the proposed exclusion

area boundary (EAB) and the low population zone (LPZJ. The table also demonstrates that any

potential doses would be'within the radiological dose consequence evaluation factors set forth

in 10 CFR 50.34(a)(1). The applicant provided the accident-specific source terms (release

rates of radioactive materials from the ESP footprint (PPE values) to the environment) and

resulting site-specific dose consequences for each DBA in Tables 15.4-2 through 15.4-27 of the

SSAR.

In Request for Additional Information (RAI) 15.4-1, the staff noted that Westinghouse has

revised its atmospheric dispersion factors (X/Q values) in the AP1000 design control document

(DCD) since the applicant'submitted the North Anna ESP application, and it asked whether the

applicant planned to use the updated values in revising its application. The applicant

responded that it elected not to update the ESP application to incorporate the latest X/Q values

in the AP1000 design certification. The applicant further stated that site-specific doses would.

be updated, as necessary, in any combined license- (COL) or construction permit (CP)

application, after a specific reactor design is selected.

In RAls 15.4-2 and 15.4-3, the staff noted that SSAR Section 15.4 provides total effective dose

equivalent (TEDE) values for the ABWR design, while the ABWR design is certified with the

thyroid and whole body'doses specified in 10 CFR Part 100.- The staff asked the applicant to

compare these doses. In its response, the applicant stated that it would revise the SSAR to

include the thyroid and whole body doses from the ABWR DCD, in addition to the estimated

TEDE values. The applicant incorporated this information into its application.

In RAI 15.4-4, the staff asked the applicant to provide references and explain the methodology'

it used to determine time-dependent activity releases for each DBA. The applicant provided the

requested references. In its response, the applicant stated that the respective DCDs present

the methodologies used for calculating time-dependent releases for the ABWR and AP1000.

The staff finds the methodologies used in the respective DCDs to be acceptable.

In RAI 15.4-5, the staff asked the applicant to provide, for each DBA, the doses it used for the

EAB and the LPZ for the AP1000 and the ABWR, as well as the ratios of site-specific x/Q

values to design certification x/Qs used. In its response, the applicant stated that it would

revise the dose tables in SSAR Section 15.4 to show the X/Q values'and doses from the

AP1 000 and ABWR DCDs, in addition to the ratios of site-specific x/Q values to design

certification x/Q values. The applicant incorporated this information into its application.

In RAI 15.4-6, the staff asked the applicant to clarify whether the 0- to 2-hour EAB doses

presented in the SSAR are for the 2-hour period with the greatest EAB doses and, if they are

not, to provide the doses for the 2-hour period with the greatest EAB doses. In its response,

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the applicant stated that the greatest EAB dose occurs during the first 2 hours of the accident

for all APIOQO accidents evaluated in SSAR Chapter 15, except for a LOCA. As indicated in

Section 15.6.5.3.8.1 of the AP1000 DCD, the period from 1 to 3 hours yields the greatest EAB

dose for a LOCA. The applicant incorporated this information into its application.

15.2 Regulatory Evaluation

In SSAR Section 1.8 and in SSAR Chapter 15, the applicant identified the following applicable

NRC regulations and guidance regarding reactor accident radiological consequence analyses:

* - 10 CFR 52.17

* O'CFR Part 100

* 10 CFR 50.34, "Contents of Applications; Technical Information"

* ' Regulatory Guide (RG) 1.3, uAssumptions Used for Evaluating the Potential Radiological

Consequences of a Loss of Coolant'Accident for Boiling Water Reactors," issued June

1974

* RG 1.25, "Assumptions Used for Evaluating the Potential Radiological Consequences of

a Fuel Hanfdling' Accident in the Fuel Handling and Storage Facility for Boiling and

Pressurized Water Reactors," issued March 1972 -

* RG 1.145, "Atmospheric Dispersion Models for Potential Accident Consequence

Assessments at Nuclear Power Plants," issued November 1982

* RG 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis

Accidents at Nuclear Power Reactors," issued July 2000

* NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for

Nuclear Power Plants," issued July 1981

* TI D-1 4844, "Calculation of Distance Factors for Power and Test Reactor Sites," issued

March 1962

The staff reviewed SSAR Section 1.8 and Chapter 15 for conformance-with the applicable.

regulations, and considered the corresponding guidance, as identified above. In its evaluation,

the staff used the 'dose consequence evaluation'factors found in 10 CFR 50.34(a)(1) that are a

factor in determining the-acceptability of the site in accordance with 10 CFR 52.17(a)(1).

The regulations at 10 CFR 52.17(a)(1) require that'ESP applications contain an analysis and

evaluation of the major structures, systems, and components of the facility that bear

significantly on the acceptability of the site under the radiological consequence evaluation

factors identified 'in 10 CFR 50.34(a)(1). -In addition, the ESP site characteristics must comply

with the requirements of 10 CFR Part 100.I-The regulations at 10 CFR 50.34(a)(1)(ii)(D) require

the following for a postulated fission product release based on a major accident:

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* An individual located at any point on the boundary of the exclusion area for any 2-hour

period following the onset of the postulated fission product release would not receive a

radiation dose in excess of 25 rem TEDE.

* An individual who is located at any point on the boundary of the LPZ and who is

exposed to the radioactive cloud resulting from the postulated fission product release

(during the entire period of its passage) would not receive a radiation dose in excess of

25 rem TEDE.

Because the applicant has not selected a reactor design to be constructed on the proposed

ESP site, the applicant used a PPE approach to demonstrate that it meets these requirements.

A PPE is a set of plant design parameters that are expected to bound the characteristics of a

reactor(s) that may be constructed at a site, and it serves as a surrogate for actual reactor

design information. As discussed in NRC Review Standard (RS)-002, "Processing Applications

for Early Site Permits," and in Chapter 1 of this SER, the staff considers the PPE approach to

be an acceptable method for assessing site suitability. For the purposes of this analysis, the

applicant proposed a fission product release from the PPE (ESP footprint) to the environment,

and the staff reviewed the applicant's dose evaluation based on this release.

15.3 Technical Evaluation

The applicant evaluated the suitability of the site under the radiological consequence evaluation

factors identified in 10 CFR 50.34(a)(1) using bounding reactor accident source terms and dose

consequences as a set of PPE values based on two surrogate designs, as well as site-specific

X/Q values based on the ESP footprint. The following paragraphs describe the staff's review of

each aspect of this evaluation.

15.3.1 Selection of DBAs

The applicant selected the DBAs listed in Section 15.1 of this SER, based on the proposed

AP1000 reactor design and the certified ABWR reactor design, indicating that it chose these

two reactor designs because they have (or are based on) previously certified standard designs

and have recognized bases for postulated accident analyses. The staff finds that the applicant

selected DBAs which are consistent with the DBAs listed and analyzed in NUREG-0800 and

RG 1.183. Therefore, the staff finds that the applicant provided an acceptable DBA selection

for evaluating the compliance of the proposed ESP site with the dose consequence evaluation

factors specified in 10 CFR 50.34(a)(1). The applicant stated that, because of their greater

potential for inherent safety, the DBAs of the other reactors being considered for the proposed

ESP site are expected to be bounded by those DBAs analyzed in the proposed AP1 000 and

certified ABWR DCDs. While the staff has not reviewed these designs other than the proposed

AP1000 and certified ABWR in detail, it believes that conclusions drawn regarding the site's

acceptability based on the AP1000 and ABWR designs are likely to be valid for the other

reactor designs that the applicant is considering. At the time of any COL or CP application that

might be filed with respect to construction and operation of a reactor at the North Anna ESP

site, the applicant will confirm, and the staff will evaluate, whether the analyses considered here

bound the design proposed in the COL or CP application.

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15.3.2 Design-Specific (Assurmed) X/Q Values

To support its accident analyses based on the ABWR as a surrogate design, the applicant used

the assumed X/Q values' in the certified ABWR'DCD. In evaluating the AP1000, the applicant

used those X/Q values in the proposed AP1000 DCD that were under review by the staff at thetime the North Anna ESP application was submitted. Westinghouse subsequently revised the

X/Q values in the AP1000 DCD. Consequently, the assumed X/Q values and the calculated

design-specific doses used in the North Anna ESP application may differ from those associated

with a certified API 000 DCD. However, the staff determined that the PPE values for the

assumed X/Q values associated with the AP1 000 design used by the applicant in its accident

analyses are reasonable and, therefore,' that they are adequate for the purpose of

demonstrating that a reactor with design characteristics similar to an AP1 000 could be sited at

the proposed ESP site. Section 15.4 of the SSAR lists the X/Q values the applicant used for the

version of the AP1 000 and the certified ABWR that it considered.

In Table 1.3-1 of the SSAR, the applicant also listed a set of design-specific assumed

X/Q values, some of which neither the applicant nor the staff used in their radiological

consequence evaluations. The staff finds that the X/Q values in'Table 1.3-1, with the exception

of those used in the applicant's dose assessments in Chapter 15 of the SSAR, are not needed

to assess the'suitability of the proposed site. Therefore, the staff did not review them.;

15.3.3 Site-Specific Was

The staff reviewed the applicant's site-specific X/Q values and performed an independent

evaluation of atmospheric dispersion in accordance -with the guidance provided in Section 2.3.4

of RS-002. The staff finds the X/Q values to be acceptable, -as described in Section 2.3.4 of this

SER. The staff intends to include these site-specific x/Qs in any ESP that the NRC may issue

for the North Anna ESP site.

15.3.4 Source Terms and Radiological Consequence Evaluations

To evaluate the suitability of the site using the radiological consequence evaluation factors in

10 CFR 50.34(a)(1), the applicant provided the bounding reactor accident source terms as a set

of PPE values based on (1) the surrogate AP1 000 and 4386 megawatt thermal (MWt) ABWR -

designs (as explained below) and (2) the site-specific X/Qs based on the ESP footprint. The

source terms are expressed as the timing and release rate of fission products to the'

environment from the proposed ESP site. The dose consequences are then derived from the

source terms using established methods.

The AP1 000 source terms are based on the guidance provided in RG 1.183. The

methodologies and assumptions used by Westinghouse, the AP1000 vendor, in its radiological

consequence analyses are consistent with the guidance provided in RG 1.183. The resulting

doses calculated for the AP1000 design using assumed site parameters meet the dose

consequence evaluation factors sp'ecified in 10 CFR 50.34(a)(1) (i.e., 25 rem TEDE). The

methodologies and assumptions used by General Electric, the ABWR vendor, in its radiological

consequence analyses for the ABWR design are corisistednt with'the guidance provided in

RGs 1.3 and 1.25. <The ABWR source terms are based on the guidance in TID-1 4844.' The

resulting doses for the' ABWR reactor design using assumed site parameters meet the dose

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consequence evaluation factors specified in 10 CFR 100.11, "Determination of Exclusion Area,

Low Population Zone, and Population Center Distance," which are 300 rem to the thyroid and

25 rem to the whole body. While the requirements of 10 CFR 100.11 are not applicable to

ESPs, the staff notes that the final rule at Appendix A, "Design Certification Rule for the U.S.

Advanced Boiling Water Reactor," to 10 CFR Part 52, "Early Site Permits; Standard Design

Certifications; and Combined Licenses for Nuclear Power Plants," states the following:

The Commission has determined that with regard to the revised design basis

accident radiation dose acceptance criteria in 10 CFR 50.34, the ABWR design

meets the new dose criteria, based on the NRC staff's radiological consequence

analyses, provided that the site parameters are not revised.

Therefore, the staff concludes that the certified ABWR design, in conjunction with assumed site

parameters, meets the dose consequence evaluation factors specified in 10 CFR 100.11, as

well as those specified in 10 CFR 50.34(a)(1).

In its site-specific DBA radiological consequence analyses, the applicant scaled the ABWR

source terms and the resulting doses from the power level, certified under Appendix A to

10 CFR Part 52, of 4005 MWt to 4386 MWt for its version of the ABWR. The applicant used a

linear scaling method. Because the fission product release rate is directly proportional to the

fission product inventory if mitigating processes remain the same, and because the fission

product inventory is directly proportional to reactor power, the staff finds this scaling

methodology to be acceptable for the purposes of this evaluation.

In determining the potential radiological consequence doses resulting from DBAs at the

proposed site, the applicant used the site-specific atmospheric dispersion factors (X/Q values)

in conjunction with the DBA radiological consequence doses and its postulated x/Q values

provided in the SSAR of the certified ABWR (SSARIABWR) 'and the proposed AP1000 DCD.

The certified ABWR and the proposed API 000 designs met the radiological consequence

evaluation factors identified in 10 CFR 50.34 (a)(1) with their postulated X/Q values.

The x/Q values indicate the atmospheric dilution capability. Smaller X/Q values are associated.

with greater dilution capability, resulting in lower radiological doses.. The radiological

consequence doses are directly proportional to the X/Q values. The applicant provided the sitespecific X/Q values used in its radiological consequence analyses in Table 1.9-1 of the SSAR,

and the staff discussed and evaluated their X/Q values in Section 2.3.4 of this SER.

The applicant used the atmospheric dispersion computer code (PAVAN) to derive its sitespecific X/Q values and the staff has revised Section 2.3.4 of this SER to indicate that a copy of

the input files used by the applicant to execute PAVAN can be found in the applicant's response

to RAI 2.3.4-1. The staff described the PAVAN code calculations for the North Anna site in

more detail in Section 2.3.4 of this SER.

The applicant used the ratios of the site-specific X/Q values to those postulated in the

SSARIABWR and AP1000 DCD to determine and demonstrate that the radiological

consequence doses at the proposed site meet the requirements of 10 CFR 50.34. The

estimated site-specific x/Q values for the proposed site are lower than those postulated in the

SSARIABWR and APIOCO DCD. The certified ABWR and the proposed AP1000 designs met

the radiological consequence evaluation factors identified in 10 CFR 50.34 (a)(1) with their

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postulated X/Q values. Accordingly, the resulting DBA radiological consequence doses at the

proposed site are lower than those provided in the SSAR/ABWR and APIOQO DCD and,

therefore, meet the requirements of 10 CFR 50.34.:

The staff believes that accepting the radiological consequences of the DBAs at the proposed

site based on the AP1 000 and ABWR designs are likely to be valid for the other reactor designs

the applicant is considering. Whether or not the final reactor design selected by the applicant at

the North Anna ESP site is in fact bounded by the acceptance made here would be subject to

review during the staff's consideration of any COL or CP application. In accordance with '

10 CFR 52.79(a)(1), at the COL stage, the staff will evaluate whether the design of the facility

falls within the parameters specified in an ESP, should one be issued for the North Anna' ESP

site.

The staff has verified the design-specific source terms the applicant provided and finds them to

be consistent with those evaluated by the staff as part of the design certification reviews.

Further, the staff finds that the references provided by the applicant and the methodology it

used to determine timing and release rate of fission product source terms to the environment

(and consequent dose consequences) from the proposed ESP site are acceptable. Therefore,

the staff finds the source terms from the PPE (ESP footprint) themselves to be reasonable and

acceptable.- The staff intends to include the site-specific X/Q values as site characteristics listed

in Appendix A, in any ESP that the NRC might issue for the North Anna site.

In response to RAI 15.4-6, the applicant stated that the greatest EAB dose occurs during the

first 2 hours of the DBAs, except for the API000 'LOCA. In view of the accident progression

sequences for the designs used in the DBA dose assessment, the staff agrees with this

conclusion.

Based on its evaluation of the applicant's analysis methodology and inputs to that analysis, the

staff finds that the applicant's conclusion that the dose consequences for the chosen surrogate

designs comply with the dose consequence evaluation factors of 10 CFR 50.34(a)(1)' is correct.

Table 15.3-1 identifies the following site XIQ values as appropriate for inclusion in any ESP that

the staff might issue for the North Anna ESP site.

Table 15.3-1 Staff's Proposed Short-Term (Accident Release) Atmospheric Dispersion

Site Characteristics (Site-Specific XIQ Values)

LOCATION AND TIME INTERVAL X/Q VALUE

0-2 hour EAB 2.26x4 s/M3

0-8 hour LPZ 2.05x 5 s/M3

8-24 hour LPZ 1 .36x- s/m3

1-4 day LPZ 5.58x6 s/rM3

4-30 day LPZ 1.55x6 s/rM3

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RS-002 calls for the staff to perform a confirmatory radiological consequence calculation.

However, the design-related inputs to the applicant's dose calculation were directly extracted

from design documentation previously submitted to and reviewed by the NRC in connection

with design certification applications. Because the applicant simply used the ratio of the sitespecific x/Q values to the postulated design X/Q values, the staff did not consider an

independent calculation to be useful or necessary and, therefore, did not perform one.

15.4 Conclusions

As set forth above, the applicant submitted its radiological consequence analyses using the

site-specific X/Q values and PPE source term values and concluded that the proposed site

meets the radiological consequence evaluation factors identified in 10 CFR 50.34(a)(1).

Based on the reasons set forth above, the staff finds that the applicant's PPE values for source

terms that it included as inputs to the radiological consequence analyses are reasonable.

Further, the staff finds that the applicant's site-specific X/Q values and dose consequence

evaluation methodology are acceptable.

Therefore, the staff concludes that the proposed distances to the EAB and the LPZ outer

boundary of the proposed ESP site, in conjunction with the fission product release rates to the

environment provided by the applicant as PPE values, are adequate to provide reasonable

assurance that the radiological consequences of the DBAs will be within the dose consequence

evaluation factors set forth at 10 CFR 50.34(a)(1) for the proposed ESP site. This conclusion is

subject to confirmation at the COL or CP stage that the design of the facility specified by the

COL or CP applicant falls within the ESP PPE values.

The staff further concludes that (1) the applicant has demonstrated that the proposed ESP site

is suitable for power reactors with source term characteristics bounded by those of the

4386 MWt ABWR and AP1000 without undue risk to the health and safety of the public and

(2) the applicant complies with the requirements of 10 CFR 52.17 and 10 CFR Part 100.

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17. EARLY SITE PERMIT QUALITY ASSURANCE MEASURES

17.0 Introduction

Dominion Nuclear North Anna, LLC (Dominion or the applicant), supplied information on quality

assurance (QA) measures applied the to early site permit (ESP) activities the applicant and its

principal contractors conducted. The staff of the U.S. Nuclear Regulatory Commission (NRC)

conducted an inspection of the applicant's QA measures on November 17-21, 2003.

Subsequently, the staff performed an in-office technical review to evaluate whether the

applicant and its principal contractors had applied adequate QA measures. Specifically, the

staff conducted a review to determine whether the applicant adequately applied the guidance in

Section 17.1.1, "Early Site Permit Quality Assurance Controls," of Review'Standard (RS)-002,

"Processing Applications for Early Site Permits," to demonstrate the integrity and reliability of

data that were obtained during ESP activities.

-Under Title 1 0, Section 52.18, of the Code of Federal Regulations (10 CFR 52.1 8), 'Standard

for Review of Applications," the staff evaluates ESP applications in accordance with the- -

applicable regulations of 10 CFR Part 50, "Domestic Licensing of Production and Utilization

Facilities," and its appendices, as well as 10 CFR Part 100, "Reactor Site Criteria," as they

apply to construction permits. The current regulations do not require ESP holders or applicants

to implement a QA program compliant with the requirements of Appendix B, "Quality Assurance

Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50. However,

the applicant is expected to implement QA measures equivalent in substance to the measures

described in Appendix B to 10 CFR Part 50 to provide reasonable assurance that the

information derived from ESP activities that could be used in the design and/or construction of

systems, structures, and components (SSCs) important to safety would support satisfactory

performance of such SSCs once in service. Therefore, the staff evaluated quality measures for

activities associated with the applicant's generation of site-related information that could be an

input to the design of future SSCs to ensure that these measures could provide reasonable

assurance of the integrity and reliability of the information; assuming these measures were

equivalent in substance to the criteria of Appendix B to 10 CFR Part 50.

In accordance with 10 CFR 52.79(a)(1), if an application for a combined license (COL)

references an ESP, it must contain information sufficient to demonstrate that the design of the

facility falls within the site parameters specified in the ESP. Therefore, the ESP applicant must

provide reasonable assurance of the reliability and integrity of data contained in or supporting

the ESP application, which in turn supports any future COL or construction permit (CP)

application.

Conformance with the QA measures described in RS-002, Section 17.1.1, provides

reasonable assurance that the applicant used adequate QA measures to support its ESP

application. The staff focused its review on .whether the applicant's .QA measures adequately -

addressed the guidance in Section 17.1 ;1 of RS-002 for each applicable area, as determined by

the applicant (e.g., organization and QA program). :The staff performed much of its evaluation

in an inspection conducted in November 2003 and documented in Inspection

Report 05200008/2003001 (ADAMS Accession No. ML040150170). For any area the applicant

determined was not applicable, the staff verified that the ESP activities did not rely on QA

measures associated with that area. The review focused on the applicant and its primary

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contractor, Bechtel. Inspection Report 05200008/2003001 includes details on the

subcontractors involved in the Dominion ESP activities. Section 17.7 of this report discusses

the adequacy of the QA measures applied by these subcontractors.

In Chapter 17, "Quality Assurance," of the site safety analysis report (SSAR), the applicant

submitted the description of the QA measures it applied to ESP activities. Chapter 17 of the

SSAR includes the ESP Application Development Quality Assurance Manual, Revision 2

(hereafter referred to as the QA Manual). The QA Manual delineates the QA plan for the

development of an ESP application. The applicant developed this manual using guidance from

the American Society of Mechanical Engineers (ASME) NQA-1 -2000, "Quality Assurance

Requirements for Nuclear Facility Applications," published in 2000. As discussed in Inspection

Report 05200008/2003001, the applicant used elements of the operating QA program for the

existing North Anna Units 1 and 2, which are located adjacent to the ESP site, to simplify the

QA process for ESP application development. Use of detailed implementing procedures from

the operating plant QA program for ESP activities obviated the need to develop new guidance

for applicable ESP activities. The applicant's QA Manual provides details about the QA process

for developing an ESP application and specifies the use of the processes in place that meet the

requirements of Dominion's current QA program.

17.1 Organization

17.1.1 Technical Information in the Application (Organization)

The applicant supplied information on the ESP organization in SSAR Section 17.1, which

includes the QA Manual. The QA Manual describes the organization, programs, and

procedural requirements of the Dominion Quality Assurance Program and states that they are

intended to ensure compliance with the criteria of Appendix B to 10 CFR Part 50.

The QA Manual states that a QA program will outline the organization, programs, and

procedural requirements necessary to ensure that the application is developed in a quality

manner and, as appropriate, in accordance with the requirements of Appendix B to 10 CFR

Part 50. In this manual, the applicant described an ESP organization consisting of five groups,

including the Early Site Permit Project, Nuclear Operations, Nuclear Engineering, Nuclear

Support Services, and Nuclear Oversight. An organization chart outlines the overall structure

and lines of authority. The manual sets forth each group's role and responsibilities, as well as

the roles and responsibilities of first-line supervisors, management, and QA organization.

Inspection Report 05200008/2003001 provides additional information on the staff's review of

the applicant's QA organization.

17.1.2 Regulatory Evaluation (Organization)

While the NRC does not require an ESP applicant to develop an organization compliant with the

criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002 contains guidance for the

staff to use in evaluating an ESP applicant's organization. In Section 2 of its QA Manual, the

applicant stated that its design controls would ensure that the application is developed in a

quality manner and, as appropriate, in accordance with the requirements of Appendix B to

10 CFR Part 50.

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Paragraph 17.1.1.1 in Section 17.1.1 of RS-002 outlines the QA measures that constitute an

acceptable organization, including (1) an organization description and charts of the lines,

interrelationships, and areas of responsibility and authority forall organizations performing

quality-related activities, including the applicant's organization and those of its principal

contractors, (2) the relative location of the QA organization, degree of independence from the

organization performing the ESP activities, and authority of the individuals assigned the

responsibility for performing QA functions, and (3) the organizational provisions that exist for

ensuring the proper implementation of QA controls.

17.1.3 Technical Evaluation (Organization)

17.1.3.1 Dominion

The staff reviewed the Dominion QA Manual. In Section 2, the QA Manual describes the

organizational responsibilities for ESP activities and those QA measures Dominion

implemented. Section 2 states that the Nuclear Oversight Group is responsible for

independently planning and performing activities to verify the development and effective

implementation of nuclear management QA programs for activities associated with ESP

development. As discussed in Inspection Report 05200008/2003001, the staff reviewed the

training records of all involved management personnel. These management personnel all

appear to have received appropriate training. Section 2 of the QA Manual also states that the

Vice President of Nuclear Support Services has the -overall responsibility for implementing the

QA program for the ESP organization. The QA Manual provides specific guidance on resolving

issues through the levels of management and details the roles and responsibilities of the QA'

organization.

As discussed in Inspection Report 05200008/2003001, the staff conducted interviews with key

applicant personnel involved in ESP activities. From the interviews, the staff determined that

these personnel were knowledgeable about their roles and responsibilities. Nuclear oversight"

personnel report through a management chain completely separate from ESP application ,

development and product management. The staff found the guidance for organizational roles

and responsibilities adequate for conducting ESP activities.

As described in Inspection Report 05200008/2003001, the applicant developed procedures

specific to ESP activities not covered by the current QA program procedures for the existing

operating units.

17.1.3.2, Bechtel

Dominion selected Bechtel as the primary contractor-for ESP application activities. Bechtel

designed its Nuclear Quality Assurance Manual (NOAM) to meet the requirements of

Appendix B to 10 CFR Part 50. Bechtel used the NOAM to develop the quality assurance

program plan (QAPP) specific to the Dominion ESP application effort.: The NQAM contains

detailed organization charts and personnel responsibilities. Bechtel's project quality assurance

manager (PQAM) directed and controlled the project QA prograrm. The PQAM was tasked with

assuring that the QA actions Bechtel performed throughout the p'roject organization were

accomplished in accordance with the quality program criteria., The PQAM has organizational

independence, reporting directly to the President of Bechtel's Nuclear Global Business Unit

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(GBU). The GBU President has overall responsibility for the adequacy and implementation of

the Bechtel nuclear GA program. The staff found Bechtel's guidance for organizational roles

and responsibilities adequate for conducting ESP activities.

17.1.4 Conclusion (Organization)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that the applicant has implemented an acceptable

organization. The staff considered the regulatory guidance of Section 17.1.1 of RS-002 in their

review of this portion of the application. The guidance in RS-002 helps to provide reasonable

assurance that information derived from ESP activities that could be used in the design and/or

construction of SSCs important to safety would support satisfactory performance of such SSCs

once in service.

17.2 Quality Assurance Program

17.2.1 Technical Information In the Application (QA Program)

The applicant supplied information on the QA program in SSAR Section 17.1, which includes

the GA Manual. The GA Manual states that th6 objective of the Dominion Quality Assurance

Program for the ESP application is to comply with the criteria in Appendix B to 10 CFR Part 50,

as amended, and with the QA program requirements in Dominion's implementing procedures,

which Inspection Report 05200008/2003001 discusses in greater detail.

The GA Manual states that the Dominion Quality Assurance Program applies to those ESP

activities that can affect, either directly or indirectly, the safety-related site characteristics or

analysis of those characteristics. In addition; this program applies to engineering activities used

to characterize the site or analyze that characterization. The program defines the qualityrelated activities associated with developing the ESP application. Specifically, the GA Manual

states that the Dominion Quality'Assurance Program provides written policies, standards,

procedures, and instructions covering engineering, design, procurement, periodic surveillance,

and supporting tests for the development of the application.

The GA Manual states that nuclear oversight personnel report through a line of management

completely separate from ESP application development, production management, and

influences. The Nuclear Oversight Group must conduct audits in accordance with the Dominion

Quality Assurance Program and perform other duties as directed by the Director of Nuclear

Oversight. The GA Manual specifies the qualification criteria for nuclear oversight personnel.

17.2.2 Regulatory Evaluation (QA Program)

While the NRC does not require an ESP applicant to have a GA program compliant with the

criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002 contains guidance for the

staff to use in evaluating an ESP applicant's GA program. RS-002, paragraph 17.1.1.2,

outlines the GA measures that constitute an acceptable level'of control for ESP activities. The

GA program should include (1) a scope of QA measures adequate to ensure that appropriate.

quality controls are applied to all site characterization data related to the design and analysis of

SSCs important to safety that might be constructed on the proposed site, (2) provisions to

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ensure proper definition of QA measures, and (3) provisions to ensure the adequacy of

personnel qualifications.

17.2.3 Technical Evaluation (QA Program)

In this section of the safety evaluation report (SER), the staff documents its evaluation of the

applicant and primary contractor's overall QA program description. The staff provides a

detailed review and evaluation of each applicable portion of the program in the following

sections of this SER.

17.2.3.1 Dominion

The staff reviewed the QA Manual, which delineates the Dominion Quality Assurance Program

for the development of an ESP application and outlines the organization, programs, and

procedural requirements for the applicant's QA program. The applicant developed the manual

using guidance from ASME NQA-1-2000.

To simplify the QA process, the applicant invoked portions of the current QA program for.,

Dominion's existing operating units. However, the operating Dominion Quality Assurance

Program specifically excludes construction activities. The QA Manual provides details for

construction-related QA processes that can be interchanged with appropriate sections of the

operating QA program. The staff found the applicant's methodology for a QA program, which is

based on the implementation of ASME NQA-1-2000 and applicable operating QA guidance, to

be adequate for conducting ESP activities.

The applicant developed procedures specific to the ESP project to control ESP activities not

adequately addressed in the operational program procedures. As discussed in Inspection

Report 05200008/2003001,. the staff found the procedures adequate for conducting ESP

activities.

Inspection Report 05200008/2003001 also discusses the staff's review of the training and

qualification program documents for all involved QA personnel; this review found no

deficiencies.

17.2.3.2 Bechtel

The Bechtel NQAM identifies Bechtel's requirements for the development of quality program

projects, such as the Dominion ESP application.. Bechtel stated that it designed the QA policies

contained in the NOAM to meet the requirements of Appendix B to 10 CFR Part 50. To this'

end, the NQAM incorporates QA policies corresponding to each'criterion in Appendix B to,'

10 CFR Part 50. Bechtel used the NQAM to develop a QAPP specific to the Dominion ESP

application QA effort. --

The stated purpose of the QAPP is to establish the quality program interface between the

Bechtel NQAM and Dominion's specific requirements relevant to the ESP application

development activities. The QAPP specifically'identifies the QA'policies applicable to the

Dominion ESP project, as well as the requirements contained in the Dominion QA Manual.

Bechtel developed the NQAM for the full scope of its services, while the QAPP specifically

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identifies QA policies applicable to Bechtel's scope of work on the Dominion ESP project.

Bechtel applied the requirements of the QA program established in the QAPP in a graded

manner, commensurate with the importance to safety of the activities being performed.

The staff reviewed the QAPP and QAPM and found that the documents cover all aspects of an

adequate QA program, establish'a clear link between the Dominion and Bechtel QA programs,

and explain how the relationship worked.- Modifications to the QA policies, as appropriate,

reflected unique project or applicant requirements. The documents' also stipulate that the -

reporting of defects or noncompliance to the NRC must be in accordance with 10 CFR Part 21,

"Reporting of Defects and Noncompliance." The staff therefore finds the Bechtel Quality

Assurance Program to be adequate for conducting ESP activities.

As discussed in Inspection Report 05200008/2003001, the staff also reviewed the training and

qualification program documents for all involved QA personnel and found no deficiencies.

17.2.4 Conclusion (QA Program)

As set forth above, the staff reviewed the QA measures implemented by the applicant and its

primary contractor and concludes that these measures form an acceptable QA program. The

staff considered the regulatory guidance of Section 17.1.1 of RS-002 in their review of this

portion of the application. The guidance in RS-002 helps to provide reasonable assurance that

information derived from ESP activities that could be used in the design and/or construction of

SSCs important to safety would support satisfactory performance of such SSCs once in service.

17.3 Desiqn Control

17.3.1 Technical Information in the Application (Design Control)

The applicant supplied information on design control in SSAR Section 17.1, which includes the

QA Manual. The manual states that the Nuclear Design Control Program (NDCP) delineates

procedures, responsibilities, processes, and standards related to design control. The applicant

based its procedures for design controls, analysis,'and reviews on the applicable documents

referenced in the Nuclear Design Controi Manual (NDCM) and included in American NationalStandards Institute (ANSI) N45.2.11-1974, "Quality Assurance Requirements for Nuclear Power

Plants," published in 1974, as modified in the Dominion QA procedures (see Inspection

Report 05200008/2003001).

The QA Manual states that the NDCP provides for verifying or checking the adequacy of design

through the performance of design review or suitable testing. *The NDCP establishes measures

for review of the selection and suitability of the application of materials, parts, equipment, and;

processes essential to safety-related or safety-significant functions. These measures require

the use of valid and applicable industry standards and specifications.

The QA Manual states that quality measures are assured through all levels of the design control

program by the design control 'organization, station, and corporate support organization. The

applicant's procedures (discussed in Inspection Report 05200008/2003001) require that the

applicant document and correct any nonconforming condition it identifies, in accordance with

the corrective action process.

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The QA Manual states that the NDCP delineates procedures to assure that the design basis,

regulatory requirements, codes, and standards are correctly translated into specifications,

drawings, procedures, or instructions forthose items classified as safety related. Further,

design changes, including field changes,-afe'subject to design control measures commensurate

with those applied to the original design and the applicable, Specified design requirements;

As discussed in Inspection Report 05200008/2003001, Dominion's engineering standard - establishes the interface between the company and its contractors for design activities. The'

standard requires that the preparation, review, and approval of design documents follow the

licensee's program requirements.

In Request for Additional Information (RAI) 17.1-1, the staff asked the applicant to describe the

QA measures it used to authenticate and verify any data important to safety that it retrieved

from Internet Web sites that support information in the SSAR that could affect the design,

construction,' or operation of SSCs important to safety. In its response, the applicant provided a

table identifying all the Internet Web sites it used as a source of information for the SSAR. A'

column in the table identifies whether the applicant used the information from' an Internet Web

site to support information in the SSAR that could affect the design, construction, or operation

of SSCs important to safety. Another column describes the measures used to authenticate and

verify data retrieved from Internet Web sites that support information in the SSAR that could

affect the design, construction, or operation of SSCs important to'safety.

17.3.2 Regulatory Evaluation (Design Co'ntrol)

While the NRC does not require an ESP applicant to implement design controls compliant with

the criteria of Appendix B to 10 CFR Part 50,'Section 17.1.1 of RS-002 contains guidance for

the staff to use in evaluating an ESP applicant's design controls. RS-002, paragraph-17.1.1.3,

describes the QA measures that constitute an acceptable level of design control. Acceptable

design controls should-include (1) the scope'of activities that could affect design and - -

construction activities for SSCs important to safety that might be constructed on the site, (2) a

definition of the organizational structure, activity, and responsibility of the positions or groups

responsible for design activities important to safety (if any), (3) provisions to carry out design

activities important to safety in a planned,' controlled, and orderly manner, (4) provisions for

interface control between functional units'of the applicant's organization, (5) provisions to'verify

the technical adequacy of design documents' applicable to ESP activities that could affect SSCs

important to safety, and (6) provisions to control design charines applicable to ESP activities

that could affect SSCs important to safety (if any).

17.3.3 Technical Evaluation (Design Control)' -

17.3.3.1 Dominion

The staff reviewed the Dominion procedures describing design control measures for design

verification,'computer software control, enginreering'drawings, design calculations, personnel

training', design deviations, internal and external design control communications, design

documentation, organizational responsibilities, field changes, 'and revisions.

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The QA Manual delineates the QA plan for developing an ESP application and describes

personnel roles and responsibilities for those involved in the project. The manual states that

the NDCP delineates procedures to assure that design bases, regulatory requirements,

codes, and standards are correctly translated into specifications, drawings, procedures, or

instructions. The Dominion nuclear and engineering standards (discussed in Inspection

Report 0520000812003001) further describe the design control program. As stated in the QA

Manual, the procedures for design controls, analysis, and review included, as part of their basis,

ANSI N45.2.11-1974, as modified in the Dominion QA procedures (discussed in Inspection

Report 05200008/2003001). Based on the training and procedural guidance, the staff found

the guidance for design control to be adequate for conducting ESP activities. The staff verified

the adequacy of Dominion's design control process by reviewing applicable procedures as

discussed in Inspection Report 05200008/2003001.

Dominion's QA procedures (discussed in Inspection Report 05200008/2003001) describe the

NDCP and the overall design control attributes, qualification of nuclear oversight personnel, and

measures established to assure that regulatory requirements are met. The NDCP constitutes a

detailed program for preparing, reviewing, maintaining, and approving procedures and

standards to ensure compliance and consistency with Criterion V, "Instructions, Procedures,

and Drawings," of Appendix B to 10 CFR Part 50. The NDCP also provides for verification

and/or independent review of the adequacy of design through design reviews, use of alternate

calculational methods, or testing. Additionally, the staff found that the NDCP adequately

addresses control of design changes and organizational interfaces. For these reasons, the

staff found the guidance of the NDCP to be consistent with Section 17.1.1 of RS-002.

The staff evaluated the applicant's response to the RAI concerning the QA measures the

applicant used to authenticate and verify data retrieved from Internet Web sites that support

information in the SSAR affecting the design, construction, or operation of SSCs important to

safety. In its response to the RAI, the applicant listed all Internet Web sites referenced in the

SSAR, identified whether the referenced data supported information in the SSAR that could

affect the design, construction, or operation of SSCs important to safety, and described the

method used to authenticate or verify the data. In all cases, the applicant requested that the

respective Internet Web site organization authenticate or verify a hard copy of the data. The

staff found this method of authenticating Internet Web site data to be acceptable. The staff

stated that it would verify the completion of the applicant's requests for authentication as part of

its inspection program before developing the final safety evaluation report. The staff identified

this item as Confirmatory Item 17.3-1.

The staff conducted a followup inspection of Confirmatory Item 17.3-1 on February 8, 2005, at

the primary contractor's office in Frederick, Maryland. The staff determined, through review of

supporting documentation, that the applicant had provided adequate quality assurance

measures to authenticate and verify data retrieved from Internet Web sites that support

information in the SSAR that could affect the design, construction, or operation of SSCs

important to safety. Specifically, Bechtel either (1) obtained letters certifying the authenticity of

the data from the organizations posting the data on the Internet, or (2) performed an

engineering review of the data to verify their reasonableness. Qualified individuals performed

these engineering reviews based on their experience with similar data and compared the data

to similar data obtained from other sources. Based on this inspection, the staff concludes that

Confirmatory Item 17.3-1 is resolved.

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17.3.3.2 Bechtel

Dominion established the ESP workscope and quality requirements for'Bechtel in a Dominion

purchase order (PO), as discussed in Inspection Report 05200008/2003001., The PO included

a detailed description of Bechtel's workscope, including identification of specific sections of the

ESP application for which Bechtel was responsible for performing design control activities

supporting analyses, evaluations, and procurement. The PO also described Bechtel's'

responsibilities for ensuring that personnel involved with the project were trained'and

knowledgeable about the QA design control requirements.

Dominion specified that materials and services supplied by Bechtel were related to nuclear

safety and that Bechtel should implement a quality control and assurance program that

complied with the requirements of Appendix B to 10 CFR Part 50 and ANSI N45.2.11-1974.

Bechtel implemented the ESP project quality requirements specified in the project-specific

QAPP. The Bechtel OAPP invoked the quality policies contained in the Bechtel QA manual

applicable to the ESP project.

As discussed in Inspection Report 05200008/2003001, the staff reviewed Bechtel procedures

describing design control measures in the areas of design verification, computer software

control, engineering drawings, design calculations, personnel training, design deviations,

internal and external design control communications, design documentation, organizational

responsibilities, and field changes and revisions.- The staff found that the Bechtel procedures

clearly stated the requirements for the preparation, review, approval, and control of design

criteria, in accordance with ANSI N45.2.11-1974 and/or ASME NQA-1-2000. Additionally,

Bechtel procedures regarding engineering control define the requirements for the preparation

and control of ESP project and task design criteria, including the standards, codes,'regulations,

and design bases used 'for the project. The staff verified that the procedures provided the

means to coordinate and communicate design criteria changes (including revision control)

throughout any affected project discipline group. The procedures also specified internal

document management requirements, including record retention.

As discussed in Inspection Report 05200008/2003001, the staff reviewed Section 3.2 of the'

QAPP and Bechtel's implementing procedures to verify that controls exist for design control

interfaces among Bechtel personnel both internally and externally (i.e., with other contractors).

The procedures define responsibilities for personnel internal and external to the organization,

including communication, documentation, and 'distribution of design control criteria. This

includes control of design input and development, special analysis, and approvals. Bechtel also

defined responsibilities regarding actions to verify traceability 'and the appropriateness of

information before it is used in any design document.

Section 3.3 of the QAPP and the Bechtel implementing procedures describe responsibilities

and requirements for verifying the design work performed internally, including nongeneric

computer software verification requirements. The staff confirmed that Bechtel had defined

requirements for the performance and documentation of design verification on SSCs important

to safety for the ESP. The 'staff verified that procedural controls and descriptions existed for

design verification, 6ither by interdisciplinary design review, independent off-project design

review by technical staff, or individual critical design review. Once selected, the procedures

specify that Bechtel document the verification method and justify and document design

deviations.

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Section 3.4 of the QAPP describes design change controls. The staff verified that the

procedures specify, requirements to control changes to the design of SSCs important to safety,

after the initial design is complete, and include requirements for the review and independent

verification of such changes. As discussed in Inspection Report 05200008/2003001, additional

controls in Bechtel's implementing procedures specify engineering responsibilities and

requirements for initial, as well as revised or changed, documents and drawings affecting the

ESP project. For these reasons, the staff finds the design controls Bechtel described in the'

QAPP to be adequate for the conduct of ESP activities.

17.3.4 Conclusion (Design Control)

As set forth above, the staff reviewed the QA control measures employed by the applicant and

its primary contractor and concludes that they have implemented acceptable design controls.

The staff considered the regulatory guidance of Section 17.1.1 of RS-002 in their review of this

portion of the application. The guidance in RS-002 help to provide reasonable assurance that

information derived from ESP activities that could be used in the design and/or construction of

SSCs important to safety would support satisfactory performance of such SSCs once in service.

17.4 Procurement Document Control

17.4.1 Technical Information in the Application (Procurement Document Control)

The applicant supplied information on procurement document control in SSAR Section 17.1,

which includes the QA Manual. The manual stated that the applicant based its procedures for

design controls, analysis, and reviews on the applicable documents referenced in the NDCM,

including ANSI N45.2.11-1974, as modified by Dominion's QA procedures.

The QA Manual states that administrative procedures describe the program for completing

procurement documents, including review, approval, document control, and change control.

Dominion's procedures require that the applicant establish administrative procedures to ensure

that procurement documents reference all actions required by a supplier, in accordance with the

applicable codes, specifications, and drawings. The applicant must prepare, review, and

approve procurement documents, as delineated in the procedures.

The QA Manual requires that procurement documents incorporate the design-basis, technical,

and quality requirements, including the applicable regulatory requirements, specifications,

codes and standards, test and inspection requirements, and instructions for special processes.

For development of the ESP application, the manual states that activities subject to this criterion

were limited to the procurement of vendor services.

17.4.2 Regulatory Evaluation (Procurement Document Control)

While the NRC does not require an ESP applicant to implement procurement document

controls compliant with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002

contains guidance for the staff to use in evaluating an ESP applicant's procurement document

controls. RS-002, paragraph 17.1.1.4, outlines the QA measures that constitute an acceptable

level of procurement document controls. These controls should include (1) provisions to ensure

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that applicable technical requirements and QA controls are included or referenced in

procurement docurmnents related to ESP activities that could affect SSCs important to safety,

and (2) provisions'for the review and approval of procurement documents for ESP activities that

could affect SSCs important to safety.

17.4.3 Technical Evaluation (Procurement Document Control),

17.4.3.1 Dominion

The QA Manual delineates the QA plan for procurement document control. The manual states

that administratiVe"procedures describe the program for completing procurement documents,'

including review, approval, document control, and change control. The applicant also

established administrative procedures to ensure that procurement documents reference all

actions required by a supplier, in accordance with applicable codes, specifications, anrd

drawings. The procedures also ensure that procurement documents incorporate design-basis,

technical, and quality requirements, including applicable regulatory requirements. As discussed

*in Inspection Report 05200008/2003001, the applicant based the procedures implementing this

section on Dominion's QA procedures, which contain relevant standards, requirements, or

guides. In addition, the staff verified that the applicant had adequate implementation

procedures for control of procurement documents, as discussed in Inspection

Report 05200008/2003001.

17.4.3.2 Bechtel

Bechtel procured engineering services and support from four subcontractors, including Tetra

Tech NUS, Inc., MACTEC Engineering and Consulting, Inc., Risk Engineering, Inc., and William

Lettis & Associates, Inc. 'The staff reviewed the procurement documents for these ' subcontractors to ensure adequate implementation of procurement document control.

Section 17.7 of this SER discusses the specific details of the procurement controls Bechtel

applied to each of these suppliers. '

As discussed in Inspection Report 05200008/2003001, the applicant established workscope

and quality requirements for Bechtel. The PO for Bechtel's services implemented the ESPproject quality requirements given in the project-specific QAPP. The Bechtel QAPP invoked the

quality policies contained in the Bechtel QA manual that applied to the ESP project.' In

accordance with specifications contained in the PO, Dominion approved the QAPP. For

procurement documrhent control, the QAPP states that Bechtel should use the'NOAM.' Policy

No. Q-4.1, "Preparation of Procurement Documents,' of the NQAM provides guidance for the

preparation, review, approval, and coritrol of pr'6curefient dobumeirits. -

As discussed in Inspection Report 05200008/2003001, the Dominion PO contained a detailed

description of Bechtel's workscope, including identification of specific sections of the ESP

application for which Bechtel was to performisupporting analyses, evaluations,' nd

investigations. Dominion specified that materials and services supplied by Bechtel were

nuclear safety related and required that Bechtel implement a quality contr6l and assurance

program that complied with the requirements of 'Appenrdix B to 10 CFR Part 50 and'

ANSI N45.2.11-1974. Additionally, Dominion specified that th6 requirements of '10 CFR Part 21

be applied to the Bechtel PO. As discussed in Inspection Report 05200008/2003001, the staff

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reviewed the Dominion safety-related vendor list and verified that Bechtel was listed as an

active safety-related vendor, qualified to supply design and engineering services for major

projects, including the ESP project.' The staff did not note any deficiencies in this area.

17.4.4 Conclusion (Procurement Document Control)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they have implemented an acceptable level of

procurement document control which meets the guidance of Section 17.1.1 of RS-002 and

helps to provide reasonable assurance that information derived from ESP activities that could

be used in the design and/or construction of SSCs important to safety would support

satisfactory performance of such SSCs once in service.

17.5 Instructions. Procedures, and Drawings

17.5.1 Technical Information in the Application (Instructions, Procedures, and Drawings)

The applicant supplied information on instructions, procedures, and drawings in SSAR

Section 17.1.1, which includes the QA Manual. As discussed in Inspection

Report 05200008/2003001, the Dominion QA procedures list the standards, requirements, or

guides which serve as the basis for the procedures, drawings, and instructions the applicant

used to implement this section of the QA Manual.

The QA Manual states that the applicant established, approved, implemented, and maintained

detailed written procedures to control development of the ESP application. Administrative,

procedures describe the requirements for developing, reviewing, approving, and controlling

procedures, instructions, and drawings used for testing, as well as for design development,

administrative, and other activities performed in support of application development. These

requirements include references, prerequisites, precautions, limitations, manufacturers'

specifications, check-off lists, and acceptance criteria.

The QA Manual states that changes to procedures or instructions require that the specific

procedure or instruction be revised before the applicant implements the change. The revision

process must have the same level of review as the original procedure or instruction. The QA

Manual also states that the design control process governs drawing changes.

17.5.2 Regulatory Evaluation (Instructions, Procedures, and Drawings)

While the NRC does not require an ESP applicant to have instructions, procedures, and

drawings compliant with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002

contains guidance for the staff to use in evaluating an ESP applicant's instructions, procedures,

and drawings. RS-002, paragraph 17.1.1.5, details the QA measures that constitute an

acceptable level of control for instructions, procedures, and drawings. Such controls should*

include provisions for (1) ensuring that ESP activities that could affect SSCs important to safety

are prescribed by and accomplished in accordance with instructions, procedures, or drawings,

and (2) including quantitative and qualitative acceptance criteria in instructions, procedures, and

drawings related to ESP activities that could affect SSCs important to safety.

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17.5.3 Technical Evaluation (Instructions, Procedures, and Drawings)

17.5.3. 1 Dominion

Section 7, "Document Control," of the QA'Manual describes the measures that the applicant

established for control of procedures, instructions, and drawings to provide for the'review,

approval, issues, and changes thereto. The QA Manual requires that changes be'approved by

the same organization that performed the initial review and approval, though that approval may

be delegated. Section 7 also requires that the applicant process, distribute, and control all

procedures; dispose of obsolete copies; and maintain records of all procedure holders. Further,

Section 7 requires that the applicant maintain an index of procedures, as well as the latest

version of each. Section 7 also states that the station administrative procedures should

address the measures for procedure control; Inspection Report 05200008/2003001 discusses

the Dominion QA procedures that contain requirements, standards, and guides that serve-as

the basis for its implementing procedures. These procedures state that Dominion complied with

Regulatory Guide (RG) 1.33, Revision 2, "Quality Assurance Program' Requirements

(Operation)," with exceptions and clarifications noted. The staff reviewed the administrative

procedures and found the guidance adequate for the control of instructions,' procedures, and

drawings.:'

The method to control ESP project procedures, set forth in ESP-002, 'Procedure Control," in

the QA Manual, includes responsibilities. The document states that the manager for the ESP

project identifies the necessary procedures and guidelines. This method requires that all ESP

procedures be subject to an independent review and provides the approval authority. It also

states that procedures must be maintained consistent with ESP-002, as well as with NDCP

procedures and engineering standards, which contain provisions for including quantitative and

qualitative acceptance criteria.

As discussed in Inspection Report 05200008/2003001, Dominion's procedure for implementing

the NDCM details the NDCP and addresses the review and revision of procedures and

standards, including methods of and reasons for changes to these procedures.

In addition, Dominion's QA procedures set forth expectations for procedure use and state that

all procedure users in the Nuclear Business Unit (NBU) are responsible for verifying that only

the latest approved documents are used to perform work activities, as discussed in Inspection

Report 0500008/2003001. Procedures also provide instructions for distribution to ensure that

users have the latest approved version of a procedure available at the job site.

The procedures also address compliance, requiring that NBU employees strictly adhere to

procedures, that users ensure that procedures are approved and appropriate for the specific

tasks or evolutions to be performed, and that users verify'a procedure before its use to ensure

that it is the cuirrent and approved revision. There are also requirements that; if an activity

require's a written procedure, the procedure must be used to perform that activity.

The procedures also contain requirements for developing and revising procedures and for

removing superseded procedures from use. The procedures describe intent versus nonintent

changes and explain the approval authority for each. They also describe how changes are

implemented, including consideration of work in progress when a change becomes effective. In

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fill

addition, they describe how hard-copy procedures, if maintained, are distributed, and they

address the Electronic Procedure Distribution System (EPDS), a computer program used for

the electronic distribution of procedures. Applicant staff stated that Dominion maintained and

distributed all ESP procedures electronically. The NRC staff found that the applicant's

measures for instructions, procedures, and drawings meet the guidance in Section 17.1.1 of

RS-002. Additionally, in the course of reviewing the instructions, procedures, and drawings

related to ESP activities, the staff verified that they were adequate for the task being performed

and were properly controlled.

As discussed in Inspection Report 05200008/2003001, the NRC staff reviewed a sample of the

original ESP procedures at the Innsbrook Records Management Center. The staff found that

these procedures had approval signatures consistent with Dominion's requirements.

17.5.3.2 Bechtel

As discussed in Inspection Report 05200008/2003001, the Bechtel procedures provide

requirements for the preparation, application, control, maintenance, and compilation of data in

the controlled document database. The procedures state that all engineering department

procedures (EDPs) must be prepared under the direction of the Engineering Committee and

issued for review and comment by the cognizant Manager of Engineering, as well as by other

managers, to allow a cross-functional review. The Bechtel Corporate Manager of Engineering

has the approval authority. The Manager of Quality Assurance/Quality Services must review

the EDPs.

As discussed in Inspection Report 05200008/2003001, the staff reviewed engineering

department instructions (EDPIs), which Bechtel uses to modify EDPs for specific projects or to

develop a project-specific procedure when no EDP exists. Applicable Bechtel procedures

(1) require approval of procedure revisions in the same manner as specified for new

procedures, (2) contain requirements for control and distribution of procedures, and (3) specify

that procedure users must ensure that copies downloaded or printed from the corporate

database are the latest revision. The procedures also state that the Bechtel Document

Management Center maintains the original procedures, and that project engineers are

responsible for identifying applicable EDPs and EDPIs. The staff found Bechtel's measures for

instructions, procedures, and drawings adequate for the conduct of ESP activities.

17.5.4 Conclusion (Instructions, Procedures, and Drawings)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they implemented an acceptable level of control for

instructions, procedures, and drawings. The staff considered the regulatory guidance of

Section 17.1.1of RS-002 in their review of this portion of the application. The guidance in

RS-002 helps to provide reasonable assurance that information derived from ESP activities that

could be used in the design and/or construction of SSCs important to safety would support

satisfactory performance of such SSCs once in service.

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17.6 Document Control

17.6.1 Technical Information in the Application (Document Control)

The applicant supplied information on document control in SSAR Section 17.1, which includes

the QA Manual. The QA Manual states that the applicant established and documented

administrative measures describing controls for review, approval, and issuance of documents

such as proc'edures, instructions, and drawings.' These requirements also address changes to

documents before their release. The manual requires that changes'be approved by the-same

organization that performed the original review and approval. However, this responsibility may

be delegated to other qualified, responsible organizations. The manual also requires that the

applicant incorporate approved changes into procedures and drawings'and other appropriate

documents associated with the change. This method helps to ensure that procedures,

drawings, and instructions, as well as changes to them, are processed, distributed, and

controlled and that obsolete copies are discarded.

17.6.2 Regulatory Evaluation (Document Control)

While the NRC does not require an ESP applicant to implement document control procedures

compliant with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002 contains

guidance for the staff to use in evaluating an ESP applicant's document controls. RS-002,

paragraph 17.1.1.6, describes the QA measures that constitute' an acceptable level of

document control. Acceptable document controls should include provisions to ensure that

documents related to ESP activities that could affect SSCs inmportant to'safety, including

changes, are reviewed for adequacy, approved for release by authorized personnel, and

distributed and used at the location where the prescribed activity will be performed.

17.6.3 Technical Evaluation (Document Control) ''

Each section of this SER describes (or references relevant discussion in Inspection

Report 05200008/2003001).the specific documents the staff reviewed and discusses their

adequacy. The'staff considered the scope of the documents to b'e adequate for the ESP

activities that the applicant conducted. The staff reviewed documents that the applicant had

reviewed and approved for'issuance to ensure that the process was followed. Based on these

considerations and reviews, the staff concludes that the applicant and its primary contractor had

adequate controls in place to ensure the proper revision of a do6urnent.

17.6.4 Conclusion (Document Control).

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they implemented acceptable document controls. The

staff considered the regulatory guidance of Section 17.1.1of RS-002 in their review of this

portion of the application. The guidance in RS-002 help to provide reasonable assurance that

information derived from ESP activities that could be used in the design and/or construction of

SSCs important to safety would support satisfactory performance of such SSCs once in service.

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'IF'

17.7 Control of Purchased Material. Equipment. and Services

17.7.1 Technical Information in the Application (Control of Purchased Material,

Equipment, and Services)

The applicant supplied information on the control of purchased material, equipment, and

services in SSAR Section 17.1, which includes the QA Manual. The manual stated that

Dominion QA procedures contain standards, requirements, or guides that provide the basis for

the procedures implementing this section.

The QA Manual stated that the applicant's administrative procedures describe the requirements

for controlling purchased material, equipment, and services, including commercial-grade items,

for use in safety-related applications. It also states that the applicant evaluates suppliers before

contract award, except in specified emergency conditions. Surveillance of suppliers during

fabrication, inspection, testing, and shipment of materials, equipment, and components must be

planned and performed in accordance with written procedures to ensure conformance with

applicable PO requirements. Administrative procedures describe the requirements for

controlling purchased material, equipment, and services. The applicant must identify,

document, and correct any nonconforming conditions consistent with its corrective action

process.

17.7.2 Regulatory Evaluation (Control of Purchased Material, Equipment, and Services)

While the NRC does not require an ESP applicant to implement control of purchased material,

equipment, and services compliant with the criteria, of Appendix B to 10 CFR Part 50,

Section 17.1.1 of RS-002 contains guidance for the staff to use in evaluating an ESP

applicant's control of purchased material, equipment, and services. RS-002,

paragraph 17.1.1.7, provides the QA measures that constitute an acceptable level of control of

purchased material, equipment, and services. Such controls should include (1) provisions for

the control of purchased material, equipment, and services related to ESP activities that could

affect SSCs important to safety which apply to selecting suppliers and assessing the adequacy

of quality, and (2) provisions to ensure the onsite availability of documented evidence of the

conformance to procurement specifications of material and equipment related to ESP activities

that could affect SSCs important to safety before their installation or use.

17.7.3 Technical Evaluation (Control of Purchased Material, Equipment, and Services)

Section 17.4.3.2 of this SER provides a detailed discussion of the controls of purchased

material, equipment, and services that Dominion applied to its primary contractor. This section

of the SER focuses on the additional subcontractors that were engaged in the North Anna site

ESP activities. The following sections discuss the scope of activities and the QA measures

applied to those activities.

17.7.3.1 Risk Engineering, Inc.

Bechtel subcontracted to Risk Engineering, Inc. (REI), to support Bechtel's ESP efforts in

performing probabilistic seismic hazard and/or sensitivity analyses for the North Anna site. As

discussed in Inspection Report 05200008/2003001, Bechtel's service requisition for REI's work

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specified that REI provide its QA manual for Bechtel approval. Additionally, the service

requisition specified that all work be performed under a QA program, in accordance with the

criteria of Appendix B to 10 CFR Part 50 aid in compliance with the requirements of 10 CFR

Part 21. The staff found that REI maintained a QA-manrual and o6ftware quality assurance plan

(SQAP), both of which REI submitted to Bechtel. Further, the staff found that Bechtel project

management and QApersonnel reviewed and accepted the REI QA manual and SQAP. --

Additionally, the staff noted that Bechtel performed supplier audits of REI in November. 2002

and June 2003. Based on a review of its QA program and supplier audits, Bechtel added REI

to its list of evaluated suppliers and identified REI as a supplier with a QA program consistent

with the specifications of ANSI N45.2.11 -1974.

As discussed in Inspection Report 05200008/2003001, the staff reviewed the QA measures

employed by REI to determine whether they were acceptable and met the guidance of

Section 17.1.1 of RS-002. Additionally, the staff held discussions with REI management to

ensure that REI implemented QA measures properly. Based on its review of associated

documents, the staff concludes that the QA measures were acceptable and appropriately:

implemented for use in the control of activities performed by REI related to Dominion's ESP -

application.

17.7.3.2 William Lettis & Associates, Inc.

As discussed in Inspection Report 05200008/2003001, the staff reviewed Bechtel's service

requisition for work to be performed by William Lettis & Associates, Inc. (Lettis). The requisition

outlined Bechtel's request for technical services from Lettis for the collection and evaluation of

data that formed the basis of SSAR Sections 2.5.1 through 2.5.3. -

Bechtel requested technical services in the form of field and office studies designed to meet the

guidance of Appendix D to RG 1.165, uldentification and Characterization of Seismic Sources

and Determination of Safe Shutdown Earthquake Ground Motion," for identifying and .

characterizing seismic source zones in the region around the North Arina site. The studies also

address investigation of the potential for active tectonic deformation (permanent ground

displacement) at and in the vicinity of the site, in accordance with Appendix D to RG 1.165.

The service requisition also outlines the applicable codes and standards. In addition, Bechtel's

service requisition required the subcontractor to perform work in accordance with all the latest

relevant and applicable regulatory guides and NRC guidance. -

The staff noted that Bechtel's service requisition required Lettis to (1) integrate Bechtel's

Quality Assurance Piogram requirements into its work processes and, before starting work,

submit a summary workplan and schedule confirrming an understanding of the work,- (2) ensure

that all Lettis personnel performing ESP work undergo QA training by Bechtel, (3) check for

proper implementation of the QA requirements as work progressed, (4) allow Bechtel or

Dominion access to its facilities and records for QA inspection and audit purposes, (5) identify

and document all deviations fro'm the requirements -of the service requisition, and (6) identify -

10 CFR Part 21 requirements- -

The staff reviewed the QA measures employed by Lettis to determine whether they constituted

an acceptable program and met the guidance of Section 17.1.1 of RS-002. Based on its

review, as discussed 'above, the staff concludes that the QA measures were acceptable for use

in the control of activities performed by Lettis related to Dominion's ESP application.

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17.7.3.3 Tetra Tech NUS, Inc.

As discussed in Inspection Report 05200008/2003001, Bechtel's service requisition for work to

be performed by Tetra Tech NUS, Inc. (Tetra Tech), limited the scope of work performed by'

Tetra Tech to the preparation of certain portions of the ESP environmental report. Because

Bechtel identified this work as non-safety related, the quality requirements specified in the

service requisition mandated only that Tetra Tech have a QA program compatible with theprovisions and requirements of International Organization for Standardization (ISO) 9001. The

staff reviewed the Tetra Tech scope of work and concluded that because the workscope was

limited to developing the environmental report, it did not require QA controls equivalent in

substance to the criteria of Appendix B to 10 CFR Part 50. The staff did not perform an

additional review of Tetra Tech's QA measures.

17.7.3.4 MACTEC Engineering and Consulting, Inc.

Bechtel subcontracted to MACTEC Engineering and Consulting, Inc. (MACTEC), to obtain

geological testing support: As discussed in Inspection Report 05200008/2003001, Bechtel's

technical specification for work to be performed by MACTEC mandated that the MACTEC

Quality Assurance Program meet the requirements of Appendix B to 10 CFR Part 50 and

comply with the criteria of 10 CFR Part 21.

As discussed in Inspection Report 05200008/2003001, the staff found that, consistent with the

requirements of the Bechtel technical specification, MACTEC developed a project-specific

workplan to identify the scope of work activities and quality requirements and applied the

MACTEC quality assurance program description (QAPD).

The staff noted that the MACTEC QA organization was independent of the organization

performing field or lab work and reported directly to the senior project principal engineer and

project manager. The staff found that the MACTEC QAPD and workplan provided adequate

measures for the control of MACTEC work activities to ensure the integrity and reliability of site

geological test data.

MACTEC used the services of five additional suppliers to complete the scope of work outlined

in the Bechtel technical specification. These suppliers performed work activities associated

with surveying, drilling, geologic testing, and laboratory analyses.. The MACTEC project

principal engineer, the project manager, and a representative from the QA organization

reviewed the work instructions MACTEC provided to these subcontractors. Additionally, in,

discussions with the staff, the MACTEC project principal engineer stated that all subcontractors

performing site work were trained on the MACTEC QA program and the requirements of

10 CFR Part 21.

In general, field and laboratory testing activities must be conducted in accordance with

recognized testing methods from the American Society for Testing and Materials (ASTM) or the

U.S. Environmental Protection Agency (EPA). The applicant described deviations from these

testing methods in Appendix B, uGeotechnical Tests," to Section 2.5.4 of the ESP application.

The staff reviewed the QA measures employed by MACTEC to determine whether they were

acceptable and met the guidance in Section 17.1.1 of RS-002. Based on its review, as

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discussed above, the staff concluded that the QA measures were acceptable for use in the

control of activities performed by MACTEC related to the Dominion ESP application.

As described below, the staff reviewed the workscope and QA measures applicable to each of

the five MACTEC subcontractors ' -'

17.7.3.4.1 Applied Research Associates

Applied Research Associates (ARA) provided geological testing support for the performance of

cone penetrometer and seismic characterization testing. As discussed in'lnspection

Report 05200008/2003001, the staff found that the MACTEC project workplan stated that cone

penetrometer testing and seismic downhole testing must be 'performed in general accordance

with ASTM D-5778-95, uStandard Test Method for Performing Electronic Friction Cone and

Piezocone Penetration Testing of Soils," and ASTM D-4428/D-4428M-00, "Standard Test

Methods for Crosshole Seismic Testing.! In addition to these ASTM standard tests, the staff

noted that ARA also developed an operating procedure that included guidance for equipment.

field verification procedures, testing instructions, and requirements'for test records.

The staff noted that MACTEC work instructions applicable to ARA activities stated that work

was to be performed in accordance with ASME NOA-1 -2000. The MACTEC principal project

engineer stated to the staff that MACTEC had previously reviewed ARA for compliance with

ASME NQA-1-2000 to support cone penetrometer work at the Savannah River Site.

Additionally, MACTEC stated that it had review6d the ARA technical capability and personnel

qualifications during the vendor procurement process.

Based on a review of the MACTEC work instructions governing ARA work activities,

discussions with MACTEC personnel, and the basis for qualification of ARA as a supplier of

ESP-related services, the staff found that MACTEC implemented adequate measures to

provide reasonable assurance that the data collected by ARA were accurate and reliable.'

17.7.3.4.2 Grumman Geophysics

Grumman Geophysics (Grumman), located in Columbus, Ohio, conducted crosshole and

downhole seismic testing at the North Anna site as a subcontractor to MACTEC. As noted

in Inspection Report 05200008/2003001, the MACTEC.workplan specified that crosshole

testing be performed in accordance with ASTM D-4428/D-4428M-00. In Appendix B

to Section 2.5.4 of the SSAR, MACTEC identified specific deviations from the

ASTM D-4428/D-4428M-00 test methods.

Grumman performed downhole seismic testing in accordance with the Grumman Standard

Operating Guideline A.0, "Downhole Seismic Testing." As discussed in'lnspection

Report 05200008/2003001, the staff reviewed Grumman's standard operating guideline for this

work and determined that it provided adequate instructions for the performance of downhole

seismic testing. -

The MACTEC work instructions for the Grumman workscope stated that the work was'to be

done under a QA program compliant with ASME NQA-1-2000. MACTEC personnel stated to

the staff that Grumman was qualified as a supplier for the ESP project based on a previous

contract with MACTEC under the vendor procurement process, as well as a review of past

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I , K

work, personnel qualifications, and equipment information. The MACTEC senior principal

project engineer also stated that MACTEC provided continuous oversight of the Grumman field

activities.

Based on a review of MACTEC work instructions governing Grumman activities and MACTEC's

oversight of Grumman field activities, the staff found that MACTEC implemented adequate

measures to provide reasonable assurance that the data collected by Grumman were accurate

and reliable.

17.7.3.4.3 Stantec Consulting

MACTEC subcontracted to Stantec Consulting (Stantec), located in Richmond, Virginia, to

perform topographical surveys to locate geologic boreholes and exploration points. As

discussed in Inspection Report 05200008/2003001, MACTEC personnel stated that Stantec

was qualified as a supplier based, in part, on a review of Stantec's QA program, technical

procedures, equipment, calibration methods, and personnel qualifications. The staff reviewed a

sampling of survey results and verified that survey data were certified by a Stantec land

surveyor licensed by the Commonwealth of Virginia.

Based on a review of MACTEC work instructions governing Stantec activities and the use of

survey personnel licensed by the Commonwealth of Virginia, the staff found that MACTEC

implemented adequate measures to provide reasonable assurance that the survey data

collected by Stantec were accurate and reliable.

17.7.3.4.4 Bedford Well Drilling

MACTEC subcontracted to Bedford Well Drilling (Bedford), located in Bedford, Virginia, to drill

boreholes and install casings for crosshole seismic work. Although Bedford was a licensed

contractor in the Commonwealth of Virginia, it did not maintain a.QA program that complied with

the criteria of Appendix B to 10 CFR Part 50 orASME NQA-1-2000. However, the MACTEC

principal project engineer stated that MACTEC provided continuous surveillance of the site

activities conducted by Bedford.

The staff reviewed the work conducted by Bedford and found that, given the limited nature of

the work activities and the oversight provided by MACTEC, the activities performed by Bedford

were adequately controlled for the purposes of the ESP site characterization studies.

17.7.3.4.5 Severn Trent Laboratory

MACTEC subcontracted to Severn Trent Laboratory (Severn Trent) for soil chemistry testing

services. MACTEC specified that laboratory testing be accomplished in accordance with the

requirements of EPA Testing Standard SW-846, Revision 1, "Test Methods for Evaluating Solid

Waste: Physical/Chemical Methods" (see Inspection Report 05200008/20030010). As

discussed in Inspection Report 05200008/2003001, MACTEC qualified Severn Trent as a

supplier for ESP services based, in part, on the performance of a MACTEC procurement

process QA audit conducted in April 2002. Although the audit was associated with work at the

Savannah River Site, the MACTEC senior principal project engineer stated to the staff that the

North Anna ESP workscope was similar to the work performed at the Savannah River site.

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Based on a review of the scope of laboratory testing activities and the results of the MACTEC

vendor audit, the staff found thiat activities performed by Severn Trent were adequately

controlled for the purposes of the ESP site characterization studies. These controls offered

reasonable assurance of the accuracy'and reliability of the ESP data provided by'Severn Trent.

17.7.4 Conclusion (Control of Purchased Material, Equipment, and Services)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

contractors and concludes that they have implemented acceptable controls for purchased

material, equipment, and -services. The staff considered the regulatory guidance of

Section 17.1.1 of RS'002 in'their review'of this portion of the application. The guidance in

RS-002 help to provide reasonable assurance that information derived from ESP activities that

could be used in the design and/or construction of SSCs important to safety would support

satisfactory performance of such SSCs once in service.

17.8 Identification and Control of Materials. Parts, and Components

17.8.1 Technical Information in the Application (Identification and Control of Materials,

Parts, and Components)

The applicant supplied information on the identification and control of materials, parts, and

components in SSAR Section 17.1, which includes the QA Manual. The manual stated that the

applicant would not procure or use any safety-related materials, parts, or components. For this

reason, the applicant stated that this criterion did not apply to the development of an ESP

application.:

In RAI 17.1-2, the staff asked the applicant to explain why the identification and control of

materials, parts, and components criterion does not apply to the development of the ESP

application. Alternatively, if this QA measure were to apply to the ESP application, the staff

asked the applicant to describe the QA measures it and its primary contractor would use. In its

response, the applicant stated that, under Dominion's overall direction, several companies were

involved in the preparation of the ESP application. The quality requirements imposed on the

various companies differed depending on their scope of work. The applicant determined that

the identification and control of materials, parts, and components was not applicable to the ESP

project because no safety-related materials, parts, or components would be procured within theproject scope. The applicant stated the same reason for not invoking this'requirement for

Bechtel's work. The staff noted that Bechtel invoked the complete requirements of Appendix B

to 10 CFR Part 50 on all of the subcontractors it used on the ESP project for work important to

safety..

17.8.2 Regulatory Evaluation (Identification and'Control of Materials, Parts, and

Components)

While the NRC does not require an ESP applicant to implement an identification and control of

materials',' parts, and components program compliant with the criteria of Appendix B to 10 CFR

Part 50, Section 17.1.1 of RS-002 contains guidance for the staff to use in evaluating an ESP

applicant's identification and control of materials, parts, and components.- RS-002,

paragraph 17.1.1.8, provides the QA'measures that constitute an acceptable level of

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identification and control of materials, parts, and components. Such controls should include

provisions to (1) identify and control materials, parts, and components related to ESP activities

that could affect SSCs important to safety, and (2) ensure that incorrect or defective items are

not used in ESP activities that could affect SSCs important to safety.

17.8.3 Technical Evaluation (identification and Control of Materials, Parts, and

Components)

Neither the applicant'nor its primary contractor invoked QA measures for the identification and

control of materials, parts, and components. The staff concluded, based on its review of the

applicant's response to RAI 17.1-2 and observations during the inspection, that the applicant

and Bechtel did not conduct activities important to safety requiring the identification and control

of materials, parts, and components.

17.8.4 Conclusion (Identification and Control of Materials, Parts, and Components)

As set forth above, the staff reviewed the applicant and its contractor's need for these QA

measures and concludes that, based on the scope of work for the ESP project, the identification

and control of materials, parts, and components is not required.

17.9 Control of Special Processes

17.9.1 Technical Information in the Application (Control of Special Processes)

The applicant supplied information on the control of special processes in SSAR Section 17.1,

which includes the QA Manual. The manual states that the safety-related scope of the

development of the ESP application would not involve the use of special processes. For this

reason, the applicant stated that this criterion does not apply to the development of an ESP

application.

In RAI 17.1-2, the staff asked the applicant to explain why the control of special processes does

not apply to the development of the ESP application. Alternatively, if this QA measure does

apply to the ESP application, the staff asked the applicant to describe the QA measures it and

its primary contractor used. In its response, the applicant stated that, under Dominion's overall

direction, several companies were involved in the preparation of the ESP application. The

quality requirements imposed on the various companies differed depending on their scope of

work. Dominion determined that control of special processes was not applicable because the

project scope did not include any safety-related construction activities. The applicant stated the

same reason for not invoking this requirement for Bechtel's work. The staff noted that Bechtel

invoked the complete requirements of Appendix B to 10 CFR Part 50 on all subcontractors it

used on the ESP project for safety-related work.

17.9.2 Regulatory Evaluation (Control of Special Processes)

While the NRC does not require an ESP applicant to implement control of special processes

compliant with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002 contains

guidance for the staff to use in evaluating an ESP applicant's control of special processes.

RS-002, paragraph 17.1.1.9, provides the QA measures that constitute an acceptable level of

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control of special processes. Acceptable control of special processes should include provisions

to (1) ensure the acceptability of special processes used for ESP activities that could affect

SSCs important to safety, and (2) ensure that qualified personnel using qualified procedures

and equipment perform special processes related to ESP activities that could affect SSCs

important to safety.

17.9.3 Technical'Evaluation (Control of Special Processes)

Neither the applicant nor its primary contractor invoked QA measures for control of special

processes. The staff concluded, based on its review of the applicant's response to' RAI 17.1-2

and observations during the inspection, that the applicant and Bechtel did not conduct activities

important to safety requiring control of special processes.

17.9.4 Conclusion (Control of Special Processes)

As set forth above, the staff reviewed the need for QA measures by the applicant and its

contractors and concludes that, based on the scope of work for the ESP project, control of

special processes is not required.

17.10 Inspection

17.10.1 Technical Information in the Application (Inspection)

The applicant supplied information on controls for inspection in SSAR Section 17.1, which

includes the QA Manual. As discussed in Inspection Report 05200008/2003001, the manual

states that the Dominion QA procedures contain the standards, requirements, or guides which

form the basis for the procedures implementing this section.

The QA Manual states that administrative procedures describe the requirements for the

inspection of relevant ESP activities. The manual notes that inspection procedures for those

activities affecting quality must be established, as appropriate, before work commences.

Written procedures must be developed as needed to include inspection hold points.

The QA Manual identifies procedures for examinations, measurements, or tests that require

witnessing at inspection holdpoints. The inspection performed at a holdpoint must be specific in

nature. It must include quality characteristics and acceptance/rejection criteria, or it must'

specify qualitative criteria, such as operability checks, complian'ce withprocedural steps, or

cleanliness instructions. -The inspection mtust be documented by signature or initials on the

written procedure form.-.

The QA Manual states that the inspection program requires that appropriate inspectors be

assigned for the activit being inspected. An inspector may be a memnber of the organization'

performing the activity. However, the inspector mu'st be qualified and must not be the person

performing the activity or the supervisor directly responsible for the activity. '

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17.10.2 Regulatory Evaluation (inspection)

While the NRC does not require an ESP applicant to implement inspection controls compliant

with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002 contains guidance

for the staff to use in evaluating an ESP applicant's controls for inspection. RS-002,

paragraph 17.1.1.10, provides the QA measures that constitute an acceptable level of

inspection control. Acceptable inspection controls should include (1) provisions for the

inspection of activities affecting the quality of ESP activities that could affect SSCs important to

safety, including the items and activities to be covered, (2) organizational responsibilities and

qualifications for individuals or groups performing inspection-of ESP activities that could affect

SSCs important to safety, and (3) provisions for inspection personnel to be independent of the

performance of the activity being inspected.

17.10.3 Technical Evaluation (Inspection)

17.10.3.1 Dominion

Section 11, "Inspection," of the QA Manual describes the measures that the applicant

established for inspection of activities affecting quality. As discussed in Inspection

Report 05200008/2003001, Section 11 of the QA Manual invokes the requirements of

Dominion's existing QA procedures for the current operating units. The staff found that the

Dominion Quality Assurance Program conformed to the criteria of Appendix B to 10 CFR

Part 50 and complied with the regulatory positions of the RGs listed in the Dominion QA

procedures. The staff found that nuclear oversight personnel, independent of the ESP activities

performed, conducted the inspection activities. The personnel appeared to be adequately

trained and qualified. Based on staff discussions with the nuclear oversight personnel who

conducted the inspections, the staff concluded that the activities inspected appeared to have

been adequately observed and documented.

17.10.3.2 Bechtel

The Bechtel QAPP invokes the requirements of the NQAM. Policy No. Q-10.1, "Plant Site

Inspections," of the NQAM identifies the requirements and responsibilities for plant site

inspection activities performed to verify quality. The policy applies to inspections performed at

the ESP site by the Bechtel Quality Control Group for work in which Bechtel is responsible for

quality verification inspection. Policy No. Q-7.6, Subcortractor Control," of the NQAM

describes Bechtel's surveillance of subcontractors who perform their own quality verification

inspection. Bechtel stated that it designed the NQAM policies to meet the requirements of

Appendix B to 10 CFR Part 50. Based on staff discussions with Bechtel personnel who had

conducted inspections, the staff concluded that these personnel were knowledgeable of

inspection requirements and appeared to be adequately trained and qualified. In addition, the

staff found that Bechtel inspection personnel were independent of the ESP activities they

inspected. The staff found no deficiencies in Bechtel's oversight and inspection of

subcontractor activities.

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17.10.3.2.1 MACTEC

In accordance with the project workplan, MACTEC provided oversight and surveillance for site

activities. As discussed in Inspection Report 05200008/2003001, the staff reviewed QA

checklists documenting the MACTEC QA surveillances performed to assure that MACTEC field

activities complied with applicable procedures, codes, and standards. The QA surveillance

checklists pertained to observations of MACTEC field activities conducted November 21-22,

2002, and December 11-12, 2002.

The staff determined that MACTEC completed the checklists for each section of MACTEC

Work Plan No. 1, issued on November 22, 2002. The checklists addressed the salient aspects

of each section of the plan. For example, the workplan addressed field requirements

associated with planning and permitting. The surveillance checklist required verification of

weather conditions and preparation of required permits before the start of field activities. The

staff noted that the checklist associated with QA program documentation required verification

that 10 CFR Part 21 requirements are available to project personnel. The staff also noted that

MACTEC did not identify any deficiencies during the surveillance activities.

The staff also found that the MACTEC QA organization was independent of the organizations

performing laboratory or field work.

17.10.4 Conclusion (Inspection)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they implemented an acceptable level of control for

inspection. The staff considered the regulatory guidance of Section 17.1.1 of RS-002 in their

review of this portion of the application. The guidance in RS-002 helps to provide reasonable

assurance that information derived from ESP activities that could be used in the design and/or

construction of SSCs important to safety would support satisfactory performance of such SSCs

once in service. .

17.11 Test Control

17.11.1 Technical Information in the Application (Test Control)

The applicant supplied information on test controls in SSAR Section 17.1, which includes the

QA Manual. As discussed in Inspection Report 05200008/2003001 the manual states that the

Dominion QA procedures contain the standards, requirements, or guides on which the

procedures implementing this section are based.

The QA Manual states that administrative procedures describe the requirements for test control

in safety-related applications. Written test procedures must control testing done in support of

the ESP application development. The manual states that these test procedures will include or

reference (1) the requirements and acceptance limits contained in applicable design and

procurement documents, (2) test prerequisites, such as the availability of adequate and

appropriate equipment and calibrated instrumentation; trained, qualified, and licensed or

certified personnel; the completeness of the item to be tested; suitable and controlled

environmental conditions; and provisions for data collection and storage, (3) instructions for

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If

performing the test, (4) inspection points, as appropriate, and (5) acceptance and rejection

criteria.

17.11.2 Regulatory Evaluation (Test Control)

While the NRC does not require an ESP applicant to implement test controls compliant with the

criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002 contains guidance for the

staff to use in evaluating an ESP applicant's test controls.' RS-002, paragraph 17.1.1.11,

provides the QA measures that constitute an acceptable level of test control. Acceptable test

controls should include provisions to ensure (1) that tests performed related to ESP activities

that could affect SSCs important to safety are appropriately controlled to provide confidence

that these SSCs will perform adequately in service, and (2) that prerequisites are provided in

written test procedures and that test results are documented and evaluated for ESP activities

that could affect SSCs important to safety.

17.11.3 Technical Evaluation (Test Control)

The staff found that the Bechtel QAPP established the quality control interface between the

Dominion QA program and the Bechtel NQAM. Dominion also established policies for test

control in the QA Manual and used the guidance contained in ASME NQA-1-2000. The Bechtel

NQAM further delineates these policies. The staff reviewed reports of testing accomplished by

subcontractors and found that they appear to have performed the testing in accordance with the

policies established in the Bechtel NQAM. As discussed below, the applicant's test controls,

and those of its primary contractor and subcontractors, meet the guidance in Section 17.1.1 of

RS-002.

17.11.3. 1 Dominion

Section 12, "Test Control," of the QA Manual states that written test procedures control testing

in support of the ESP application development. The section also states that the test

procedures include test prerequisites, requirements, and acceptance limits contained in

applicable design and procurement documents; instructions for performing the test; appropriate

inspection points; acceptance and rejection criteria; prerequisites regarding the use of trained

and qualified personnel to perform the test; provisions for data collection and storage; and

methods for documenting or recording test results. Instrumentation used for testing must be in

a calibration program, further described in Section 17.12 of this SER. During the inspection,

the staff reviewed test procedures for content, acceptance and rejection criteria, and test

results. The staff did not note any deficiencies.

17.11.3.2 Bechtel

Policy No. Q-11.1, 'Testing Requirements," of the Bechtel NQAM applies to the ESP project, as

stated in the Bechtel QAPP. The policy identifies the requirements and responsibilities for the

control of tests and safety-related items and systems. Bechtel stated that the test control

policies contained in the NQAM were intended to meet the requirements of Appendix B to

10 CFR Part 50 and ASME NQA-1 -2000. ASME NQA-1 -2000 requires test prerequisites for

applicable procedures. The Bechtel policy states that tests must be performed consistent with

written procedures that incorporate or reference test requirements, acceptance limits, and the

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measuring and test equipment to be used. The policy further mandates that components,

systems, and equipment be tested in accordance with applicable design documents, test

procedures, codes, standards, or other specified supplier requirements. Additionally, the policy

provides requirements for personnel qualification, test methods, and review and documentation

of test results and deviations. The staff did not note any'deficiencies.

The staff reviewed a sample of the documentation for testing performed in support of the ESP

project by Bechtel and its subcontractors. The sample included a review of geotechnical field'

investigations and laboratory reports, seismic source characterization models, cone

penetrometer tests, soil and rock sample laboratory tests, and probabilistic seismic hazard

assessments. The staff did not note any deficiencies. -

17.11.4 Conclusion (Test Control)

As set forth above, the staff reviewed the QA measures employed by the applicant and its'-

primary contractor and concludes that they implemented acceptable test controls. The staff

considered the regulatory guidance of Section 17.1.1 of RS-002 in their review of this portion of

the application. The guidance in RS-002 help to provide reasonable assurance that information

derived from ESP activities that could be used in the design and/or-construction of SSCs

important to safety would support satisfactory performance of such SSCs once in service.

17.12 Control of Measuring and Test Equipment

17.12.1 Technical Information in the Application (Control of Measuring and Test

Equipment)

The applicant supplied information on the control of measuring and test equipment (M&TE)

in SSAR Section 17.1, which includes the QA Manual. As discussed in Inspection.

Report 05200008/2003001, the manual states that the Dominion QA procedures contain the

standards, requirements, or guides which form the basis for the procedures implementing this

section.

The QA Manual states that administrative procedures describe the requirements for the control

of M&TE used in the measurement, inspection, maintenance, and monitoring of safety-related

applications. The QA Manual notes that a program, established and documented in the

administrative procedures, describes the calibration technique and frequency, maintenance,

and control of all M&TE that are used in the measurement, inspection, maintenance, and

monitoring of satety-related SSCs. The manual states that it does not intend to imply a need

for special calibration and control measures of rulers, tape measures, levels, and other basic

tools, if normal commercial practices provide adequate accuracy. Controls for M&TE include

the transportation, storage, and protection of the equipment; the handling of associated

documents giving the status of all items under the calibration system, such as maintenance

history, calibration test data, and individual log sheets assigned to each device; and the

permanent marking of each device by a unique number.

The QA Manual states that M&TE used on safety-related systems or equipment are calibrated

using reference standards for which calibration has a known, valid relationship to nationally

recognized standards or accepted values of natural physical constants. Stickers must be

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affixed on a conspicuous surface identifying, at a minimum, the date of the last calibration and

next calibration due date.

In addition, the QA Manual states that, when M&TE used in activities affecting quality is found

to be out of calibration, the applicant will evaluate and document the validity of previous tests

and the acceptability of devices previously tested. All previous tests and measurements

performed during the current or preceding calibration cycle must be redone if the evaluation so

indicates.

17.12.2 Regulatory Evaluation (Control of M&TE)

While the NRC does not require an ESP applicant to implement controls of M&TE compliant

with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002 contains

guidance for the staff to use in evaluating an ESP applicant's control of M&TE. RS-002,

paragraph 17.1.1.12, details the QA measures that constitute an acceptable level of control of

M&TE. Acceptable control of M&TE should include provisions to ensure that tools, gauges,

instruments, and other measuring and testing devices are properly identified and controlled and

are calibrated and adjusted at specified intervals.

17.12.3 Technical Evaluation (Control of M&TE)

17.12.3.1 Dominion

Section 17.2.12 of the Bechtel QAPP and Section 13 of the QA Manual state that the applicant

established administrative procedures that describe its control of M&TE. As discussed in

Inspection Report 05200008/2003001, Dominion's administrative procedures further describe

requirements and programmatic controls for M&TE. The QAPP and QA Manual note that

controls were established for M&TE transportation, storage, and protection of equipment.

Dominion established additional controls for documentation of maintenance history, calibration

test data, and log sheets assigned to each device. Section 13 of the QA Manual further states

that M&TE is to be used on safety-related equipment, or systems will be calibrated using

reference standards for which calibration has a known relationship to nationally recognized

standards, such as the National Institute of Standards and Technology. The staff found the

guidance for control of M&TE adequate for the conduct of ESP activities. Based on a review of

the applicant's administrative controls for M&TE, the staff determined that the applicant

implemented adequate measures to provide reasonable assurance that it would properly control

M&TE.

17.12.3.2 Bechtel

Policy No. Q-1 2.1, "Control of Measuring and Test Equipment," of the Bechtel NQAM applies to

the ESP project, as stated in the Bechtel QAPP, and defines the responsibilities for the

maintenance and control of M&TE. The policy applies to the calibration and control of M&TE

used by Bechtel personnel, suppliers, and subcontractors to conduct tests, make

measurements, and record inspection and test results. The policy states that control of M&TE

must conform to the requirements of ANSI N45.2, Section 12, or ASME NQA-1 -2000,

Supplement 12S-1. The policy requires that the calibration procedures define the calibration

method, means of identification, recalibration frequency of the M&TE, and issuance of tools,

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gauges, and test equipment used. Additionally, the policy discusses the evaluation of M&TE

found to be outside calibration limits, calibration against certified equipment having known

relationships to nationally recoghized standards, and documentation of M&TE usage in test

records. -

As discussed in Inspection Report 05200008/2003001, the staff reviewed the policies,

requirements, and controls established in the procedures noted above as they apply to M&TE.

The staff also reviewed a sample of calibration records related to the performance of geologic.

tests, seismic test activities, and laboratory testing completed in support of the ESP project.

Based on the review of Bechtel's administrative controls and sample of calibration records, the

staff determined that Bechtel implemented adequate measures to provide reasonable

assurance that it properly controlled M&TE.

17.12.4 Conclusion (Control of M&TE)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they implemented acceptable control of M&TE. The staff

considered the regulatory guidance of Section 17.1.1 of RS-002 in their review of this portion of

the application. The guidance in RS-002 helps to provide reasonable assurance that

information derived from ESP activities that could be used in the design and/or construction of

SSCs important to safety would support satisfactory performance of such SSCs once in service.

17.13 -Handling, Storage, and Shipping -

17.13.1 Technical Information in the Application (Handling, Storage, and Shipping)

The applicant supplied information on the controls for handling, storage, and shipping in

SSAR Section 17.1, which includes the QA Manual. As discussed in Inspection - - -

Report 05200008/2003001, the manual states that the Dominion QA procedures contain the

standards, requirements, or guides that form the basis for the procedures implementing this

section. The manual states that administrative procedures describe the requirements for

control of handling, storage, and shipping of equipment for safety-related applications..

The QA Manual also states that Dominion has established measures in its administrative

procedures to provide adequate methods for use by qualified personnel for the classification,

packaging, cleaning, preservation, shipping, storage, and handling of material and equipment.

These measures, prepared in accordance with design and specification requirements, define

responsibilities, levels of cleanliness, tagging, and storage levels for categorized items. The

procedures must also control cleaning, handling,istorage, packaging, shipping, and

preservation of materials, components, and systems to preclude damage, loss, or deterioration

by -environmental conditions, such as temperature or humidity. Materials verification and

vendor surveillance inspectors verify implementation of these measures. -

The QA Manual notes that the operational QA program includes some activities described in

this section that may not be needed for ESP application development. However, the manual

adds that handling, storage, and potential shipping of soil samples taken during site

geotechnical investigations are examples of safety-related activities for the ESP program that

are subject to this criterion.

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17.13.2 Regulatory Evaluation (Handling, Storage, and Shipping)

While the NRC does not require that an ESP applicant implement controls for handling,

storage, and shipping compliant with the criteria of Appendix B to 10 CFR Part 50,

Section 17.1.1 of RS-002 contains guidance for the staff to use in evaluating an ESP

applicant's controls for handling, storage, and shipping. RS-002, paragraph 17.1.1.13, provides

the QA measures that constitute an acceptable level of handling; storage, and shipping control.

Such controls should include provisions to control the handling, storage, shipping, cleaning, and

preservation of items related to ESP activities that could affect SSCs important to safety, in

accordance with work and inspection instructions, to prevent damage, loss, and deterioration by

environmental conditions, such as temperature or humidity.

17.13.3 Technical Evaluation (Handling, Storage, and Shipping)

Dominion identified soil core samples as the sole type of sample material within the scope of

this criterion. MACTEC, one of Bechtel's subcontractors, retrieved the soil core samples, which

were stored and maintained onsite. The following sections detail the QA measures these

organizations applied for the handling and storage of the soil core samples.

17.13.3.1 Dominion

Section 14 of the QA Manual, "Handling, Storage, and Shipping," states that Dominion

established measures in its administrative processes for classifying, packaging, cleaning,

preserving, shipping, storing, and handling materials and equipment. The section further states

that these procedures define responsibilities, levels of cleanliness, tagging, and storage levels.

They also provide for measures to preclude damage, loss, or deterioration by environmental

conditions. As discussed in Inspection Report 05200008/2003001, the section also notes that

the Dominion QA procedures contain standards, requirements, or guides that form the basis for

implementing the procedures.

The staff found that these procedures note the establishment of such measures and that

inspectors verify their implementation. The procedures state that Dominion complied with

RG 1.38, Revision 2, "Quality Assurance Requirements for Packaging, Shipping, Receiving,

Storage, and Handling of Items for Water-Cooled Nuclear Power Plants," with specified.-

clarifications and exceptions.

As discussed in Inspection Report 05200008/2003001, Dominion's applicable lower-tier

administrative procedures specify responsibilities for materials handling, provide specific

requirements and guidelines for packaging and for storage areas, and provide storage

environments in terms of Levels A through D. Dominion-stored the ESP materials at the most,-

stringent level (A), in accordance with the procedures. This storage level maintains materials

that are exceptionally sensitive to-environmental conditions and therefore require special

protection against temperature and humidity changes, physical damage, and airborne

contamination. Such storage must be in a fire-resistant, weathertight, well-ventilated building or

enclosure, which is (1) not subject to flooding,(2) temperature and humidity controlled, and

(3) ventilated via filters.

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The staff inspected the storage facilities for the soil samples at the North Anna site. These

materials were kept in a dedicated Level A facility (i.e., a locked cage). The temperature,

airflow, and humidity appeared'to be'consistent with a facility subjected to stringent climate

control. The applicant stored the soil samples in sturdy wooden crates or in sealed glass jars

kept in compartmented boxes. ;The staff did not note'any deficiencies in the applicant's storage

arrangements.

17.13.3.2 MACTEC

As discussed in Inspection Report 05200008/2003001, the MACTEC workplan contains

instructions for handling core materials and samples before storage or testing. It requires that

(1) disturbed soil sampling be performed in accordance with ASTM D1586-99,:"Standard Test

Method for Penetration'Test and Split-Barrel Sampling of Soils," (2) undisturbed sampling be

performed in accordance with ASTM D1587-00, uStandard Practice for Thin-Walled Tube

Sampling of Soils for Geotechnical Purposes," and (3) sample handling follow ASTM D4220-95,-

"Standard Practices for Preserving and Transporting Soil Samples." The workplan also - -

provides additional instructions on specific measures'for sample handling.

The staff reviewed the core and soil sample inventory log and found samples to be uniquely

identified. During a check of several log entries against stored samples, the staff found no

inconsistencies. The staff noted that several of the inventory sheets indicated that samples

were prepared and checked by the same person, while others were apparently not checked.

While this practice increases the chance of an error, the staff did not note any performance

issues caused by this practice.

Based on observation'of the storage area; a visual check of the samples, and review of the

inventory sheets, the staff concluded that the applicant had properly stored and inventoried the

samples and met the guidance in Section 17.1.1 of RS-002. - --

17.13.4 Conclusion (Handling, Storage,-and Shipping)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

subcontractors and concludes that they implemented acceptable controls for handling, storage,

and shipping. The staff considered the regulatory guidance of Section 17.1.1 of RS-002 in their

review of this portion of the application. The guidance in RS-002 help to provide reasonable - - -

assurance that information derived from ESP activities that could be used in the design and/or

construction of SSCs important to safety would support satisfactory performance of such SSCs

once in service.

17.14 Inspection. Test, and Operatin4 Status'

17.14.1 Technical Information in the Application (Inspection, Test, and Operating Status)

The applicant supplied information on controls for inspection, test, and operating status in

SSAR Section 17.1, which includes the QA Manual. The manual states that the applicant's

administrative procedures and station operating procedures describe the requirements for

inspection, test, and operating status of items and/or equipment for safety-related applications.

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[Ir al

The QA Manual states that the administrative and station operating procedures establish

measures for identifying and documenting the inspection and test status for items to prevent

missing specified inspections and tests. These measures also define the three general

categories of inspection and test status for items-accept, reject, or hold. They provide for

status identification by stickers, tags, record cards, test records, checklists, or logs. Station

procedures must control the application and removal of the various status tags, stickers, and

other indicators. Specific test procedures control testing that supports the ESP project.

17.14.2 Regulatory Evaluation (Inspection, Test, and Operating Status)

While the NRC does not require an ESP applicant to implement controls for inspection, test,

and operating status compliant with the criteria of Appendix B to 10 CFR Part 50,

Section 17.1.1 of RS-002 contains guidance for the staff to use in evaluating an ESP

applicant's controls for inspection, test, and operating status. RS-002, paragraph 17.1.1.14,

provides the QA measures that constitute an acceptable level of controls for inspection, test,

and operating status. Such controls should include provisions to indicate the inspection, test,

and operating status of items related to ESP activities that could affect SSCs important to

safety to prevent inadvertent use or bypassing of inspection and tests.

17.14.3 Technical Evaluation (Inspection, Test, and Operating Status)

17.14.3.1 Dominion

Section 15, "Inspection, Test, and Operating Status," of the QA Manual states that the applicant

established measures in administrative and station operating procedures regarding the

identification and documentation of inspection and test status items to prevent inadvertent

bypassing of specified instructions and tests. The manual defines measures in three general

categories and provides for status identification by stickers, tags, record cards, test records,

checklists, or logs. Additionally, the manual states that the applicant identifies the operating

status of items and/or equipment through records, checklists, or operational tagging systems

maintained to indicate the status and authority to operate the item and/or equipment. Testing to

support the ESP project is controlled by specific contractor test procedures. Section 17.11 of

this SER also discusses test control. Based on its review of ESP administrative procedures and

station operating procedures, the staff found the applicant's controls for inspection, test, and

operating status to be adequate.

17.14.3.2 Bechtel

Policy No. Q-10.1 (discussed in Section 17.10 of this SER) of the Bechtel NQAM applies to the

ESP project, as stated in the Bechtel QAPP. The policy defines the requirements and

responsibilities for site quality verification. The policy states that procedures or instructions

shall provide for the identification of personnel responsibilities, recordkeeping, inspection

results, frequency of test documentation, and special process controls. Policy No. Q-1 1.1

(discussed in Section 17.11 of this SER) and Policy No. Q-15.1, "Control of Nonconformances,"

which describes the requirements for identifying nonconforming items, detail the additional QA

controls in this area. Section 17.15 of this SER provides more details regarding QA controls for

nonconforming materials, parts, or components.

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As discussed in Inspection Report 05200008/2003001, the staff reviewed the policies noted '-

above, as well as applicable administrative procedures, to verify that Bechtel established

adequate QA controls in this area. Based on a review of applicable policies and procedures,

the staff found the Bechtel guidance for inspection, test, and operating status'adequate for the

conduct of ESP activities.,

17.14.4 Conclusion (Inspection, Test, and Operating Status)

As set forth above, the staff reviewed the QA measures employed by the applicant and its'

primary contractor and concludes that they' implemented acceptable controls for inspection,-

test, and operating status. The staff considered the regulatory guidance of Section 17..1 ofRS-002 in their review of this portion of the application.' The guidance in RS-002 help'to ' provide reasonable assurance that information derived from ESP activities that could bleused in

the design and/or construction of SSCs important to safety would support satisfactory

performance of such SSCs once in service. '-

17.15 Nonconforming Materials. Parts, or Components

17.15.1 Technical Information in the Application (Nonconforming Materials, Parts, or

Components)

The applicant supplied information on controls for nonconforming materials, parts, or

components in SSAR Section 17.1, which includes the QA Manual. The QA Manual states

that the applicant's administrative procedures describe the requirements for control of

nonconforming materials, parts, or components for safety-related applications. Because of the

scope of ESP activities, the applicant did not expect to receive any parts, materials, or

components from offsite sources. However, the controls govern soil and site characterization

samples and their storage and shipment, if necessary. Specifically, the administrative

procedures require that the individual who discovers a nonconformance must identify, describe,

and document it on a deviation report or a discrepant shipment report.

The QA Manual states that when a nonconforming item is identified, it is placed in the hold area

established in the storeroom or other segregated location, if practical, and identified with a hold

tag to prevent its inadvertent use. If material is classified as "reject," the hold tag must remain

attached to the materiaVcomponent until loaded for departure from the site and can only be

removed by authorized personnel in accordance with approved procedures.

The QA Manual states that audits and inspections ensure the implementation and verification of

the procedures for the control of nonconformances.

17.15.2 Regulatory Evaluation (Nonconforming Materials, Parts, or Components)

While the NRC does not require that an ESP applicant implement controls of nonconforming

materials, parts, or components compliant with the criteria of Appendix B to 10 CFR Part 50,

Section 17.1.1 of RS-002 contains guidance for the staff to use in evaluating an ESP

applicant's control of nonconforming materials, parts, or components. RS-002,

paragraph 17.1.1.15, provides the QA measures that constitute acceptable provisions for

addressing nonconforming materials, parts, or components control. Such controls should

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include provisions to control the use or disposition of nonconforming materials, parts, or

components related to ESP activities that could affect SSCs important to safety.

17.15.3 Technical Evaluation (Nonconforming Materials, Parts, or Components)

17.15.3.1 Dominion

The applicant established a process for nonconforming materials, parts, or components,

outlined in the QA Manual. As discussed in Inspection Report 05200008/2003001, a Dominion

implementing QA procedure details the process for controlling nonconformances observed

during receipt, inspection, storage, fabrication, erection, installation, initial and/or acceptance

testing, or initial operation. The procedure provides for the preparation and issuance of

deviation reports and discrepant shipment reports, in accordance with prescribed procedures.

The procedure states that, when the'applicant identifies a nonconforming itemn, it is placed in a'

hold area with a hold tag to prevent its inadvertent use. The procedure also provides guidance

for the disposition of rejected material or material placed on hold. The staff found the guidance

for nonconforming materials, parts, or components to be adequate for the scope of ESP

activities.

17.15.3.2 Bechtel

In developing the QAPP, Bechtel determined that certain quality policies contained in the

Bechtel NQAM do not apply to the ESP project, including the control of supplier and

subcontractor nonconformances; identification and control of materials, parts, and components;

control of special processes; control of status items; control of nonconformances; significant

reportable deficiencies; and construction/site services QA records.

Bechtel personnel stated that its nonconformance quality policies address hardware

procurement nonconforming conditions. Bechtel personnel noted that it would address

deviations in ESP project engineering services from procurement specifications under the other

processes that apply to the ESP project, such as the supplier deviation disposition process, the

engineering error report process, or the corrective action request process. The staff reviewed

these other deviation reporting processes and found that Bechtel had implemented sufficient

measures to provide reasonable assurance that it could identify and correct nonconformances

in procured engineering services.

As discussed in Inspection Report 05200008/2003001, the staff reviewed the scope of the

QAPP, including quality-related activities determined not to apply to the ESP project, and found

that the QAPP was consistent with the Dominion QA Manual. The quality elements covered by

the Bechtel QAPP were also consistent with the scope of work outlined in Dominion's PO for

Bechtel. Additionally, the staff found that the QAPP controls were reasonable and consistent

with the guidelines contained in Section 17.1.1 of RS-002. Therefore, the staff determined that'

the procurement of engineering services from Bechtel complied with the Dominion QA Manual

requirements and was consistent with the procurement controls specified in the Dominion

NDCM procedures.

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17.15.4 Conclusion (Nonconforming Materials, Parts, or Components)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they implemented an acceptable level of control for

nonconforming materials, parts, or components. The staff considered the regulatory guidance

of Section 17.1.1 of RS-002 in their review of this portion of the application. The 'guidance in

RS-002 helps to provide reasonable assurance that information derived from ESP activities that

could be used in the design and/orconstniction of SSCs important to safety would support'- satisfactory performance of such SSCs'once in service.

17.16 Corrective Action

17.16.1 Technical Information in the Application (Corrective Action)

The applicant supplied information on its Corrective Action Program in SSAR Section 17.1,

which includes the QA Manual. The manual states that the applicant would control the

Corrective Action Program in accordance with Dominion QA procedures.

The QA Manual states that Dominion establishes corrective action measures as an integral part

of the processing and resolution of nonconformances and failures in service. These measures

assure that significant adverse quality conditions are identified, documented, their cause

determined, and the necessary corrective actions taken to preclude repetition of the adverse

quality conditions. It further states that the monitoring effort of the staff and the audits '

conducted by the Nuclear Oversight Group ensure the verification of the proper implementation

of corrective action measures and closeout of corrective action'docunmentation. The applicant

uses deviation reports and audit findings to report adverse conditions significant to quality,' the

cause of the conditions, and the initiation of corrective action to the appropriate levels of both

offsite and onsite management; If further corrective action is required, the applicant relies on'

the appropriate management program for performing, tracking, and closing the issue.

The QA Manual states that the Nuclear Engineering Group maintains a program to evaluate

complex design concerns that may lead to adverse quality c6nditions. The potential problem

reporting (PPR) system allows for detailed, multidisciplinary reviews of complex design

concerns that may yield deviation reports. Many design concerns cannot be determined to be

adverse to quality until a detailed design review is performerns The PR prote detrmie to b

activity as part of the NDCP. -

The QA Manual states that nuclear oversight and inspection personnel have the authority, and

the responsibility, to stop work in progress when it is not being done in accordance with

approved procedures or when it may jeopardize safety or equipment integrity.

17.16.2 Regulatory Evaluation (Corrective Action)'

While the NRC does not require an ESP a'ppiicant to implement a corrective action program

compliant with the criteria of Appendix B to 10 CFR Part 50, Section 17.1.1 of RS-002 contains

guidance for the staff to use in evaluating an .ESP applicant's corrective action program.'

RS-002, paragraph 17.1.1.16, provides the QA measures that constitute'an acceptable

corrective action program. This program should include provisions to ensure that conditions

17-35
'El

adverse to quality are promptly identified and corrected. For significant conditions adverse to

quality, those provisions should preclude recurrence.

17.16.3 Technical Evaluation (Corrective Action)

17.16.3.1 Dominion

The applicant established a corrective action program. As discussed in Inspection -

Report 05200008/2003001; the QA Manual outlines the process, which is controlled in the

Dominion QA procedures. These procedures detail the requirements for identifying, screening,

documenting, resolving, and tracking discrepancies associated with the development of the

ESP application. They also detail the process for identifying and determining the operability

and reportability of conditions potentially adverse to quality and operability.

The staff noted that the Dominion engineering staff maintains a program to evaluate design

concerns that could lead to adverse quality conditions. The PPR' system, which is described in

the NDCM procedures, allows for detailed, multidisciplinary reviews of complex design concerns

that may yield a deviation report. The PPR system is not a corrective'action or commitment

tracking system. Instead, it provides a means to analyze and review complex technical

concerns that may be significant and may' become issues. As outlined in the-procedure, other

processes handle corrective actions and commitment tracking. The NRC staff found that the

applicant's procedures governing corrective actions met the guidance in Section 17.1.1 of

RS-002. Inspection Report 0520008/2003001 details specific examples of identified problems:

and the resultant corrective actions for ESP activities. The staff found that the applicant

followed the guidance in the governing procedures and documents and adequately

implemented corrective actions.

17.16.3.2 Bechtel

Bechtel's ESP-specific QAPP states that the NQAM would guide its Corrective Action Program.

The manual states that corrective action applies to significant conditions adverse to quality, as

described in Criterion XVI of Appendix B to 10 CFR Part 50; ANSI N45.2, Section 17; and'

ASME NQA-1-2000. In addition, the QAPP states that, if Bechtel personnel performing work

identify a condition adverse to quality in existing Dominion procedures or documentation, they

must document such a condition on a deviation report form, in accordance with Dominion

procedures, and report it to Dominion for further evaluation and disposition.' The staff

concluded that Bechtel personnel implemented the corrective action program outlined in the

QAPP.

17.16.4 Conclusion (Corrective Action)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they implemented an acceptable corrective action

program. The staff considered the regulatory guidance of Section 17.1.1of RS-002 in their

review of this portion of the application. The guidance in RS-002 helps to provide reasonable

assurance that information derived from ESP activities that could be used in the design and/or

construction of SSCs important to safety would support satisfactory performance of such SSCs

once in service.

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17.17 Quality Assurance Records

17.17.1 Technical Information in the Application (Quality Assurance Records)

The applicant supplied information on QA record controls in SSAR Section 17.1, which includes

the QA Manual. The manual states that the Dominion QA procedures contain the requirements

for the retention and storage of QA records. The administrative procedures establish and

document the requirements and responsibilities for QA record transmittal, retention, and

maintenance subsequent to the completion of work at the power station.

The QA Manual states that elements of the operating QA program must be used to ensure

quality in the ESP project. Section 18 of the QA Manual, which addresses QA records, states

that the administrative procedures document the requirements and responsibilities for record

transmittal, retention, and maintenance. Dominion primarily used the existing administrative

procedures for its current operating units, although the applicant did implement several

administrative procedures specific to the ESP as part of its ESP project manual. As discussed

in Inspection Report 0520008/2003001, the QA Manual also refers to the Dominion QA

procedures as the source of requirements and commitments for retention and storage of QA

records.

These procedures contain the requirements and responsibilities for QA records transmittal,

retention, and maintenance. They list examples of QA records applicable to the operating

nuclear power plants and state that records were maintained in accordance with NRC

regulations, commitments to ANSI N45.2.9-1974, "Requirements for Collection, Storage and

Maintenance of Quality Assurance Records for Nuclear Power Plants," and administrative

requirements. These procedures contain statements of commitment to standards,;

requirements, or guides, and they refer, to RG 1.88, "Collection, Storage, and Maintenance of

Nuclear Power Plant Quality Assurance Records." This RG (which the NRC has withdrawn

because the ANSI standards endorsed by the RG have been incorporated into

ASME NQA-1 -1983, Quality Assurance Program Requirements for Nuclear Facilities," and

subsequently endorsed by RG 1.28, Revision 3, 'Quality Assurance Program Requirements

(Design and Construction)") endorsed the requirements and guidelines for records collection,

storage, and maintenance in ANSI N45.2.9-1974, subject to certain clarifications and

exceptions. Dominion's procedures also describe record retention measures, including

maintaining proper indices, establishing a filing system, and constructing and securing records

facilities to prevent destruction of records by fire, flooding, theft, and deterioration through

environmental conditions, such as temperature and humidity.

17.17.2 Regulatory Evaluation (Quality Assurance Records)

While the NRC does not require an ESP applicant to control QA records compliant with the

criteria of Appendix B, Section 17.1.1 of RS-002 contains guidance for the staff to use in

evaluating an ESP applicant's QA records. RS-002, paragraph 17.1.1.17, provides the QA

measures that constitute an acceptable level of QA record control. Acceptable control of QA

records should include provisions for the identification, retention, retrieval, and maintenance of

quality records.

17-37
II

17.17.3 Technical Evaluation (Quality Assurance Records)

17.17.3.1 Dominion

During the inspection, a records management supervisor stated that permanent records

submitted as "QA" were kept until and unless the Records Management Group was instructed

to discard them. The staff observed the records to be retrievable through reference to a file

number and vault location.

As discussed in Inspection Report 0520008/2003001, Dominion procedures include a lower-tier

operating procedure for records management. This procedure establishes methods,

responsibilities, and requirements for creation, collection, storage, maintenance, and disposition

of records generated during operations, maintenance, and support of Virginia Power's nuclear

power plants. It also describes personnel responsibilities for records management. The

procedure contains requirements for (1) quality and legibility of records, (2) storage and

maintenance of records, including the transmittal of completed records to Records

Management within 30 days, (3) correction of records, (4) preparation of records for archival

storage in a controlled environment, and (5) periodic media inspections to allow detection of

unexpected degradation of records.

Applicable Dominion procedures refer to the nuclear-required records lists (NRRLs) for

retention requirements. The staff reviewed a sample of these lists. For each record type, the

NRRL lists the controlling Dominion procedure, the retention period, the retaining organization,

and applicable regulations or other external documents (e.g., ANSI N45.2.9-1974).

Dominion procedures also contain requirements for records storage vaults and invoke

ANSI N45.2.9-1974, with exceptions as specified in the procedures. They contain specific

requirements for vaults and their contents. The staff conducted an inspection of the Innsbrook

Technical Center Vital Records Vault, and found it to have limited access, and to be climate

controlled and well ventilated. The vault appeared to be clean, and the staff noted no obvious

evidence of environmental problems. Based on a review of the document control process,

procedures, and storage vault, the staff found that the applicant's control of QA records meets

the guidance of Section 17.1.1 of RS-002.

17.17.3.2 Bechtel

The staff reviewed records retention requirements for the applicant's primary ESP contractor,

Bechtel. Bechtel's NQAM Policy No. Q-17.1 provides requirements for design and procurement

records retention and turnover. This document states that Bechtel will turn QA records over to

Dominion progressively as it completes tasks. The policy commits to ANSi N45.2.9-1974 and

ASME NQA-1-1 983, Supplement 17S-1, for maintenance and control of records. Once Bechtel

turns the records over to its client, the policy states that Bechtel is not required to keep the

copies it retains under controlled conditions, consistent with ANSI standards.

As discussed in Inspection Report 0520008/2003001, Policy No. Q-17.2 provides requirements

for supplier and subcontractor records. It states that procurement documents will specify

access for Bechtel and client staff to the end of the retention period, which is specified in the

17-38
Bechtel records retention requirements as the end of the contract plus 6 years. Requirements

include document types to be turned over, either at job completion or at the time of issue.

As is also discussed in Inspection Report 0520008/2003001, Bechtel's administrative

procedures set forth requirements for processing, controlling, distributing, and maintaining

supplier documents. They require that supplier documents received by Bechtel be controlled

through Bechtel's InfoWorks database. 'The staff found Bechtel's control of QA records

adequate for the scope of ESP activities conducted.

17.17.4 Conclusion (Quality Assurance Records)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they implemented an acceptable level of control for

quality assurance records. The staff considered the regulatory guidance of Section 17.1.1 of

RS-002 in their review of this portion of the application. The guidance in RS-002 helps to

provide reasonable assurance that information derived from ESP activities that could be used in

the design and/or construction of SSCs important to safety would support satisfactory

performance of such SSCs once in service.

17.18 Audits

17.18.1 Technical Information in the Application (Audits)

The applicant supplied information on audits in SSAR Section 17.1, which includes the QA

Manual. As discussed in Inspection Report 0520008/2003001, the manual states that the

Dominion QA procedures contain the standards, requirements, or guides which form the basis

of the procedures implementing this section.

The QA Manual states that administrative procedures describe the requirements for audits,

which are performed on a formal, preplanned audit schedule. Under these procedures, theapplicant periodically reviews and revises the audit system as necessary to ensure-coverage

commensurate with current and planned activities. The applicant may perform additional audits

as deemed necessary by management. The quality status and safety importance of the

activities being performed determines the scope of the audit. Trained personnel who do not

have direct responsibilities in the area being audited conduct the-investigation in accordance

with preplanned and approved audit plans or checklists.

The Nuclear Oversight Group conducts periodic internal and external audits. It conducts

internal audits to determine the adequacy of programs and procedures and whether they are

meaningful and in compliance'with the overall QA program. External audits determine the

adequacy of vendor and contractor Appendix B programs. Audits must be performed in those

areas where the requirements of Appendix B are being implemented. -

The QA Manual states that the applicant's management responds to all audits and initiates

corrective action when indicated. The applicant documents followup of applicable areas

through inspections, review, reaudits, or other appropriate means to verify implerrientation of

assigned corrective action.

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I It:

17.18.2 Regulatory Evaluation (Audits)

While the NRC does not require an ESP applicant to control audits in accordance with the

criteria of Appendix B to;10 CFR Part 50, Section 17.1.1 of RS-002 contains guidance for the

staff to use in evaluating an ESP applicant's control of audits. RS-002, paragraph 17.1.1.18,

provides the QA measures that constitute an acceptable level of audit control. Acceptable

audits should include (1) provisions for audits to verify compliance with all aspects of QA

measures and to determine the effectiveness of these measures, and (2) responsibilities and

procedures for conducting, documenting, and reviewing the results of audits (including

designating management levels to review and assess audit results).

17.18.3 Technical Evaluation (Audits)

The staff reviewed all audits and the requisite audit reports that cover Dominion's ESP

activities. Inspection Report 05200008/2003001 contains details of this review.

17.18.3.1 Dominion

The QA Manual delineates the QA plan for the development and conduct of audits for ESP

activities. The applicant performed internal audits of selected aspects of the ESP activities with

a frequency commensurate with safety significance. Nuclear oversight personnel conducted

periodic internal and external audits on a formal, preplanned audit schedule.

Nuclear oversight personnel conducted internal audits to determine the adequacy of programs

and procedures to ensure compliance with the overall QA program. Audits were scheduled

and conducted using existing operational procedures. As discussed in Inspection

Report 0520008/2003001, the staff reviewed the Dominion internal auditing procedures and

found them to be adequate.

Dominion's Nuclear Oversight Group also conducted external audits to determine the adequacy

of the contractors' QA programs. Areas reviewed included, but were not limited to, activities

associated with the preparation, review, approval, and control of design and design changes;

procurement documents; instructions, procedures, and drawings; and indoctrination and

training programs. Nuclear oversight personnel reported the results of each audit in writing to

the Project Manager, the Vice President for Nuclear Support Services, the Senior Vice

President for Nuclear Operations, and the Chief Nuclear Officer. Where corrective action

measures were indicated, the Nuclear Oversight Group conducted documented followup to

verify implementation of the assigned corrective action.

As discussed in Inspection Report 0520008/2003001, the staff interviewed Dominion QA

personnel who conducted audits of ESP activities and reviewed personnel training and

qualification records. In addition to routine individual and continuous training, personnel

performing ESP specific activities received training. The staff reviewed the compliance of

Dominion personnel with applicable procedural guidance and requirements for training and

qualification, and verified the adequacy of the procedure. In addition, the staff reviewed training

records and personnel qualifications. The staff did not note any deficiencies.

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17.18.3.2 Bechtel

The applicant listed Bechtel on the Dominion safety-related vendor list as a supplier qualified to

provide design and engineering services for major projects, including the ESP project. As.

discussed in Inspection Report 0520008/2003001, the applicant based its designation of

Bechtel as a qualified supplier,-in part, on two supplier audits that it had conducted within the

year preceding submission of the ESP application.: Specifically, the joint Nuclear Utility

Procurement Issues Committee (NUPIC) conducted an audit during November 2002, and

Dominion conducted a vendor programs audit during July 2003. The NUPIC audit verified

continued satisfacto'r implementation of the Bechtel Nuclear Quality Program in meeting the

intent of Appendix B to 10 CFR Parts 50 and 21. :

As is also discussed in Inspection Report 0520008/2003001, the staff reviewed Bechtel's audit

planning. The staff found that documents specifying audit plans -were sufficient in detail to meet

Bechtel's procedure requirements and that Bechtel performed audits as scheduled.

The staff reviewed Bechtel procedures for audits and found that Bechtel met procedural

requirements for auditing design and construction phase project activities at least annually or

once within the life of the project, whichever is shorter. Applicable procedures included

requirements for auditor qualifications, audit implementation guidance, audit report

documentation, and audit followup and closeout guidance. The staff found that these

procedures had been met.

The staff reviewed Bechtel procedures for qualification of auditors and found that the auditor

qualification requirements are equivalent in substance to the criteria of Appendix B to 10 CFR

Part 50 and consensus standards. The procedures detail topics such as training audit"

participation, examination, and maintenance of auditor qualifications.

Based on a review of the NUPIC, Dominion, and primary contractor audits, the staff found that

ESP audit activities were of sufficient scope and depth to provide reasonable assurance of the

applicant and contractors' qualifications to perform safety-related work. In particular, the staff

noted that audit activities included a review of significant quality attributes, such as design and

software.control, procurement activities, training, record retention, and corrective action. The

staff determined that deficiencies identified during these audit activities were adequately

resolved.

17.18.4. Conclusion (Audits)

As set forth above, the staff reviewed the QA measures employed by the applicant and its

primary contractor and concludes that they implemented acceptable audit controls. The staff

considered the regulatory guidance of Section 17.1.1 of RS-002 in their review of this portion of

the application. The guidance in RS-002 help to provide reasonable assurance that information

derived from ESP activities that could be used in the design and/or construction of SSCs

important to safety would support satisfactory performance of such SSCs once in service.

17-41
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17.19 Conclusions

Based on its review and evaluation of the QA measures contained or referenced in the SSAR,

as set forth above, the staff concludes the following:

* The organizations and persons performing QA functions have the independence and

authority necessary to effectively carry out QA measures without undue influence from'

those directly responsible for costs and schedules.

* The QA procedures and measures, when properly implemented, are equivalent in

substance to the criteria of Appendix B to 10 CFR Part 50 and conform to the guidance

in RS-002, Section 17.1.1.

* The applicant applied QA measures to all ESP activities that established information..

regarding (1) the design and construction of SSCs important to safety which might be:

constructed on the proposed site, or (2) the establishment of site characteristics for

comparison to the values of site parameters postulated in a certified design or to serve

as design inputs for a custom design. The measures provide adequate confidence that

information provided in the ESP application and accepted by the NRC is reliable and,.

when used as input for the design or construction of SSCs important to safety, would not

adversely impact their ability to perform satisfactorily in service. Therefore, the staff

concludes that the applicant implement acceptable QA measures fore the ESP

activities.

17-42
18. REVIEW BY THE ADVISORY COMMITTEE ON REACTOR

SAFEGUARDS

The Advisory Committee on Reactor Safeguards (ACRS) completed its review of the

application from Dominion Nuclear North Anna, LLC, for an early site permit (ESP) for the

North Anna ESP site and the U.S. Nuclear Regulatory Commission (NRC) staff's safety

evaluation report (SER) for this application. The ACRS ESP subcommittee began its detailed

review of the North Anna ESP application and the staff's draft safety evaluation report (DSER)

in December 2004. The ACRS ESP subcommittee met with representatives from Dominion

and the staff on March 2, 2005. The ACRS held its full committee meeting on the North Anna

ESP DSER on March 3, 2005. The discussions during these meetings focused on the open

items from the DSER. On the basis of its review, the ACRS issued an interim letter report,

dated March 11, 2005, which addresses the portions of the North Anna ESP application that

concern safety. The staff responded to the interim letter report in its letter dated June 3, 2005

(ADAMS Accession No. ML051260009). This report captures the actions that the staff has

taken in response to the comments and recommendations identified by the ACRS in its interim

report of March 11, 2005, as described in the staff's response letter of June 3, 2005. The staff

issued its FSER after the resolution of open items discussed in the DSER and after receipt of

the ACRS interim letter report to the Commission related to its review.

During its meeting with the ACRS on July 6, 2005, the staff discussed the resolution of open

items and the responses to ACRS comments on.the major elements of the ESP review. At the

524t meeting of the ACRS, the full Committee considered the staff's FSER, as well as

Dominion's North Anna ESP application, and issued its final letter report to the NRC Chairman

on July 18, 2005. That letter report is included as Appendix E to this report.

In its final letter report dated July 18, 2005, the ACRS concurred with the NRC staff's

conclusions concerning Dominion's ESP application and concluded that the proposed site,

subject to the permit conditions recommended by the staff, can be used for up to two nuclear

power units each of up to 4300 MW thermal without undue risk to public health and safety.

18-1
19. CONCLUSIONS

In accordance with Subpart A, "Early Site Permits," of Title 10, Part 52, "Early Site Permits,

Standard Design Certifications, and Combined Licenses for Nuclear Power Plants," of the Code

of Federal Regulations (10 CFR Part 52), the staff of the U.S. Nuclear Regulatory Commission

reviewed the site safety analysis report and emergency planning information included in the

early site permit (ESP) application submitted by Dominion Nuclear North Anna, LLC, for the

North Anna ESP site. On the basis of its evaluation and independent analyses as discussed in

this safety evaluation report (SER), the staff concludes that the North Anna ESP site

characteristics comply with the requirements of 10 CFR Part 100, "Reactor Site Criteria," with

the limitations and conditions proposed by the staff in this SER for inclusion in any ESP that

might be issued. Further, for the reasons set forth in this SER, the staff concludes that, taking

into consideration the site criteria contained in 10 CFR Part 100, a reactor, or reactors, having

characteristics that fall within the parameters for the site, and which meets the terms and

conditions proposed by the staff in this SER, can be constructed and operated without undue

risk to the health and safety of the public. For the same reasons, the staff also concludes that

issuance of the requested ESP will not be inimical to the common defense and security or to

the health and safety of the public. If issued, the North Anna ESP may be referenced in an

application to construct or to construct and operate a nuclear power reactor, or reactors, with a

total generating capacity of up to 8600 megawatts (thermal) at the ESP site, subject to the

terms and conditions of the permit.

19-1
- -

Appendix A

Permit Conditions, COL Action Items, Site Characteristics, and

Bounding Parameters

A.1 Permit Conditions Table .. ................... A-2

Definition .. A-2

Section 2.1 - Introduction .. A-2

Section 2.4 - Hydrology .. A-2

Section 2.5 - Geology, Seismology, and Geotechnical Engineering . .A-3

A.2 COL Action Items Table ..................... A-4

Definition. ................................................................ A-4

Section 2.1 - Introduction ............................. A-4

Section 2.2 - Nearby Industrial, Transportation, and Military Facilities . ............ A-4

Section 2.3 - Meteorology .. A-5

Section 2.4 - Hydrology .. A-5

Section 2.5 - Geology, Seismology, and Geotechnical Engineering . .A-7

Section 11.1 - Radiological Effluent Release Dose Consequences from Normal Operations A-8

Section 13.6 - Industrial Security .A-8

A.3 Site Characteristics Table .......................... A-9

Definition ................. A-9

Section 2.1 - Introduction ..................-. I ' A-9

Section 2.3 - Meteorology ................. A-1 0

Section 2.4 - Hydrology ........................ A-17

Section 2.5- Geology, Seismology, and Geotechnical Engineering ................... A-19

A.4 Bounding Parameters Table -.............................. . .. A-20

Definition ...... A-20

Section 2.4 - Hydrology .............. ;' . A-20

Figure 1 The proposed facility boundary for the ESP site .A-21

Figure 2 Selected Horizontal and Vertical Response Spectra for the Hypothetical Rock

Outcrop Control Point SSE at the Top of Zone IIl-IV Material .A-22

- A-1i
- t

A.1 Permit Conditions

Permit Condition: The Commission's regulation in 10 CFR § 52.24 authorizes the inclusion of limitations and conditions in an ESP. A permit condition is not needed when an existing NRC regulation requires a future regulatory review of a matter to ensure adequate safety during design, construction, or inspection activities for a new plant. The staff is proposing that the Commission include eight permit conditions, which are set forth below, to control various safety matters.

Permit

Condition SER

No. Section Description

2.1 - Introduction

1 2.1.2 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this application to govern exclusion area control. This permit condition would require that approvals called for by State law for, among other matters, agreements providing for shared control of the North Anna ESP exclusion area, be obtained and the agreements executed before construction of a nuclear power plant begins under a construction permit or COL referencing the ESP.

2 2.1.2 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this application requiring that the ESP holder obtain the right to implement the site redress plan before initiating any activities

authorized by 10 CFR 52.25.

2.4 - Hydrology

The NRC staff proposes to include a condition in any ESP that might be issued in connection with this application requiring that an applicant referencing such an ESP in an application for a fourth proposed unit use a dry cooling tower system during normal operation.

A-2

-- M
Permit

Condition SER

No. Section Description

4 2.4.13 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this application

requiring that an applicant referencing such an ESP design any new unit's radwaste systems with features to

preclude any and all accidental releases of radionuclides into any potential liquid pathway.

2.5 - Geology, Seismology, and Geotechnical Engineering

5 2.5.1 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this application

requiring that the ESP holder and/or an applicant referencing such an ESP replace weathered or fractured rock at -

the foundation level with lean concrete before initiation of foundation construction.

6 2.5.1 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this application

prohibiting the ESP holder or an applicant referencing such an ESP from using an engineered fill with high

_ _ compressibility and low maximum density, such as saprolite.

7 2.5.4 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this application

requiring that the ESP holder and/or an applicant referencing such an ESP perform geologic mapping of future

excavations for safety-related structures, evaluate any unforseen geologic features that are encountered, and

notify the NRC no later than 30 days before any excavations for safety-related structures are open for NRC's

examination and evaluation.

8 2.5.4 The NRC staff proposes to include a condition in any ESP that might be issued in connection with this application

requiring that the ESP holder and/or an applicant referencing such an ESP improve Zone II saprolitic soils to

reduce any liquefaction potential if safety-related structures are to be founded on them.

A-3
A.2 COL Action Items

COL Action Items: The combined license (COL) action items set forth in the SER and incorporated herein identify certain matters

that shall be addressed in the final safety analysis report (FSAR) by an applicant who submits an application referencing the North

Anna ESP. These items constitute information requirements but do not form the only acceptable set of information in the FSAR. An

applicant may depart from or omit these items, provided that the departure or omission is identified and justified in the FSAR. In

addition, these items do not relieve an applicant from any requirement in 10 CFR Parts 50 and 52 that govern the application. After

issuance of a construction permit (CP) or COL, these items are not controlled by NRC requirements unless such items are restated

in the preliminary safety analysis report or FSAR, respectively.

The staff identified the following COL action items with respect to individual site characteristics in order to ensure that particular

significant issues are tracked and considered during the review of a later application referencing any ESP that might be issued for

the North Anna ESP site.

Action *SER [ .

Item No. Section Subject To Be Addressed Reason for Deferral

2.1 - Introduction

2.1-1 2.1.1 A COL or CP applicant should provide latitude, longitude, and Universal Exact unit locations not known at ESP

Transverse Mercator coordinates for new units. stage.

2.1-2 2.1.2 A COL or CP applicant should make arrangements with the appropriate Such arrangements not required at

local, State, Federal, or other public agencies to provide for control of the ESP stage. ._ portions of Lake Anna and the WHTF that are within the exclusion area.

2.2 - Nearby Industrial, Transportation, and Military Facilities

2.2-1 2.2.2 A COL or CP applicant should perform an evaluation of industrial hazards, No hazard present, but zoning could

if any, associated with this site. allow them during ESP term.

2.2-2 2.2.3 A COL or CP applicant should assess design-specific interactions New unit design and specific location

between the existing and new units and, if necessary, propose measures not known at ESP stage

to account for such interactions..

A-4
Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

2.3 - Meteorology

2.3-1 2.3.2 A COL or CP applicant should, as part of detailed engineering, assess the Cooling tower location and design not

potential impact of the dry cooling towers on the design and operation of known at ESP stage

the new facility.

2.3-2 2.3.4 A COL or CP applicant should assess dispersion of airborne radioactive Control room location and design not

materials to the control room. known at ESP stage.

2.3-3 2.3.5' A COL or CP application should verify specific release point Exact release points and receptor

Icharacteristics and specific locations of receptors of interest used to locations not known at ESP stage.

'generate the long-term (routine release) atmospheric dispersion site

characteristics.

2.4 - Hydrology __'

2.4-1 12.4.1 A-COL or CP'application should provide the NRC for review the layout of The feasibility of the use of the existing intake and discharge tunnels and the construction techniques to be used discharge tunnel from the abandoned

before commencement of construction activities., units is not known at the ESP stage.

2.4-2 2.4.1 A COL or CP applicant should develop a plant shutdown protocol for Future uses and therefore low-level

proposed Unit 3 when water surface elevation in Lake Anna falls to 242 ft frequency not known at ESP stage. MSL Water surface elevation of 73.8 m

(242 ft) MSL is the applicant-proposed

shutdown level for the new Utnits. -

2.4-3 2.4.1 A COL or CP applicant should show that the combined cooling water flow Maximum additional water available for

rate for the new units does not exceed 2540 cfs. use by the'new units is limited by the

water budget calculation.

2.4-4 2.4.2 A COL or CP applicant should show that the ESP site is graded such that Detailed design of the plants, Including

any flooding caused by local intense precipitation will be discharged to the site grade are beyond the scope of

Lake Anna even in the event that any and all active drainage systems may an ESP review.

be blocked and unable to function

..

A-5
Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

2.4-5 2.4.2 A COL or CP applicant should show that all safety-related structures are Certain locations within the ESP site

located at elevations above the maximum water surface elevation area can be at the flood elevation of the

produced by local intense precipitation, or that adequate flood protection site in response to local intense

measures are in place to ensure their safety. precipitation. It Is not feasible to

determine flooding protection needs at

the ESP stage in response to local

intense precipitation because final site

grade and drainage patterns are not yet

known.

2.4-6 2.4.4 A COL or CP applicant should demonstrate that the UHS reservoirs are Detailed engineering design of

designed so as to satisfy the NRC's regulations. underground UHS reservoirs, should

they be needed, to preclude uplift due

to buoyancy is not within the scope of

ESP review.

2.4-7 2.4.4 A COL or CP applicant should demonstrate that the UHS storage basins Detailed engineering design of

provide storage sufficient to meet 30-day emergency cooling water needs underground UHS reservoirs, should

accounting for any and all losses including but not limited to seepage, they be needed, to ensure adequate evaporation, and icing for the selected plants, if the selected plant designs capacity is not within the scope of ESP

includes a UHS. Programmatic provisions should be provided for plant review.

shutdown when the liquid water volume in the UHS storage basin is

inadequate.

2.4-8 2.4.8 A COL or CP applicant should address whether Lake Anna or the WHTF The ESP water budget analysis relies

will be used for safety-related water withdrawals. on independent UHS reservoirs only,

but need for a UHS is not known at the

ESP stage.

2.4-9 2.4.10 A COL or CP applicant should adequately address the issue of slope Safety of intake structure from slope

embankment protection during design of the intake structure. embankment failure is a part of intake

structure design, which is beyond the

scope of an ESP review.

A-6

Z__ *W*FFPA*PPPPW" !9
Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

2.4-10 2.4.11 A COL or CP applicant should identify the most restrictive cooling water Technical specifications for safe needs to account for the frequency of low-flow conditions and related shutdown of the plant due to low water minimum water elevation In Lake Anna and propose corresponding conditions are based on consideration . actions. - of the details of the design of the

normal cooling water heat sink that are

not available at the ESP stage.

2.5 - Geology, Seismology, and Geotechnical Information

2.5-1 2.5.1 A COL or CP applicant should perform additional borings to identify any Exact unit locations not known at ESP weathered or fractured rock beneath the new foundations. stage.

2.5-2 2.5.4 A COL or CP applicant should submit plot plans and the profiles of all' Exact unit locations and design not seismic Category I facilities for comparison with the subsurface profile'and known at ESP stage. . material properties-. -

2.5-3. 2.5.4- -An ESP holder and/or a COL or CP applicant should submit excavation -- - Exact unit locations and design not and backfill plans'for NRC review. known at ESP stage.

2.5-4 2.5.4 A COL or CP applicant should assess groundwater conditions as they Exact unit locations and design not affect foundation stability or detailed dewatering plans. known at ESP stage.

2.5-5 2.5.4 A COL or CP applicant should perform additional soil column amplification Exact unit locations not known at ESP /attenuation analyses. , - stage.

2.5-6 2.5.4 .A COL or CP applicant should provide analysis of the stability of all Exact unit locations and design not planned safety-related facilities, Including bearing capacity, rebound, known at ESP stage. settlement, and differential settlements under deadloads of fills and plant ,_______ facilities, as well as lateral loading conditions.

2.5-7 2.5.4 A COL or CP applicant should provide design-related criteria pertinent to Exact unit locations and design not structural design. known at ESP stage.

.......

.. . . - *

A-7
Action SER

Item No. Section Subject To Be Addressed Reason for Deferral

2.5-8 2.5.4 A COL or CP applicant should provide specific plans for each proposed Exact unit locations and design not

ground improvements technique it plans to employ so that the staff may known at ESP stage.

determine whether the chosen techniques will ensure that Zone IIA

saprolitic soils will be able to support safety-related foundations.

2.5-9 2.5-4 A COL or CP applicant should determine the average shear-wave velocity Site average shear-wave velocity of the

of the material underlying the foundation for the reactor containment and Zone III-IV bedrock slightly less than

verity that it is equal to or exceeds that of the chosen design. design value provided at ESP stage.

2.5-10 2.5.5 A COL or CP applicant should conduct a more detailed dynamic analysis Locations of safety-related structures

of the stability of the existing slope and any new slopes using the safe- relative to the existing or new slopes

shutdown earthquake (SSE) ground motion. not known at ESP stage.

2.5-11 2.5.5 A COL or CP applicant should provide plot plans and cross Locations of safety-related structures

sections/profiles of all safety-related slopes, and specify the measures relative to the existing or new slopes

that it will take to ensure the safety of slopes and any structures located not known at ESP stage.

adjacent to the slopes.

11.1 - Radiological Effluent Release Dose Consequences from Normal Operations

11.1-1 11.1.4 A COL or CP applicant should verify that the calculated radiological doses Specific details of how the new facility

to members of the public from radioactive gaseous and liquid effluents for will control, monitor, and maintain

any facility to be built on the North Anna site are bounded by the radioactive gaseous and liquid effluents

radiological doses included in the ESP application and reviewed by the not known at ESP stage.

NRC.

13.6 - Industrial Security

13.6-1 13.6 1 ACOL or CP applicant should provide specific designs for protected area Exact locations and design of barriers

| | barriers. | not known at ESP stage.

A-8
A.3 Site Characteristics

Site Characteristics: Based on site investigation, exploration, analysis and testing, the applicant initially proposes a set of site

characteristics. These site characteristics are specific physical attributes of the site, whether natural or man-made. Site

characteristics, if reviewed and approved by the staff, are specified in the ESP. The staff proposes to include the following site

characteristics in any ESP that might be issued for the North Anna site.

Site Characteristic| Value Definition

2.1 - Introduction

Exclusion Area Boundary The perimeter of a 5000 ft radius The area surrounding the reactor, in

circle from the center of the which the reactor licensee has the

abandoned Unit 3 containment authority to determine all activities

including exclusion or removal of

personnel and property from the area

Low Population Zone 6 mile radius circle centered at the The area immediately surrounding the

Unit 1 containment building exclusion area which contains

residents

Population Center Distance 8 miles The minimum allowable distance from

the reactor to the nearest boundary of

a densely populated center containing

more than about 25,000 residents

A-9
Site Characteristic Value Definition

2.3 - Meteorology

Ambient Air Temperature and Humidity________________

Maximum Dry-Bulb 2% annual exceedance 90 OF with 75 OF concurrent wet- The ambient dry-bulb temperature

Temperature bulb (and coincident wet-bulb temperature)

that will be exceeded 2% of the time

____ ____ ____ ___ ____ ____ ___ annually

0.4% annual 95 OF with 77 OF concurrent wet- The ambient dry-bulb. temperature

exceedance bulb (and coincident wet-bulb temperature)

that will be exceeded 0.4% of the time

annually

1 00-year return period 109*F The ampbient dry-bulb temperature that

has a 11% annual probability of being

exceeded (100-year mean recurrence ____ ____ ____ ____ ____interval)

Minimum Dry-Bulb 99% annual 18 OF The ambient dry-bulb temperature

Temperature exceedance below which dry-bulb temperatures will

____ ___ ____ ____ ___ ____ ___ fail 1% of the tim e annually

99.6% annual 14 F The ambient dry-bulb temperature

exceedance below which dry-bulb temperature will

____ ___ ____ ____ ___ ____ ___ fall 0.4% of the time annually

1 00-year return period -19 OF The ambient dry-bulb temperature for

which a 1 % annual probability of a

lower dry-bulb temperature exists

________________________(1100-year mean recurrence interval)

A-l0

. NO
Site Characteristic Value Definition

Maximum Wet-Bulb 0.4% annual 79 F The ambient wet-bulb temperature that Temperature exceedance will be exceeded 0.4% of the time

annually

100-year return period 88 F The ambient wet-bulb temperature that

has a 1% annual probability of being exceeded (1 00-year mean recurrence _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ in te rv a l)

Basic Wind Speed _

3-s Gust -- 96 mi/hr ~ The 3-s gust wind speed at 33 ft above

the ground that has a 1% annual

!__-_____-jprobability of being exceeded

(1 00-year mean recurrence interval)

Design-Basis Tornado

Maximum Wind Speed 260 mi/h Maximum wind speed resulting from

passage of a tornado having a

probability of occurrence of 10 7

per year

Translational Speed 52 mi/hr Translation component of the.

maximum tornado wind speed

Rotational Speed 208 mi/hr Rotation component of the maximum

tornado wind speed

Radius of Maximum Rotational Speed 150 ft Distance from the center of the

tornado at which the maximum

rotational wind speed occurs

A-11
Site Characteristic Value Definition

Maximum Pressure Drop 1.5 lbf/in2 Decrease in ambient pressure from

normal atmospheric pressure resulting

from passage of the tornado

Maximum Rate of Pressure Drop 0.76 Ibf/in2/s Rate of pressure drop resulting from

the passage of the tornado

Winter Precipitation

100-Year Snowpack 30.5 lbf/ft2 Weight of the 100-year return period

snowpack (to be used in determining

extreme winter precipitation loads for

roofs)

48-Hour Probable Maximum Winter Precipitation 20.75 in. of water Probable maximum precipitation during

the winter months (to be used in

conjunction with the 100-year

snowpack in determining extreme

winter precipitation loads for roofs)

Ultimate Heat Sink Ambient Air Temperature and Humidity

Meteorological Conditions Resulting in the 78.9 'F wet-bulb temperature with Historic worst 1 -day daily average of

Minimum Water Cooling During Any 1 Day coincident 87.7 OF dry-bulb wet-bulb temperatures and coincident

temperature dry-bulb temperatures

Meotorological Conditions Resulting in the 77.6 OF wet-bulb temperature with Historic worst 5-day daily average of

Minimum Water Cooling During Any Consecutive 5 coincident 80.9 F dry-bulb wet-bulb temperatures and coincident

days temperature dry-bulb temperatures resulting in

minimum water cooling

Meteorological Conditions Resulting in the 76.3 OF wet-bulb temperature with Historic worst 30-day daily average of

Maximum Evaporation and Drift Loss During Any coincident 79.5 F dry-bulb wet-bulb temperatures and coincident

Consecutive 30 Days temperature dry-bulb temperatures

A-12

.. W
Site Characteristic Value Definition

Meteorological Conditions Resulting in the 322 *F degree-days below freezing Historic maximum cumulative degree- Maximum Water Freezing in the UHS Water days below freezing Storage Facility

Short-Term (Accident' Release) Atmospheric Dispersion

0-2 hr x/Q Value @ EAB 2.26 x 10'4 s/M3 The 0-2 hour atmospheric dispersion

factor to be used to estimate dose

consequences of accidental airbornereleases at the EAB

0-8 hr x/Q Value @ LPZ 2.05 x 10-5 s/M3 The 0-8 hour atmospheric dispersion

factor to be used to estimate dose

consequences of accidental airborne

: -releases at the LPZ

8- 24 hr x/Q Value @.LPZ ... . 1.36x105s/m3The 8-24 hour atmospheric dispersion

factor to be used to estimate dose

consequences of accidental airborne

r6leases at the LPZ

1-4 day x/Q Value @ LPZ 5.58 x 10- s/rM3 The 1-4 day atmospheric dispersion

factor to be used to estimate dose

consequences of accidental airborne

releases at the LPZ

4-30 day X/Q Value @ LPZ 1.55 x 10-6 s/M3 The 4-30 day atmospheric dispersion

factor to be used to estimate dose

consequences of accidental airborne

releases at the LPZ

Long-Term (Routine Release) Atmospheric Dispersion

A-13
Site Characteristic Value Definition

Annual Average Undepleted/No Decay X/Q Value 3.7 x 10.6 s/M3 The maximum annual average EAB

@ EAB undepleted/no decay X/Q value for use

in determining gaseous pathway doses

to the maximally exposed individual

Annual Average Undepleted/2.26 Day Decay X/Q 3.7 x 106 s/rM3 The maximum annual average EAB Value @ EAB undepletedl2.26 day decay x/Q value

for use in determining gaseous

pathway doses to the maximally

exposed individual

Annual Average 3.3 x 10- s/rM3 The maximum annual average EAB Depleted/8.00 Day Decay x/Q Value @ EAB depleted/8.00 day decay X/Q value for

use in determining gaseous pathway doses to the maximally exposed

individual

Annual Average 1.2 x 10.8 1/M2 The maximum annual average EAB D/Q Value @ EAB D/Q value for use in determining

gaseous pathway doses to the

maximally exposed individual

Annual Average 2.4 x 10.8 s/r3 The maximum annual average resident Undepleted/No Decay X/Q Value @ Nearest undepleted/no decay XIQ value for use Resident in determining gaseous pathway doses

to the maximally exposed individual

Annual Average Undepleted/2.26 Day Decay X/Q 2.4 x 10.6 s/rM3 The maximum annual average resident Value @ Nearest Resident undepleted/2.26 day decay x/Q value

for use in determining gaseous

pathway doses to the maximally _ _ _ __ _ __ exposed individual

A-14

O"
Site Characteristic Value Definition

Annual Average Depleted/8.00 Day Decay 2.1 x 106 s/rn 3 The maximum annual average resident

x/Q Value © Nearest depleted/8.00 day decay x/Q value for

Resident use in determining gaseous pathway

doses to the maximally exposed

individual

Annual Average 7.2 x 10` -1/M 2 The maximum annual average resident

D/Q Value @ Nearest D/Q value for use In determining

Resident gaseous pathway doses to the

maximally exposed individual

Annual Average 1.4 x o1 s/iM3 The maximum annual average meat

Undepleted/No Decay animal undepleted/no decay XIQ value

x/Q Value @, Nearest Meat for use in determining gaseous Animal pathway doses to the maximally

__ __ __ .;__._ __ __ __ __ __ __ __ __ _.exposed individual

Annual Average Undepleted/2.26 Day Decay 1.4 x 10 6 s/M3 The maximum annual average meat

X/Q Value © Nearest Meat Animal animal undepleted/2.26 day decay x/Q

value for use in determining gaseous

pathway doses to the maximally .. _ exposed individual

Annual Average 1.2 x 10-6 s/M3 The maximum annual average meat

Depleted/8.00 Day Decay animal depleted/8.00 day decay X/Q

X/Q Value @ NearestMeat Animal value for use in determining gaseous

pathway doses to the maximally

exposed individual

A-15
Site Characteristic Value Definition

Annual Average 3.1 x 109 1/rM2 The maximum annual average meat

D/Q Value @ Nearest Meat Animal animal D/Q value for use in

determining gaseous pathway doses to

the maximally exposed individual

Annual Average 2.0 x 104 s/M3 The maximum annual average

Undepleted/No Decay X/Q Value @ Nearest Veg. vegetable garden undepleted/no decay

Garden X/Q value for use in determining

gaseous pathway doses to the

maximally exposed individual

Annual Average 2.0 x 1O-6 s/M3 The maximum annual average

Undepleted/2.26 Day Decay X/Q Value @ Nearest vegetable garden undepletedl2.26 day

Veg. Garden decay x/Q value for use in determining

gaseous pathway doses to the

maximally exposed individual

Annual Average 1.8 x 10-6 s/M3 The maximum annual average Depleted/8.00 Day Decay vegetable garden depleted/8.00 day

X/Q Value @ Nearest Veg. Garden decay X/Q value for use in determining

gaseous pathway doses to the

maximally exposed individual

Annual Average D/Q Value @ Nearest Veg. 6.0 x 1i09 1/M2 The maximum annual average Garden vegetable garden D/Q value for use in

determining gaseous pathway doses to

the maximally exposed individual

A-16
Site Characteristic 'Value Definition

2.4 - Hydrology

Hydrology

Proposed Facility Boundaries Appendix A, Figure 1 (FSER ESP site boundary map

Figure 2.4.14-1) shows the

proposed facility boundary using

its corners numbered 1-8 and also

lists the geographical coordinates

of these points in Virginia State

Plane Coordinate System using

NAD 83 Datum. The coordinates

are expressed in feet.

Minimum Lake Water Level 242ft MSL Low water surface shutdown elevation

for operation of NAPS Units 1 and 2,

and of proposed Unit 3

Maximum Elevation of Ground Water 82.3 m (270ft) MSL or 1 ft below The maximum elevation of ground the free surface, whichever is water at the ESP site

higher

Flood Elevation : 82.3 m (270ft) MSL Maximum flood level at the ESP site

due to a PMF in Lake Anna'd^

watershed, simultaneous failure of

upstream storage reservoirs, and

coincident wind-wave action.

Local Intense Precipitation 46.61 cm(1 8.35in)/hour and 15.42 Maximum potential rainfall at the

cm (6.1 in) in 5 minutes immediate ESP site.

Frazil and Anchor Ice The ESP site has the potential for Accumulated ice formation in a

formation of frazil and anchor ice. turbulent flow condition.

I

... .. I..-

A-17
Site Characteristic Value Definition

Maximum Ice Thickness 43.4 cm (17.1 in) thick Ice sheet thickness at Lake Anna

(based on maximum cumulative

degree-days below freezing of 178.8

_C (321.8 OF))

Maximum Cumulative Degree-Days Below 178.8 °C (322 0F) A measure of severity of winter

Freezing weather conditions conducive to ice

formation (computed using air

temperature data from Piedmont

Research Station)

Hydraulic Conductivity 1.0 m/d (3.4 ft/d) Ground water flow rate per unit

.__ .hydraulic gradient.

Hydraulic Gradient 0.03 m/m (0.03 ft/ft) Slope of ground water surface under

unconfined conditions or slope of

hydraulic pressure head under

confined conditions.

A-18

-
Site Characteristic Value Definition

2.5 - Geology, Seismology, and Geotechnical Engineering

Basic Geologic and Seismic Information

Capable Tectonic Structures No fault displacement potential within

-__-;_--_:_---_-_-_._._..._._._the investigative area

Vibratory Ground Motion,

Design Response Spectra Appendix A, Figure 2 Site Specific response spectra

-__ t , .(FSER Figure 2.5.2-6)

Stability of Subsurface Materials and Foundations

Zone IlIl Weathered Rock Minimum Bearing 16 ksf Allowable load-bearing capacity of layer (205ft -298ft) Capacity supporting plant structures

Shear Wave Velocity Propagation of shear waves through

2000 ft/sec foundation materials

Zone III - IV .. Minimum Bearing 80 ksf .. Allowable load-bearing capacity of layer

Capacity supporting plant structures

Shear Wave Velocity 3300 ft/sec Propagation of shear waves through

.... . . ... ;....foundation materials -

Zone IV Bedrock Minimum Bearing . 160 ksf Allowable load-bearing capacity of layer

(1 88ft - 298ft) Capacity . supporting plant structures

. Shear Wave Velocity -.- 6300 ft/sec Propagation of shear waves through

.__.___._._.::_._-_._foundation materials

4 ~ . . . ..

I . ...

A-19
A.4 Bounding Parameters

Plant Parameter Envelope: A plant parameter envelope (PPE) sets forth postulated values of design parameters that provide design

details to support the NRC staff's review of an ESP application. A controlling PPE value, or bounding parameter value, is one that

necessarily depends on a site characteristic. As the PPE is intended to bound multiple reactor designs, the actual design selected in

a combined license (COL) or construction permit (CP) application referencing an ESP would be reviewed to ensure that the design

fits within the bounding parameter values. Otherwise, the COL or CP applicant would need to demonstrate that the design, given

the site characteristics in the ESP, complies with the Commission's regulations. Should an applicant reference an ESP for a design

that is not certified, the applicant would need to demonstrate that the design's characteristics fall within the bounding parameter

values.

Bounding Parameters | Value Definition

._ 2.4 - Hydrology

Maximum Cooling Water Flow Rate - Unit 3 2540 cfs Total cooling water flow rate through the

condenser (also the rate of withdrawal from

Lake Anna and return to the WHTF)

Maximum Cooling Water Temperature Rise 180F Temperature rise across the condenser

(temperature of water out minus the

temperature of water in) when the lake

level is g 244 MSL

Maximum Inlet Temperature 950F Maximum temperature of water incoming

into condenser when the lake level is • 244

MSL

Minimum Site Grade 82.6 (271 ft) MSL Finished site grade

A-20
I

Floo Narti I

( 2t86 " ;Notes:

1. North Anna Site

- f | § L-'b (South noted. Zone)co

'F ~ '-~' 1~' ~2. Abandoned Unit *Mat Foundationi

;I- ii3. ThieStle oundg _, 50 D5000-foot radius ~~ the novwubando

~ . . * .2Reference NAP.,

_ 7t 4. The distance fro ~ Exclusion Area I

_p 44O 911 t6Q4> \ MM0'. i

Coot4U O s(NAPS~g O 5NAD 83i Zt87 §.

PIM~N" P EIastES ol ~ef Eo V (Fwa) (F*Wl N _______s(R.

540000 732000 390090425 11654870241

"40oo 937B 00 391OF5723 116687115.58 1

474186 949226 391=68.34 1166713280

474186 853965 390737.79 11868748 23

4287.60 65365 309314 65 1166841259I

4287 00 74700 3908923 29 116 j.8s70

448800 7470.00 39011035 116393354 "

44000 73000 3909554 1160520304

-i. I , .

and State Plane NAD 83

Drdinates are shown as

3 and 4 Reactor Buflding

& are to be removed.

ary Is the Perrneter of a

idrcle from the center of

ned Unit 3 Containment.

' USFAR. Section 2.1.1.3.

m the ESP Envelope to the

3oundary is 2854.90 feet

panl

57-

-;57-

,57-

-;T-

<5--

<5--

1 O

 .1- " -

rVXMO VIWATICII FtAV 011TU mm 104 "I twacrt v POKI STU

t--%-4-r

Figure 1 (Figure 2.4.14-1) The proposed facility boundary for the ESP site

A-21
10 .1

- -u-Hojizontal Zone III-IV spectrum

A -- Vertical Zone III-IV spectrum l

C 1 . J 0.

I-w

w 0.1

5% Critical Damping

0.01 / ;.. ^~~i ,,

0.1 1 10 100

Frequency (Hz)

Figure 

Outcrop 

2 (Figure 

Control 

2.5.2-6 (SSAR Figure 2.5-48A)) Selected Horizontal and Vertical Response Spectra for the Hypothetical Rock Point SSE at the Top of Zone III-IV Material

A-22 P4

izo-am _1
APPENDIX B

CHRONOLOGY

This appendix contains a chronological listing of routine licensing correspondence between the

staff of the U.S. Nuclear Regulatory Commission (NRC) and Dominion Nuclear regarding the

review of the North-Anna early site permit application under Project No. 719 and Docket

No. 52-008.

Revisions to the North Anna Early Site Permit Application

Rev. Date Accession Number

0 September 25, 2003 ML032731517

1 October 2, 2003 ML032731517

2 July 15, 2004 ML042010010

3 September 7, 2004 ML042590082

4 May 12, 2005 ML051450310

5 July 31, 2005 ML052150226

Revision 0 and Revision 1 of the application are contained in the same ADAMS

package. Revision 1 of the application provides changes to Revision 0 to remove proprietary

information from the application.

B-1
Document Accession TitlelDescription Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

ML051520461 Revised Schedule for the North Anna Letter NRC/NRR/DRI Dominion 05200008

Early Site Permit Application Review P/RNRP Resources

Services, Inc

14 Page(s)

12/31/1998 ML041280589 12/31/98-North Anna Early Site Permit Graphics Dominion NRC/Docume 05200008 Application Response to RAI 2.3.3-1, incl Charts nt Control

Meteorological Data 1997, Pages 1 - 169. and Tables Desk

169 Page(s)

12/31/1998 ML041280588 12/31/98-North Anna Early Site Permit Graphics Dominion NRQ/Docume 05200008 Application Response to RAI 2.3.3-1, incl Charts nt Control

Meteorological Data 1996, Pages 1 - 157. and Tables Desk

157 Page(s)

12/31/1998 ML041280590 12/31/98-North Anna Early Site Permit Graphics Dominion NRC/Docume 05200008

Application Response to RAI 2.3.3-1, incl Charts nt Control

Meteorological Data 1998, Pages 1 - 169. and Tables Desk

169 Page(s)

03/31/2002 I ML041110822 03/31/02-Response to Request for

Additional Information RAI 13.3-2

consisting of redacted versions of

emergency plans.

14 Page(s)

Emergenc

y

Preparedn

essEmergenc

y Plan

Dominion

Nuclear North

Anna, LLC

NRC/Docume

nt Control

Desk

05200008

B-2

  .  -
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type -Affiliatlon(s) Affiliatlon(s) Number

09/16/2002 ML022740172 09/16/02-North Anna Early Site Permit Letter, Dominion NRC/NRR/N 05000338, Project Quality Assurance Plan. Quality Energy Co, RLPO 05000339,

Assurance Dominion PROJO719 35 Page(s) Program Generation

01/21/2003 ML030140458 01/21/03-Early Site Permit Project Letter NRC/NRR/NR Dominion 05000338, Manager Reassignment For North Anna. LPO Generation 05000339,

PROJ6719 5 Page(s) -

04/04/2003 ML030350519 04/04/03-Pre-Application Review of

Dominion North Anna Early Site Permit

Project Quality Assurance Plan.

15 Page(s)

Letter NRC/NRR/NR

LPO

Dominion

Generation

PROJO719

PROJO720

_- . I I

B-3
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

04/08/2003 ML030940235 04/08/03-April 1, 2003 - Meeting Summary Meeting NRC/NRR/NR Atomic PROJO71 9

Regarding Public Meetings on North Anna Summary LPO Energy of

ESP Review Process, Mineral, VA. Canada, Ltd,

Dominion

6 Page(s) Energy Co,

Dominion

Generation,

Dominion

Nuclear

Connecticut,

Inc, Enercon

Services, Inc,

Framatome

ANP, Inc,

Greenpeace,

Louisa

County, VA,

Nuclear

Control

Institute,

Nuclear

Energy

Institute

(NEI),

Nuclear

Information &

Resource

Service

(NIRS),

Public -

B-4

pq

. I I . .
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillatlon(s) Number

05/06/2003 ML030980003 05/06/03-Letter to J. Hegner providing Letter NRC/NRR/NR Dominion PROJO719 guidance on how security measures LPO Energy Co should be addressed in Dominion

Energy's application for 6arly site permit at

North Anna Site.

6 Page(s) ;

06/02/2003 ML031480470 06/02/03-Letter to J. Hegner, re: Letter NRC/NRR/NR Dominion PROJO719 "Alternative Energy Sources". LPO Energy Co

7 Page(s) . -_,_-

06/11/2003 ML042310215 06/11/03'- E-Mail - Draft North Anna ESP E-Mail Dominion NRC/NRR1D 05200008, Application Table of Contents. Nuclear North RIP/RNRP PROJO719

Anna, LLC

12 Page(s) _

07/03/2003 ML032160433 07/03/03-North Anna Early Site Permit Letter Dominion NRC/NRR/N PROJO719 Project Correspondence Distribution Resources, RLPO Request. Inc

2 Page(s)

07/09/2003 ML042310212 07/09/03 - E-Mail Response to NRC E-Mail Dominion NRC/NRR/D 05200008, Inquiry during recent North Anna ESP Site Generation RIP/RNRP PROJO719 Visit.

3 Page(s) -

B-5
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

08/08/2003 ML042310210 08/08/03 - E-Mail - Disposition of E-Mail Dominion NRC/NRR/D 05200008, Comments on Certain North Anna ESP Nuclear North RIP/RNRP PROJO719 Sections. Anna, LLC

3 Page(s)

08/08/2003 ML042050279 08/08/03-E-mail dated 8/8/03 regarding E-Mail Dominion NRC/NRR/D 05200008, Dominion Energy plans regarding Certain RIP/RNRP PROJO719 Sections of its ESP Application.

3 Page(s)

09/25/2003 ML042590086 09/25/03-North Anna Early Site Permit

Application.

Letter Dominion

Nuclear North

Anna, LLC

NRC/Docume

nt Control

Desk,

NRC/NRR

05200008,

PROJO71 9

22 Page(s)

09/25/03-Letter transmitting North Anna I.

09/25/2003 1 ML032731511 09/25/03-Letter transmitting North Anna

Early Site Permit Application, Revision 1.

5 Page(s)

Letter,

LicenseApplication

for

Constructi

on Permit

DKT 50

Dominion

Nuclear

Connecticut,

Inc

NRC/Docume

nt Control

Desk,

NRC/NRR

05000338,

05000339,

05200008,

PROJO71 9

I J

B-6
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

09/25/2003 ML042010015 09/25/03-Letters Accompanying North Letter, Dominion, NRC/Docume 05200008, Anna Early Site Permit Application. License- Dominion nt Control PROJO719

Application Nuclear North Desk, 13 Page(s) for Anna, LLC NRC/NRR

Constructi

on Permit ._ _ DKT 50

09/25/2003 ML051450315 Transmittal of Revision 4 to North Anna Letter, Dominion NRC/Docume 05200008, Early Site Permit Application. License- Nuclear North nt Control PROJO719

Application Anna, LLC Desk, 29 Page(s) for NRC/NRR

Constructi . aon Permit

DKT 50

09/30/2003 ML032731602 09/30/03-North Anna Early Site Permit Final Dominion NRC/Docume 05000338, Application, Revision 0, Site Safety Safety Nuclear nt Control 05000339, Analysis Report, Figures 2.5-46 through Analysis Connecticut, Desk, 05200008, 2.5-72. Report Inc NRC/NRR PROJ0719

l (FSAR), 27 Page(s) LicenseApplication

,. Afor

Constructi

on Permit _ _ DKT 50

I ' B-7
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/09/2003 ML032600005 10/09/03-Receipt of Application for Early Letter NRC/NRR/DRI Dominion PROJO719 Site Permit For the North Anna Site. P Energy Co

7 Page(s)

10/14/2003 ML032690007 10/14/03-Summary of Meeting Held on Meeting NRC/NRR/DRI Dominion 05000338, September 3, 2003, on Quality Assurance Summary P Energy Co 05000339, Inspections For The North Anna Early Site PROJO719 Permit Application.

9 Page(s)

10/22/2003 ML042310298 10/22/03 - E-Mail from Dominion Nuclear - E-Mail Dominion Bechtel Corp, 05200008 Govt. Official List - Adjusted. Generation Dominion

Generation, 5 Page(s) NRC

10/23/2003 ML032740017 10/23/03-Enclosure 1 - Staff's Schedule Template NRC/NRR/DRI Dominion 05000338, for Safety and Environmental Review for P Energy Co 05000339, North Anna ESP Application. 05200008

1 Page(s)

10/23/2003 1 ML032740025 10/23/03-Response Letter - Acceptance of

Dominion Nuclear North Anna, LLC

Application for an ESP For the North Anna

Site.

Letter NRC/NRR/DRI

P

Dominion

Energy Co

05000338,

05000339,

05200008

8 Page(s) I I I .1

B-8

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

11/03/2003 ML042310292 11/03/03 - E-Mail from Dominion Nuclear E-Mail Dominion NRC/NRR/D 05200008

re:ODEC Point of Contact. Generation RIP/RNRP

2 Page(s) *_;

11/03/2003: ML033530342 1 1/03/03-Letter to J. Dyer from E. Letter Dominion NRC/Docume 05200008

Grecheck re: North Anna ESP Application Nuclear North nt Control - Service of ESP Application and Notice of Anna, LLC Desk, Availability. NRC/NRR

1 Page(s)

11/05/2003 ML041190477! 11/05/03-E-Mail dated 11/05/03 E-Mail, Dominion NRC/NRR/D 05200008

Conveying MCVHNCU/Dominion, Emergenc Energy Co RIP

Radiation Emergency Plan. y -

Preparedn

50 Page(s) essEmnergenc

y Plan,

Memorand

a

11/05/2003, ML041190476 11/05/03-E-mail dated 11/05/03 E-Mail, Dominion NRC/NRR/D 05200008

Conveying North Anna Evacuation Time Evacuation Generation RIP

Estimate. Time

Estimate/R,

43 Page(s) eport

_ -__ (ETE)

: ,,, ,

B-9
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

11/06/2003 ML033421011 11/06/03-North Anna Early Site Permit Letter Dominion NRC/Docume 05200008 Project Correspondence Distribution Resources, nt Control

Request. Inc Desk

2 Page(s) . -

12/04/2003 ML042510389 12/04/03 - E-mail - Draft questions for N. E-Mail NRC Dominion 05200008 Anna'site audit. Nuclear North

Anna, LLC

2 Page(s) ''_''

12/17/2003 ML042440887 12/17/03 email from T. Banks forwarding E-Mail, Dominion NRC 05200008

Dominion procedures for controlling brush Letter Nuclear North

along transmission line rights-of-way. Anna, LLC

2 Page(s) _

12/17/2003 ML033580291 12/17/03-North Anna Early Site Permit Letter, Dominion NRC/Docume 05200008

Application Reference Information. Report, Nuclear North nt Control

Technical Anna, LLC Desk 118 Page(s) ;

01/12/2004 ML040230690 01/12/04-Federal Consistency Certification Letter Dominion NRC/Docume 05200008

Under Coastal Zone Management Act, Nuclear North nt Control

Virginia Coastal Resources Management Anna, LLC Desk,' State

Program, North Anna Early Site Permit of VA,'Dept of

Application. Environmenta

I Quality 1 Page(s)

B-10 --

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

01/12/2004 ML040150170 01/12/04-Dominion Nuclear North Anna Inspection NRC/RGN- Dominion 05200008

inspection of applicant and contractor Report, II/DRS/EB Resources, quality assurance activities involved with Letter Inc

preparation of application for an early site

permit.

53 Page(s)

01/13/2004 ML040140614 01/13/04- December 8, 2003- Summary of Meeting. NRC/NRR/DRI Dominion 05200008

Public Scoping Meeting with Dominion Summary P/RLEP Nuclear North

Nuclear to Support Review of the North Anna, LLC

Anna Early Site Permit Application.

. . .____ 7 Page(s) ' , ,', ' " ' ' ,,..

01/13/2004 ML041190479- E-mails Conveying Draft Requests For E-Mail NRC/NRR/DRI Dominion 05200008

Additional Information (Packages 1-4) to P Energy Co

Dominion Regarding North Anna ESP

Application.

33 Page(s)

01/13/2004 ML042310179 01/13/04 - E-Mail from Michael Scott re: E-Mail, NRC/NRR/DRI Dominion 05200008

Draft Requests For Additional Information Request P/RNRP Generation

for North Anna ESP Review. for

Additional

7 Page(s) Information

____ (RAI) _

,.I

B-11
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

01/30/2004 ML042510373 01/30/04 - E-mail - Docketing of E-Mail NRC Dominion 05200008 Documents. Nuclear North

Anna, LLC 4 Page(s)

02/02/2004 ML042310175 02/02/04 - E-Mail from Michael Scott re: E-Mail NRC/NRR/DRI Dominion 05200008 Preliminary Questions - Package #2. P/RNRP Generation

4 Page(s)

02/13/2004 ML042440017 02/13/04- E-mail from T. Banks regarding E-Mail, Dominion NRC 05200008 possible bald eagle nests on Contrary Letter Nuclear North

Creek near the North Anna ESP site. Anna, LLC

1 Page(s) _ _ _ _ _ _ _ _ _ _ _

02/26/2004 ML040570166 02/26/04-Enclosure - Revised Review Letter, NRC/NRR/DRI Dominion 05200008 Schedule for Dominion ESP Application. Schedule P/RNRP Resources,

and Inc . 1 Page(s) Calendars

02/26/2004 ML042310167 02/26/04- E-Mail from Michael Scott re: E-Mail NRC/NRR/DRI Dominion 05200008 Preliminary Questions - Package #3. P/RLEP Generation

7 Page(s)

02/26/2004 ML040570185 02/26/04-Revised Date For Transmitting Letter NRC/NRR/DRI Dominion 05200008 Environmental Requests For Additional P/RNRP Resources, Information. Inc

5 Page(s)

B-12

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

03/08/2004 ML040300452 03/08/04-Request for Additional Letter, NRC/NRR/DRI Dominion 05200008 Information Letter No. 1 - Dominion Request P Resources, Nuclear North Anna, LLC ESP Application for Inc for the North Anna ESP Site (MC1 127) Additional

Information

12 Page(s) (RAI)

03/12/2004 ML040720580 03/12/04-Request for Additional Letter,. NRC/NRR/DRI Dominion 05200008 Information (RAI) Regarding Request P/RLEP Resources, Environmental Portion of Early Site Permit for Inc (ESP) Application for North Anna Site Additional

(TAC No. MC1 128). Information

a (RAI) l16 Page(s) -

03/17/2004' ML042320168 :03/17/04- E-Mail from Joseph Hegner of E-Mail Dominion NRC/NRRlD 05200008 Dominion re: RAI Letter No. 1 RAI 2.3.1-1, . RIP/RNRP SSAR Section 2.3.1, Regional Climatology.

2 Page(s) _ .

03/17/2004 ML041740371 E-Mails from Dominion Regarding E-Mail Dominion NRC/NRR/D 05200008 Revising North Anna ESP Application and Nuclear North RIP/RNRP Regarding RAL' Anna, LLC

4 Page(s)

B-13
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

03/18/2004 ML042310172 03/18/04-E-Mail from Michael Scott re: E-Mail NRC/NRR/DRI Dominion 05200008 Revised Draft Requests for Additional P/RNRP Generation Information for the North Anna ESP

Review.

5 Page(s)

03/19/2004 ML040910433 03/19/04-Transmittal of North Anna Early Letter Dominion NRC/Docume 05200008 Site Permit Application, Lake Anna Nuclear North nt Control Modeling Calculations. Anna, LLC Desk

17 Page(s) l

03/25/2004 ML040480124 03/25/04-Request For Additional Letter, NRC/NRR/DRI Dominion 05200008 Information Letter No. 2 - Dominion Request P Resources, Nuclear North Anna, LLC ESP Application for Inc for the North Anna ESP Site. Additional

Information

9 Page(s) (RAI)

03/30/2004 1 ML041280591 03/30/04-North Anna Early Site Permit

Application Response to RAI 2.3.3-1, Air

Quality - Meteorological Operations,

Summary of Meteorological Observations.

Graphics

incl Charts

and Tables

Dominion NRC/Docume

nt Control

Desk

05200008

14 Page(s)1 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.1I

B-1 4
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

03/31/2004 ML040980485 03/31/04-North Anna, Early Site Permit Letter Dominion NRC/Docume 05200008 Application Revised Approach for Unit 4 Nuclear nt Control Normal Plant Cooling. Connecticut, Desk

Inc

7 Page(s)

04/13/2004 ML042310164 04/13/04 - E-Mail from Michael Scott re: E-Mail NRC/NRR/DRI Dominion 05200008 Draft Request For Additional Information P/RNRP Generation Package 4.

-_-_ __- 10 Page(sj)

04/13/2004 ML041110812 04/13/04-North Anna Early Site Permit Letter Dominion NRC/Docume 05200008 Application Partial Response to Request Nuclear North nt Control for Additional Information No. 1. Anna, LLC Desk

42 Page(s)

04/14/2004 ML042320164 04/14/04- E-Mail from Joseph Hegner of E-Mail Dominion NRC/NRR/D 05200008 Dominion re: Revising the North Anna RIP/RNRP ESP Application.

2 Page(s) __

04/14/2004 ML041050879 04/14/04-New Environmental Project Manager for the Review of the Early Site

Permit (ESP) Application for the North

Anna Site.

2 Page(s)

Letter NRC/NRR/DRI

P/RLEP

Dominion

Resources,

Inc

05200008

*

B-15
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

04/15/2004 ML040840202 04/15/04-Request For Additional Letter, NRC/NRR/DRI Dominion 05200008 Information Letter No. 3 - Dominion Request P/RNRP Resources, Nuclear North Anna, LLC Early Site for Inc Permit Application for the North Anna ESP Additional

Site (TAC No. MC1127). Information

(RAI) 11 Page(s)

05/03/2004 ML042310187 05/03/04 - E-Mail re: Draft Requests for E-Mail, NRC/NRR/DRI Dominion 05200008 Additional Information Package 5. Request P/RNRP Nuclear North

for Anna, LLC 9 Page(s) Additional

Information

(RAI)__ _ _ _ _

05/06/2004 ML042310185 05/06/04 - E-Mail re: Draft Requests For E-Mail NRC/NRR/DRI Dominion 05200008 Additional Information Package 6. P/RNRP Generation

9 Page(s)

05/07/2004 ML041400016 05/07/04-North Anna - Early Site Permit Letter Dominion NRC/Docume 05200008 Application Final Response to Request for Nuclear North nt Control Additional Information No. 1. Anna, LLC Desk

8 Page(s)

B-1 6

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

05/12/2004 ML041 190447 05/12/04-Request For Additional Letter, NRC/NRR/DRI Dominion 05200008 Information Letter No. 4 - Dominion Request P Resources, Nuclear North Anna, LLC, Early Site for Inc Permit Application for the North Anna ESP Additional

Site (TAC No. MC1 127) Information

(RAI)

13 Page(s) ,

05/17/2004 ML042440879 05/17/04- email from T. Banks forwarding E-Mail, Dominion NRC 05200008 Dominion's response to environmental Letter Nuclear North

RAls for the North Anna ESP. Anna, LLC

1 Page(s).

05/17/2004 ML041450041 05/17/04-Dominion Nuclear North Anna, Letter, Dominion. NRC/Docume 05200008 LLC North"Anna Early Site Permit Request Nuclear North nt Control Application Response to Request for for Anna, LLC Desk Additional Information Regarding Additional

Environmental Portion of ESP Application. Information

(RAI)

95 Page(s) _

05/26/2004 ML042310182 05/26/04.- E-Mail re: Draft Requests For E-Mail, NRC/NRR/DRI Dominion 05200008 Additional Information Package 7. Request P/RNRP Generation

for

7 Page(s) Additional

Information .__ _(RAI) _

B-1 7
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

06/01/2004 ML041480188 06/01/04-Request for Additional Letter, NRC/NRR/DRI Dominion 05200008

Information Letter No. 5 - Dominion Request P/RNRP Resources, Nuclear North Anna Early Site Permit for Inc

Application for the North Anna ESP Site. Additional

information

10 Page(s) (RAI)

06/01/2004 ML041400498 06/01/04-Request For Additional Letter, NRC/NRR/DRI Dominion 05200008 Information Letter No. 6 - Dominion Request P/RNRP Resources, Nuclear North Anna, LLC ESP Application for Inc

for the North Anna ESP Site (TAC No. Additional

MCI 127). Information

(RAI)

11 Page(s)

06/02/2004 ML041540413 E-Mails Conveying Draft RAI Packages E-Mail, Dominion NRC/NRR/D 05200008

5,6,7 Regarding North Anna ESP Request Generation RIP/RNRP

Application. for

Additional

25 Page(s) Information

(RAI)

06/03/2004 ML042400485 06/03/04-Enclosure 2, Revisions to SSAR - No Dominion NRC/Docume 05200008

Section 1.8 in Response to RAI 1.8-1. Document Nuclear North nt Control

Type Anna, LLC Desk

35 Page(s) Applies

B-1 8
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

06/03/2004 ML050660242 Dominion (North Anna) ESP - NRC RAI Letter, NRC/NRR/DRI Dominion 05200008 letter No. 7. Request P/RNRP Resources

for Services, Inc

9 Page(s) Additional

Information

(RAI)

06/03/2004 ML041410109 06/03/04-Request For Additional Letter, NRC/NRR/DRI Dominion 05200008 Information Letter No. 7 - Dominion Request P/RNRP' Resources, Nuclear North Anna, LLCESP Application for Inc

for the North Anna ESP Site (TAC No. Additional

MCI 127). Information

(RAI)., 9 Page(s) . i_.

06/11/2004 ML041750020 06/11/04-North Anna Early Site Permit Letter Dominion NRC/Docume 05200008 Application' Response to Request for Nuclear North nt Control Additional Information No. 2 and Anna, LLC Desk

Corrected Seismic Hazard Deaggregation

Results.

17 Page(s) '-

.

To

.e

.. ,

06/14/2004 ML041670414 06/14/04-E-mail from J. Lee, NRC, to T.

Banks, Dominion, re Ju'ne 7, 2004 Telcon

re MACCS2 code. Acknowledges receipt

of 2 MACCS2 output files and the AP1 000

Table 7.4.

E-Mail I NRC Dominion 05200008

410 Page(s) -' I- I - ______________________

B-I 9
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

06/22/2004 ML041400188 06/22/04-Letter to D. Christian, Dominion, Letter NRC/NRR/DRI Dominion 05200008

re: ESP Template. P/RNRP Resources,

Inc

7 Page(s)

06/22/2004 ML041700114 06/22/04-Revised Early Site Permit Letter NRC/NRR/DRI Dominion 05200008

Environmental Review Schedule. P/RNRP Resources,

Inc

10 Page(s)

06/23/2004 ML041830193 06/23/04-Summary of Telephone Call Meeting NRC/NRR/DRI Dominion 05200008

Between the U.S. Nuclear Regulatory Summary, P/RLEP Nuclear North

Commission & Dominion Concerning Note to Anna, LLC

Clarification of Response to Request for File incl

Additional Information (RAI) Pertaining to Telcon

the North Anna Early Site Permit Record,

Application (TAC NO. MCI 128). Verbal

Comm __ 9 Page(s)

06/23/2004 ML041740376 06/23/04-North Anna Power Station 2004 - No Caroline NRC/NRR/D 05000338, Emergency Planning Information Document County, VA, RIP/RNRP 05000339, Calendar. Type Dominion, 05200008

Applies Hanover

15 Page(s) County, VA,

Louisa

County, VA,

Spotsylvania

County, VA

B-20

-
Document Accession Tltle/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

06/24/2004 ML041770579 06/24/04-Issuance of Environmental Letter NRC, Dominion 05200008 Scoping Summary Report Associated with NRC/NRR/DRI Energy Co the Staff's Review of the Application by P/RLEP

Dominion Nuclear North Anna, LLC for an

'Early, Site Permit for the North Anna ESP

Site..

142 Page(s) ..

06/28/2004 ML041890324 06/28/04-Dominion Nuclear North Anna, Letter Dominion, NRC/Docume 05200008 LLC, North Anna Early Site Permit Dominion nt Control Application Response to Virginia Nuclear North Desk

Department of Environmental Quality Anna, LLC

Comment Letter.

________ G.....67 Page(s) . __. . ..

07/08/2004 ML042310575 07/08/04-Dominion Nuclear Response to Graphics Dominion NRC/Docume 05200008

RAI Letter No. 3 for North Anna ESP. incl Charts Nuclear North nt Control

and Anna, LLC Desk

114 Page(s) Tables,

Letter, .. .Photograp

h

07/08/2004 ML042800292 North Anna, LLC, North Anna Early Site Letter Dominion NRC/Docume 05200008

Permit Application Response to Request Nuclear North nt Control

for Additional Information No. 3. Anna, LLC Desk

._ _ _ _ _ _ _ _ _ _ . . . .. : . . . 1 14 P a g e (s) ._; _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ . _. _ _. _. _. _. _

B-21
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/09/2004 ML041770093 07/09/04-Additional Information Needed Letter, NRC/NRR/DRI Dominion 05200008 with Regard to RAI Letter No. 2 - Request P/RNRP Resources, Dominion Nuclear North Anna, LLC ESP for Inc

Application for the North Anna ESP Site. Additional

Information

7 Page(s) (RAI)

07/12/2004 ML041970396 07/12/04-Dominion Nuclear North Anna, Letter Dominion NRC/Docume 05200008 LLC, North Anna Early Site Permit Nuclear North nt Control Application Response to Requests for Anna, LLC Desk

Additional Information Regarding

Environmental Portion of ESP Application.

62 Page(s) .

07/13/2004 1 ML041970029 07/13/04-E-mail from Dominion to NRC

Forwarding to Request for Additional

Information Regarding - North Anna ESP - Fromr: Maggie McClure To: Jack Cushing,

Dated July 13, 2004.

E-Mail,

Letter

Dominion

Nuclear North

Anna, LLC

NRC 05200008

64 Page(s)

07/15/2004 ML041980455 07/15/04- E-mail from Dominion with E-Mail, Dominion NRC/Docume 05200008 Attached Cover Letter for Submission of a Letter Nuclear North nt Control

Revision to the North Anna ESP Anna, LLC Desk, Application. NRC/NRR/D

RIP/RLEP 10 Page(s) I

B-22

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/15/2004 ML042330680 07/15/04- E-mail - RAI 3 e-mail. E-Mail Dominion NRC 05200008

Nuclear North

2 Page(s) Anna, LLC

07/15/2004 ML042330747 07/15/04-E-mail-Outgoing Dominion E-Mail Dominion NRC 05200008 Correspondence to NRC -NAPS ESP Nuclear North Application, Rev. 2 (SN04-434). Anna, LLC

2 Page(s) _

07/15/2004 ML042330750 07/15/04-Outgoing Dominion Letter Dominion NRC/Docume 05200008 Correspondence to NRC - NAPS ESP Nuclear North nt Control Application, Rev. 2 (SN04-434). Anna, LLC Desk

8 Page(s) e

07/15/2004 ML042010010 07/15/04-Dominion Nuclear North Anna, Letter . Dominion, NRC/Docume 05200008, LLC, Early Site Permit Application, Dominion nt Control PROJO719 Revision 2. Nuclear North Desk

Anna, LLC 9 Page(s) _

07/27/2004 ML042380120 07/27/04 - E-Mail-W-9 for Dominion E-Mail Dominion NRC/NRR/D 05200008 Nuclear North Anna, LLC. Generation RIP/RNRP

3 Page(s)

V

07/30/2004 1 ML042010023 07/30/04-North Anna Early Site Permit

Application, Revision 2, Part 2, Page 2-2-

397 through Page 2-2-492.

96 Page(s)" ::

Final

Safety

Analysis

Report

(FSAR)..

Dominion

Nuclear North

Anna, LLC

NRC 05200008,

PROJO719

., , .

_ L_ _-

B-23
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/30/2004 ML042010017 07/30/04-North Anna Early Site Permit License- Dominion NRC 05200008, Application, Revision 2, Cover Sheet Application Nuclear North PROJO719 through Part 2, Page 2.5.4A-66. for Anna, LLC

Constructi

491 Page(s) on Permit

DKT 50

07/30/2004 ML042010019 07/30/04-North Anna Early Site Permit Report, Dominion NRC 05200008, Application, Revision 2, Final Report, Technical Nuclear North PROJO719 "Results of Geotechnical Exploration and Anna, LLC

Testing," through Figure 2.5-4B-1.

396 Page(s)

07/30/2004 ML042010029 07/30/04-North Anna Early Site Permit Final Dominion NRC 05200008, Application, Revision 2, Part 2, Page 2-3-1 Safety Nuclear North PROJO719 through Quality Assurance Manual. Analysis Anna, LLC

Report 109 Page(s) (FSAR),

Manual,

Quality

Assurance

Program

B-24

PFF-RW N
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

07/30/2004 ML042010027 07/30/04-North Anna Early Site Permit Drawing, Dominion NRC 05200008, Application, Revision 2, Part 2, Page 2-2- Final Nuclear North PROJO719 .523 through Page 2-2-549. Safety 'Anna, LLC

Analysis 27 Page(s) Report

(FSAR),

Graphics

.nci Charts

and

Tables, .___ _ Map .'

07/31/2004 ML042010026 07/31/04-North Anna Early Site Permit Drawing, Dominion NRC '05200008, Application, Revision 2, Part 2, Page 2-2- Final Nuclear North PROJO719

493 through Page 2-2-522. Safety Anna, LLC

Analysis 30 Page(s) Report

(FSAR),

Graphics

incl Charts

and

Tables, ._ _ _ _ _ ._ _;_-_ __.;:_ _-.__-_ _-_.M ap _. ._.__ 

07/31/2004 ML042010032' 07/31/04-North Anna Early Site Permit Environme Dominion NRC 05200008, Application, Revision 2, Part 3, Page 3-3-1 ntal Report Nuclear North PROJO719 through Part 4. Anna, LLC

__________ ._____ _ 504 Page(s) '

;',

B-25
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

07/31/2004 ML042010031 07/31/04-North Anna Early Site Permit Environme Dominion NRC 05200008, Application, Revision 2, Part 3 - ntal Report Nuclear North PROJO719 Environmental Report through Page 3-2- Anna, LLC

255.

272 Page(s) .

08/02/2004 ML042370224 08/02/04-North Anna ESP - Response to Letter Dominion NRC/Docume 05200008 RAI No. 4, (SN 04-318). Nuclear North nt Control

Anna, LLC Desk

145 Page(s)

08/02/2004 ML042260478 08/02/04-Enclosure 2: Revisions to SSAR Final Dominion NRC/Docume 05200008 Section 2.3 and ER Section 2.7 for Safety Nuclear North nt Control

Responses to RAls 2.3.1-1 (revised), Analysis Anna, LLC Desk

2.3.1-2, 2.3.1-3, 2.3.1-4, 2.3.1-5, 2.3.1-6, Report and 2.3.2-2. (FSAR),

Letter

57 Page(s)

08/02/2004 ML042250143 08/02/04-North Anna Early Site Permit Letter Dominion NRC/Docume 05200008 Application Response to Request for Nuclear North nt Control

Additional Information No. 4. Anna, LLC Desk

88 Page(s)

08/03/2004 ML042370208 08/03/04-E-mail-Outgoing Dominion E-Mail, Dominion NRC 05200008 Correspondence to NRC - North Anna Letter Nuclear North

ESP - Response to RAINo. 4 (SN 04-318). Anna, LLC

2 Page(s)

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

08/04/2004 ML042450006 08/04/04 drawing of intake structure for Drawing Dominion NRC 05200008 North Anna ESP, sent in an email from J. Nuclear North Hegner, Dominion. Anna, LLC

1 Page(s)

08/05/2004 ML042240436 08/05/04-North Anna Early Site Permit Letter Dominion NRC/Docume 05200008 Application Response to Request for Nuclear North nt Control Additiorial Information No. 5. Anna, LLC Desk

111 Page(s)

08/05/2004 ML042370444 08/05/04 - E-Mail - Outgoing Dominion E-Mail, Dominion NRC/NRRID 05200008 Corresponidence to' NRC (First Part) - Letter Generation RIP/RNRP North Anna ESP Response to RAI No. 5 , r, , -,in !1 '(SN-04-347). "-

52 Page(s)

08/05/2004 ML042370448 08/05/04'- E-Mail - Outgoing Dominion E-Mail Dominion NRCINRR/D 05200008 Correspondence to NRC (Second Part) - Generation RIP/RNRP North Anna ESP Response to RAINo. 5

(SN-04-347).

63 Page(s)

08/05/2004 ML042290305 08/05/04-E-mail-NORTH ANNA ESP EP E-Mail NRC Dominion 05200008

RAI Nuclear North

- ___ 5 Page(s) .* ' ' Anna, LLC

B-27
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

08/10/2004 ML042290083 08/10/04-Dominion Nuclear North Anna. Letter Dominion NRC/Docume 05200008 LLC, North Anna Early Site Permit Nuclear North nt Control Application, Transmittal of Documents in Anna, LLC Desk

Response to NRC Requests for Additional

Information.

17 Page(s)

08/10/2004 ML042370455 08/10/04 - E-Mail - Outgoing Dominion E-Mail, Dominion NRC/NRR/D 05200008 Correspondence to NRC - North Anna Letter Generation RIP/RNRP ESP - Transmittal of Documents in

Response to NRC RAls (SN-04-481).

241 Page(s)

08/10/2004 ML042440681 08/10/04- email from J. Cushing, NRC, E-Mail NRC/NRR/DRI Dominion 05200008 asking for further information on spent fuel P/RLEP

transportation analyses

related to the North Anna ESP.

_______ ____ 2 P a g e ts _ __ _ _ _ __ _ _ _ _ _ _ _

08/10/2004 i ML042240409 08/10/04-North Anna, Early Site Permit

Application Response to Request for

Additional Information No. 6.

Letter Dominion

Nuclear North

Anna, LLC

NRC/Docume

nt Control

Desk

05200008

65 Page(s)

B-28
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

08/11/2004 ML042370342 08/11/04 -E-Mail - Outgoing Dominion E-Mail, Dominion NRC/NRR/D 05200008 Correspondence to NRC - NAPS ESP - Letter Generation RIP/RNRP Response to RAI No. 6 (SN-04-348).

66 Page(s)

08/17/2004 ML042310737 08/17/04-Summary of Telephone Calls Meeting NRC/NRR/DRI Dominion 05200008 Between the U.S. Nuclear Regulatory Summary P/RLEP Nuclear North Commission and Dominion Pertaining to Anna, LLC the Environmental Review of the North

Anna Early Site Permit Application (TAC NO. MC1 128).

8 Page(s) - -_-

08/19/2004 ML042440365 08i19/04-Dominion Nuclear North Anna, Letter Dominion NRC/Docume 05200008 LLC, North Anna Early Site Permit Nuclear North nt Control Application Supplemental Response to Anna, LLC Desk Request for Additional Information No. 5.

71 Page(s). l- .

08/19/2004 ML042440355 08/19/04-Dominion Nuclear North Anna,

LLC, North Anna Early Site Permit

Application Supplemental Response to

Request for Additional Information No. 4.

Letter Dominion

Nuclear North

Anna, LLC

NRC/Docume

nt Control

Desk

05200008 0 0

43 Page(s). ________ A ___________ I I

B-29
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

08/19/2004 ML042370348 08/19/04 - E-Mail - Outgoing NRC E-Mail, Dominion NRC/NRR/D 05200008 Correspondence Serial No. 04-438: North Letter Generation RIP/RNRP Anna ESP Application Response to July 9,

2004, Request for Additional Information

and RAI 2.5.2-9.

21 Page(s)

08/19/2004 ML042390471 08/1 9/04-Dominion Nuclear North Anna, Letter Dominion NRC/Docume 05200008 LLC North Anna Early Site Permit Nuclear North nt Control

Application Response to July 9. 2004 Anna, LLC Desk

Request for Additional Information and

RAI 2.5.2-9.

18 Page(s)

08/20/2004 ML042400482 08/20/04-North Anna Early Site Permit Letter Dominion NRC/Docume 05200008

-Application Response to Request for Nuclear North nt Control Additional Information No. 7. Anna, LLC Desk

29 Page(s)

08/20/2004 ML042370452 08/20/04 - E-Mail - Dominion Second E-Mail, Dominion NRC/NRR/D 05200008 Responses to NRC RAls 4 and 5. Letter Generation RIP/RNRP

81 Page(s)

B-30

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillatlon(s) Number

08/20/2004 ML042360260 08/20/04-Dominion response to RAI Letter Dominion NRC/Docume 05200008

package 7. Nuclear North nt Control

Anna, LLC Desk

63 Page(s)

08/23/2004 ML042360251 08/23/04-E-mail-Outgoing NRC E-Mail Dominion NRC 05200008

Correspondence Serial No. 04-354: Nuclear North

Response to Request for Additional Anna, LLC

Information No. 7.

2 Page(s)

08/23/2004 ML042430538 08/23/04 - E-mail from J. Wilson to T. E-Mail NRC Dominion 05200008 Banks Regarding Telcon Summary.

2 Page(s)' '_'___'_';

08/23/2004 ML042390256 08/23/04-E-mail from James Wilson re: E-Mail NRC/NRR Dominion 05200008

Telecon Summary. Nuclear North

Anna, LLC .11 Page(s)

08/23/2004 ML042460290 08/23/04- e-mail from J. Wilson, NRC, E-Mail NRC/NRR Dominion 05200008 forwarding a 08/17/04 telecon summary to

Dominion Nuclear North Anna, LLC.

2 Page(s) ;

08/23/2004 ML042430556 08/23/04 - E-mail from T. Banks to J. E-Mail Dominion NRC 05200008 Wilson' Regairding Telecon Summary.

2 Page(s) . ' ''__'_:_;'_

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

09/07/2004 ML042590082 09/07/04-Dominion Nuclear North Anna, Letter Dominion NRC/Docume 05200008 LLC North Anna Early Site Permit Nuclear North nt Control

Application Revision 3. Anna, LLC Desk

9 Page(s)

09/16/2004 ML042640344 09/16/04-Email from Dominion RE: E-Mail Dominion NRC 05200008

Dominion response to NRC conference

call - RADTRAN runs.

202 Page(s)

09/17/2004 ML042590004 09/09/04 - Summary of Meeting with Meeting NRC/NRR/DRI Dominion 05200007, Dominion, SERI and Exelon Regarding Summary P/RNRP Nuclear North 05200008, Reviews of EP Aspects of Their Anna, LLC, 05200009 Respective ESP Applications. Exelon

Generation 10 Page(s) Co, LLC,

Exelon

Nuclear,

System

Energy

Resources, __ Inc

B-32
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

09/22/2004 ML042670291 09/22/04 E-mail from Dominion re: Lake E-Mail Dominion Battelle 05200008 Anna State Park Attendance Data. Nuclear North Memorial

Anna, LLC Institute, 1 1. Page(s) - . Pacific

Northwest

National Lab,

NRC

09/23/2004 ML042680127 Email from Dominion Confirming 2001 E-Mail, Dominion Dominion, 05200008 Lake Anna - Lake Level and North Anna Environme NRC'-! - Temperature Data -2001. ntal Impact

Statement, 3 Page(s) Graphics

ind Charts

and Tables

09/23/2004 ML042720017 09/23/04 E-mail, from Dominion re North E-Mail, Dominion NRC 05200008 Anna 2001 Lake Level. Graphics

; Xincl Charts

4 Page(s) I and Tables

10/01/2004 ML042390205 10/01/04-Request For Withholding Proprietary NRO/NRR/DRI Dominion 05200008 Inf6reiation From Public Disclosure for Information P/RNRP Nuclear North 8/10/2004, Response to Request for RAI. Review Anna, LLC

7 Page(s) e

B-33
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

10/04/2004 ML042790235 10/04/04-North Anna Early Site Permit Graphics Dominion NRC/Docume 05200008 Application Response to August 2004 incl Charts Nuclear North nt Control Request for Additional Information. and Tables Anna, LLC Desk Enclosure 3 - Virginia Department of

Conservation and Recreation Park Visitor

and Boat Launch Data Sheets.

37 Page(s)

10/04/2004 ML042790226 10/04/04Transmittal of North Anna Early Environme Dominion NRC/Docume 05200008 Site Permit Application Response to ntal Nuclear North nt Control August 2004 Request for Additional Report, Anna, LLC Desk Information, and Enclosure 2, Letter

"Environmental Study of Lake Anna and

the Lower North Anna River, Annual

Report for 2001," Cover through Page 26.

44 Page(s)

10/05/2004 ML042800346 10/05/04 E-mail from V. Hull of Dominion E-Mail, Dominion Battelle 05200008 regarding Response to August 2004 Environme Memorial

Request for Additional Information -, North ntal Institute, Anna Early Site Permit/Application. Report, Pacific

Letter Northwest 111 Page(s) National Lab,

_NRC_

B-34

. ..- -
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affiliation(s) Number

10/08/2004 ML041380189 Dominion Resources Services, Inc., Letter, NRC/NRR/DRI Dominion 05200008 Withholding From Public Disclosure, North Proprietary P/RNRP Resources, Anna ESP Application. Information Inc

Review

8 Page(s)

10/13/2004 ML042880521 10/13/04 - E-Mail, re: 2 Requests for E-Mail, Dominion NRC/NRR/D 05200008 Withholding Information From Public Letter Generation RIP/RNRP

Disclosure for North Anna ESP

Application.

17 Pabe(s) l

10/20/2004 ML050660244 Dominion (North Anna) ESP - Dominion Letter Dominion NRC/Docume 05200008 Nuclear North Anna letter re: Nuclear North nt Control

supplernenta! response to RAI No. 7. Anna, LLC Desk

14 Page(s)

10/20/2004 I ML042950468 North Anna Early Site Permit Application,

Supplemental Response to RAI No. 7.

14 Page(s) -

Final

Safety

Analysis

Report

(FSAR),

Letter

Dominion

Nuclear North

Anna, LLC

NRC/Docume

nt Control

Desk

05200008

I I I I .1

B-35
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Aff iliat ion(s) Aff iliation(s) Number

10/21/2004 ML043220479 10/21/2004-E-Mail re: Outgoing NRC E-Mail Dominion NRC/NRR/D 05200008 Correspondence Serial No. 04-354A: Generation RIP/RNRP Supplemental Response to RAI No. 7 -

North Anna Early Site Permit Application.

16 Page(s) _ _ _ _ _ _ _ _ _ _ _

10/28/2004 ML0431 00322 Email from Jack Gushing, NRC to Tony E-Mail, NRC Dominion 05200008 Banks (Dominion) forwarding RAI for S-3. Letter

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 2 P a ge (s ) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

10/29/2004 1 ML043030707 Supplemental Request for Additional

Inform~ation (RAI) Regarding the

Environmental Portion of the Early Site

Permit (ESP) Application for the North

Anna Site (TAG NO. MCi 128).

Letter NRC/NRR/DRI

P

Dominion

Resources,

Inc

05200008

6 Page(s)

I 11I/08/2004 ML042590085 Request For Additional Information - Letter, NRC/NRR/DRI Dominion 05200008

Dominion Nuclear North Anna, LLC ESP Request P/RNRP Resources, Application for the North Anna ESP Site for Inc (MC1 127). Additional

Information __ _ _ _ _ _ _ 8 Page(s) (RA I) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

B-36

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

11/12/2004 ML043080347 Revised Early Site Permit Environmental Letter NRC/NRR/DRI Dominion 05200008

Review Schedule of the Dominion Early P/RNRP Resources, Site Permit Application. Ino

6 Page(s) _

11/18/2004 ML043240229 North Anna Early Site Permit Application Letter Dominion NRC/Docume 05200008 Response to October 29, 2004 RAI on Nuclear nt Control

Uranium Fuel Cycle Impacts. Connecticut, Desk

Inc

5 Page(s)

12/02/2004 ML043370460 Notice of Availability of the Draft Federal NRC/NRR/DRI Dominion 05200008 Environmental Impact Statement for Early Register P/RLEP Nuclear North Site Permit (ESP) at the North Anna ESP Notice, *Anna, LLC

Site(Tac No.. MC1 128). Letter

14 Page(s)

12/03/2004 ML043070126 Potential Open Items for the DSER For Letter NRC/NRR/DRI Dominion 05200008 The North Anna ESP Application. P/RNRP Resources,

Inc

8 Page(s) _ :

12/09/2004 ML043450334 Email from Spencer Spemmes regarding E-Mail Dominion NRC 05200008

North Anna ESP Figure 3.1-2. Resources,

I no _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 4 P a g e (s )_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

B-37
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Aff iliation(s) Affiliation(s) Number

12/20/2004 ML043560205 12/20/2004 - E-Mail re: Draft Safety E-Mail NRC/NRRIDRI Dominion, 05200008 Evaluation Report for the North Anna P/RNRP Exelon Corp, Early Site Permit Application. Framatomne

ANP, Inc, 4 Page(s) General

Atomics,

General

Electric

Nuclear

Energy

Owners

Group,

Greenpeace,

Nuclear

Control

Institute,

Nuclear

Energy

Institute

(NEI),

Nuclear

Information &

Resource

Service

(NIRS),

Public

Citizen, Inc,

ShawPittman,

LLP, Union of

Concerned

B-38

MMMOPPM-4-44".4" -
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

12/20/2004 ML043070296 Cover Letter: Draft Safety Evaluation Letter NRC/NRR/DRI Dominion 05200008

Report for the North Anna ESP P/RNRP Resources,

Application. Inc

5 Page(s) .

B-39
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

01/11/2005 ML050120082 01/11/2005-E-Mail re: Fwd: Draft Safety E-Mail NRC/NRR/DRI Dominion, 05200008

Evaluation Report for the North Anna P/RNRP Entergy Early Site Permit Application. Nuclear

Operations, 4 Page(s) Inc, Exelon

Corp,

Framatome

ANP, Inc,

General

Atomics,

General

Electric Co,

Greenpeace,

Nuclear

Control

Institute,

Nuclear

Information &

Resource

Service

(NIRS),

Public

Citizen, Inc,

ShawPittman,

LLP, Union of

Concerned

Scientists, US

Dept of . Energy

(DOE),

B-40

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

01/12/2005 ML050110239 Draft Safety Evaluation Report for the

North Anna Early Site Permit Application.

10 Page(s)

I. . I,I r I

Letter NRC/NRR/DRI

P/RNRP - No Known

Affiliation,

Advanced

Technologies

& Labs

International,

Inc, Dominion

Nuclear North

Anna, LLC,

Dominion

Resources,

Inc, Enercon

Services, Inc,

Exelon Corp;

Exelon

Generation

Co, LLC,

Framatome

ANP, Inc,

Greenpeace,

Louisa

County, VA,

Louisa

County, VA,

Public

Library, NRC,

Nuclear

Control

Institute,

Nuclear -

05200008

.I . I L I

B-41
Document Accession TitlelDescription Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

01/18/2005 ML050210193 01/18/2005-E-Mail re: Siting Study. E-Mail Dominion NRC/NRR/D 05200008

RIP/RNRP

3 Page(s)

01/25/2005 ML050450302 Dominion Nuclear North Anna, LLC North Letter Dominion, NRC/Docume 05200008

Anna Early Site Permit Application Dominion nt Control

Response to Draft Safety Evaluation Nuclear North Desk

Report Open Item 2.5-1. Anna, LLC

9 Page(s) _

01/27/2005 ML050320346 E-mail to Dominion (Tony Banks) - North E-Mail NRC/NRR/DRI Dominion 05200008

Anna Rescheduled Meeting on Draft EIS. P/RLEP

2 Page(s) _

01/28/2005 ML050390343 North Anna Early Site Permit Project Letter Dominion NRC/Docume 05200008

Correspondence Distribution Request. Nuclear North nt Control

Anna, LLC, Desk

2 Page(s) Dominion

Resources, __ Inc

01/31/2005 ML050320090 01/31/2005 - E-Mail re: Dominion E-Mail, Dominion NRC/NRR/D 05200008

Response to DSER Open Item 2.5-1. Legal- Generation RIP/RNRP

Affidavit,

11 Page(s) Letter _

B-42
Document Accession Title/Description Document Author Addressee Docket

Date Number Includes Est. Page Count Type Affiliation(s) Affillation(s) Number

02/07/2005 ML050410133 02/07/2005-E-Mail re: Information to E-Mail Dominion NRC/NRR/D 05200008

Support Upcoming Meeting to Discuss Nuclear North RIP/RNRP

North Anna ESP DSER. Anna, LLC

37 Page(s)

02/09/2005 ML050420122 02/09/2005 - E-Mail re: Directions to North E-Mail Dominion NRC/NRR/D 05200008

Anna. Nuclear North RIP/RNRP

Anna, LLC .

2 Page(s)

B-43
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

02/10/2005 ML050530387 02/10/2005-E-Mail re: Upcoming Public E-Mail NRC/NRR/DRI Dominion, 05200008

Meetings Regarding North Anna Early Site P/RNRP Entergy Permit Application. Operations,

Inc, Exelon

4 Page(s) Corp,

Framatome

ANP, Inc,

General

Electric Co,

Greenpeace,

NRC, Nuclear

Energy

Institute

(NEI),

Nuclear

Information &

Resource

Service

(NIRS),

Public

Citizen, Inc,

ShawPittman,

LLP, Union of

Concerned

Scientists, US

Dept of

Energy

(DOE),

Westinghous

e Electric Co

B-44

I
Document Accession Title/Description Document Author Addressee Docket Date Number, Includes Est. Page Count -Type Affiliation(s) Affiliation(s) Number

02/17/2005 ML050880319 02/17/05 - Public Meeting on DEIS for the Meeting NRC/NRR/DRI Dominion, 05200008 Early Site Permit at the North Anna Site, Briefing P Nuclear North U.S. Nuclear Regulatory Commission, Package/H Anna, LLC

February 17, 2005. andouts,

Slides and

29 Page(s) Viewgraph

s

02/18/2005 ML050490430 North Anna Early Site Permit Application Letter Dominion NRC/Docume 05200008 Draft Safety Evaluation Report Open Item Nuclear North nt Control

2.5-2. Anna, LLC Desk

7 Page(s)

02/18/2005 ML050530385 02/18/2005-E-Mail re: 04-785A: Dominion E-Mail, Dominion, NRC/NRR/D 05200008

Nuclear North Anna, LLC North Anna Letter Dominion RIP/RNRP Early Site Permit Application DSER Open Nuclear North

Item 2.5-2. Anna, LLC

9 Page(s) ;

02/18/2005 ML050590053 02/18/2005- E-Mail re: 04-785A - E-Mail, Dominion NRC/NRR/D 05200008

Dominion Nuclear North Anna, LLC North Letter Nuclear North RIP/RNRP

Anna Early Site Permit Application Draft Anna, LLC

Safety Evaluation Report Open Item 2.5-2.

10 Page(s)

B-45
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Aff iliation(s) Number

02/2212005 ML050660369 02/2212005-E-Mail re: Fwd: Upcoming E-Mail NRC/NRRIDRI Dominion, 05200008

Public Meetings Regarding North Anna P/RNRP Entergy Early Site Permit Application. Operations,

Inc, Exelon

5 Page(s) Corp,

Framatomne

ANP, Inc,

General

Atomics,

General

Electric Co,

Greepnpeace,

NRC, Nuclear

Control

Institute,

Nuclear

Energy

Institute

(NEI),

Nuclear

Information &

Resource

Service

(NIRS),

Public

Citizen, Inc,

ShawPittman,

LLP, Union of

Concerned ________ __ _____ ________ Scientists, US _ _ _ _ _ _

B-46

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Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

02/22/2005 ML050530390 02/22/2005 - E-Mail re: Fwd: Upcoming

Public Meetings Regarding North Anna

Early Site Permit Application.

5 Page(s) ....

E-Mail NRC/NRR/DRI

P/RNRP

Dominion,

Entergy

Operations,

Inc, Exelon

Corp,

Framatome

ANP, Inc,

General

Electric Co,

Greenpeace,

NRC, Nuclear

Energy

Institute

(NEI),

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Information &

Resource

Service

(NIRS),

Public

Citizen, Inc,

ShawPittman,

LLP, Union of

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Dept of

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05200008

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Aff iliation(s) Number

03/01/2005 ML050620206 03/01/05 E-mail from T. Banks Re: E-Mail Dominion NRC 05200008 Dominion NA ESP DEIS Comments. Nuclear North

Anna, LLC

22 Page(s) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

03/01/2005 ML05063041 1 Comment (423) of Eugene S. Grecheck re General Dominion NRC/Documne 05200008 NUREG-1 81 1, Draft Environmental Impact FR Notice Nuclear North nt Control Statement For An Early Site Permit (ESP) Comment Anna, LLC Desk At The north Anna ESP Site. Letter

20 Page(s)__ _ _ _ __ _ _ _ _

03/01/2005 ML05061 0241 North Anna Early Site Permit Application, Environme Dominion NRC/Docume 05200008 Comments on NUREG-1 81 1, Draft ntal Impact Nuclear North nt Control Environmental Impact Statement For an Statement, A'nna, LLC Desk Early Site Permit (ESP) at the North Anna Letter

ESP Site.

20 Page(s)

03/03/2005 ML050630261 03/03/05 E-mail from Tony Banks E-Mail Dominion NRC 05200008 .Regarding North Anna ESP DGIF Nuclear North Correspondence. Anna, LLC

___________ ~~6 P age(s)__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

B-48

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Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Afflilation(s) Number

03/03/2005 ML050630210 Enclosure 3-Dominion Nuclear North Anna Drawing, Dominion NRC/Docume 05200008 LLC North Anna Early Site Permit Graphics Nuclear North nt Control

application Responses To Draft Safety incl Charts Anna, LLC Desk

Evaluation Report Open Items'. and

Tables,

86 Page(s) Letter

03/03/2005 ML050830177 North Anna Early Site Permit Application Letter Dominion NRC/Docume 05200008

Responses to Draft Safety Evaluation Nuclear North nt Control Report Open Items. Anna, LLC Desk

90 Page(s)

03/03/2005 ML050660238 03/03/2005 - E-Mail re: Dominion E-Mail;- Dominion NRC/NRR/D 05200008 l Response to DSER Open Items. Letter Nuclear North RIP/RNRP

Anna, LLC

92 Page(s) _

03/03/2005 ML050660365 03/03/2005 - E-Mail re: Jay Lee Request. E-Mail Dominion NRC/NRR/D 05200008

Nuclear North RIP/RNRP , 3 Page(s) i Anna, LLC

03/07/2005 ML050730343 .03/07/2005-E-Mail re: Re: Problem w/EIE E-Mail NRC/NRR/DRI Dominion 05200008 Submission to NRC. P/RNRP Generation

2 Page(s)

03/07/2005 ML050730346 03/07/2005-E-Mail re: Re: Problem w/EIE E-Mail Dominion NRC/NRR/D 05200008 Submission to NRC. Generation RIP/RNRP

3 Page(s) ' _ _ '

B-49
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

03/10/2005 ML050730341 3/10/2005-E-Mail re: Participants on E-Mail Dominion NRC/NRRID 05200008 3/9/05 Conference Call. Generation RIP/RNRP

2 Page(s) _ _ _ _ _ _ _ _ _ _ _ _ _

03/16/2005 ML050800305 03/1 6/2005 - E-Mail re: Industry E-Mail Dominion NRC/NRR/D 05200008 Participants on 3/15/05 Seismic Call. Generation RIP/RNRP

2 Page(s)

03/18/2005 ML050840226 3/18/05 -Supplemental Request for Letter, NRC/NRR/DRI Dominion 05200008 Additional Information (RAI) Regarding the Request P Resources Environmental Portion of the Early Site for Services, Inc Permit (ESP) Application for the North Additional

Anna Site (TAC No. MCi 128). Information

(RAI) ____ ____ ___ 14 Page(s) _ _ _ _ _ _ _ _ _ _ _

03/20/2005 ML050880299 03/20/2005 Summary of Public Meeting Meeting NRC/NRRIDRI Dominion 05200008 Held to Support the Environmental Review Agenda, P/RLEP Nuclear North for the North Anna Early Site Permit Meeting Anna, LLC Application. Briefing

Package/H 21 Page(s) andouts,

Meeting

Summary, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ N o te

B-5O

-. . .
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

03/23/2005 ML050880325 03/23/2005- E-Mail re: Applicant E-Mail Dominion, NRC/NRR/D 05200008

Participants on 3/22/05 Seismic Call. Dominion RIP/RNRP

Nuclear North

2 Page(s) Anna, LLC

03/23/2005 ML051230400 E-mail from Dominion forwarding Environme Dominion NRC/NRR/D 05200008

Dominion's CZMA certification letter to ntal Impact Nuclear North RIP/RLEP

Virginia. Statement Anna, LLC.

20 Page(s) ._._-

03/24/2005 ML050890236 E-Mail from'Dominion forwarding E-Mail Dominion NRC/NRR/D 05200008

supplying' names of people on March 24,' RIP/RLEP

2005, conferehce'call.

2 Page(s)

03/29/2005 ML051010190 03/29/2005 - E-Mail re: Dominion E-Mail Dominion NRC/NRR/D 05200008

Participant on 3/29/05 Conference Call re RIP/RNRP

DSER.

2 Page(s) .'_'

', ;,

03/30/2005 ' ML051020430 I

North Anna Early Site Permit Application

Responses to Draft Safety Evaluation

Report Open Items.

Letter Dominion

'Nuclear North

Anna, LLC

NRC/Docume

nt Control

Desk

105200008

; 103 Page(s)

!

. . ,

B-51
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

03/31/2005 ML051010197 03/31/2005-E-Mail re: Outgoing NRC E-Mail, Dominion NRC/NRR/D 05200008 Correspondence Serial No. 05-194: Letter, RIP/RNRP

Responses to Draft Safety Evaluation Report, Report Open Items - North Anna Early Miscellane

Site Permit Application. 6us

105 Page(s)

03/31/2005 ML050920010 03/31/05 - Summary of a Telephone Call Meeting NRC/NRR/DRI Dominion 05200008 Between the U.S. Nuclear Regulatory Summary, P/RLEP Nuclear North Commission and Dominion Concerning Note, Anna, LLC

the Request for Additional Information Request (RAI) Pertaining to the North Anna Early for

Site Permit Application (TAC No. Additional

MC1 128). Information

(RAI) 15 Page(s)

04/07/2005 ML0510101 43 E-Mail from and response to Ms. Gunter E-Mail, Dominion NRC/NRR 05200008 (Dominion) Requesting Assistance in Environme Generation

finding the meeting Transcript. ntal Impact

Statement

4 Page(s)

04/12/2005 ML051040415 Email from Ms. Bennett (Dominion) E-Mail, Dominion NRC 05200008 forwarding response to request to Letter

document commitments made to Virginia

regarding the striped bass.

_ _ 11 Page(s)

B-52

-- . - I -- - - - - -- -, - ... ...... - ..
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affillation(s) Affillation(s) Number

04/12/2005 ML050810087 North Anna Early Site Permit (ESP) Letter NRC/NRR/DRI Dominion 05200008 Quality Assurance Assessment and P/RNRP Resources

Closure of Confirmatory Item. Services, Inc

7 Page(s)

04/12/2005 ML051090376 North Anna Early Site Permit Application, Letter Dominion NRC/Docume 05200008 Response to Supplemental Request for Nuclear North nt Control Additional Information. Anna, LLC Desk

9 Page(s)

04/13/2005 ML051100321 North Anna Early Site Permit Application, Letter Dominion NRC/Docume 05200008 Response to Supplemental Request for Nuclear North nt Control Additional Information. Anna, LLC Desk

_____ . 13 Page(s) , .

04/14/2005 ML051090196 E-Mail from Ms. Bennett (Dominion)

forwarding response to RAI (1,2,3) dated

March 28, 2005.

15 Page(s)

E-Mail,

Environme

ntal Impact

Statement

Dominion NRC/NRR 05200008

05/02/2005 I ML051230129 North Anna Early Site Permit Application, Letter Dominion NRC/Docume 05200008 Response to Draft Safety Evaluation Nuclear North nt Control Report Open Item 2.1-1. Anna, LLC Desk

6 Page(s)

.:,

B-53
Document Accession Title/Description Document Author Addressee Docket Date Number Includes Est. Page Count Type Affiliation(s) Affiliation(s) Number

05/02/2005 ML051370159 05/02/05 - E-Mail re: 05-194A: Dominion E-Mail, Dominion NRC/NRR/D 05200008 Nuclear North Anna, LLC, North Anna Letter RIP/RNRP

Early Site Permit Application, Response to

Draft Safety Evaluation Report Open Item

2.1-1.

8 Page(s)

05/06/2005 ML051040453 Status of the North Anna Early Site Permit Letter NRC/NRR/DRI Dominion 05200008 Application Review. P/RNRP Resources

Services, Inc 6 Page(s)

05/12/2005 ML051450312 Transmittal of Revision 4 to North Anna Letter Dominion NRC/Docume 05200008 Early Site Permit Application. Nuclear North nt Control

Anna, LLC Desk

7 Page(s) . _

B-54
APPENDIX C

-References

American National Standards Institute (ANSI)

-- , ANSI A58.1, uMinimum Design Loads for Buildings and Other Structures," 1982.

ANSI N45.2.1 1, "Quality Assurance Requirements for Nuclear Power Plants," 1974.

---- ,ANSI N45.2, Quality Assurance Program Requirements for Nuclear Facilities," 1977.A

ANSI N45.2.9,,"Requirements for Collection, Storage, and Maintenance of Quality

Assurance Records for Nuclear Power Plants," 1974.

American National Standards Institute and American Nuclear Society (ANSI/ANS)

ANSI/ANS-2.8, "American National Standard for Determining Design Basis Flooding at

Power Reactor Sites," 1992.

American Society of Civil Engineers and Structural Engineering Institute (SEIIASCE)

SEJ/ASCE 7-02, "Minimum Design Loads for Buildings and Other Structures," 2002.

American Society of Mechanical Engineers (ASME)

-_-_,-ASME NQA-1 -1983, "Quality Assurance Requirements for Nuclear Facility," 1983

-----, ASME NQA-1 -2000, "Quality Assurance Requirements for Nuclear Facility Applications,"

2000.

American Society for Testing and Standards (ASTM)

ASTM D4220-95, "Standard Practices for Preserving and Transporting Soil Samples,"

January 1, 2000.

ASTM D1586-99, "Standard Test Method for Penetration Test and Split-Barrel Sampling of

Soils," January 10, 1999.

ASTM D1 587-00, "Standard Practice for Thin-Walled Tube Sampling of Soils for

Geotechnical Purposes," August 10,2000.'

, ASTM D-4428/D-4428M-00, "Standard Test Methods for Crosshole Seismic Testing,"

January 10, 2000.-

ASTM D-5778-95 (2000), "Standard Test Method for Performing Electronic Friction Cone

and Piezocone Penetration Testing of Soils," January 1, 2000.

C-1
I' Is

American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE)

-- , '2001 ASHRAE Handbook - Fundamentals," July 2001.

Commonwealth of Virginia Emergency Response Plans

Caroline County Radiological Emergency Response Plan, March 2002. (ADAMS Accession

No. ML0411108220).

Commonwealth of Virginia Radiological Emergency Response Plan (COVRERP), March 2002.

(ADAMS Accession No. ML0411108220).

Hanover County Radiological Emergency Response Plan, March 2002. (ADAMS Accession

No. ML0411108220).

Louisa County Radiological Emergency Response Plan, March 2002. (ADAMS Accession

No. ML0411108220).

Orange County Radiological Emergency Response Plan, March 2002. (ADAMS Accession

No. ML0411108220).

Spotsylvania County Radiological Emergency Response Plan, March 2002. (ADAMS

Accession No. ML0411108220).

Dominion Nuclear North Anna, LLC

, March 31, 2004, Letter from Eugene S. Grecheck, Dominion Nuclear North Anna, LLC, to

NRC, Subject: North Anna Early Site Permit Application: Revised Approach for Unit 4 Normal

Plant Cooling. (ADAMS Accession No. ML040980485).

---- , August 19, 2004, Letter from Eugene S. Grecheck, Dominion Nuclear North Anna, LLC, to

NRC, Subject: Dominion Nuclear North Anna, LLC North Anna Early Site Permit Application

Supplemental Response to Request for Additional Information No. 4. (ADAMS Accession

No. ML042440355).

Electric Power Research Institute (EPRI)

-----, Seismic Hazard Methodology for the. Central and Eastern United States," Volumes 5-10,

EPRI: Palo Alto, California, July 1986.

----- , 1008910, "CEUS Ground Motion Project: Model Development and Results," EPRI: Palo

Alto, California, August 2003.

----- , TR-102293, "Guidelines for Determining Design Basis Ground Motions," Volumes 1-5,

Electric Power Research Institute: Palo Alto, California. 1993.

Johnston, A. C., et al. TR-102261-V1, 'The Earthquakes of Stable Continental Regions: -

Volume 1 - Assessment of Large Earthquake Potential," EPRI: Palo Alto, California, 1994.

C-2

l l l 1
Federal Emergency Management Agency'(FEMA)

Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. § 5121

(October 30, 2000), <http://www.fema.gov/librarv/stafact.shtm>.

International Organization of Standards (ISO)

----- , ISO 9001 -2000, "Quality Management Systems -.Requirements," December 13, 2000.

National Climatic Data Center (NCDC)

----- , Eastern Piedmont, Virginia, Divisional Normals-Precipitation, Period 1971-2000,"

Climatography of the United States, No. 85. NCDC: Asheville, North Carolina, June-15, 2002.

-----, Eastern Piedmont, Virginia, Divisional Normals-Temperature, Period 1971-2000,"

Climatography of the United States, No. 85. NCDC: Asheville, North Carolina, June 15, 2002.'

-----, Engineering Weather Data CDROM," Version 1.0. NCDC: Asheville, North Carolina,

December 23,1999.

"Richmond, -, Virginia, 2002 Local Climatological Data, Annual Summary with Comparative

Data," NCDC: Asheville, North Carolina, 2002.

, "Severe -- Thunderstorm Climatology, Total Threat," National Severe Storms Laboratory,

August 29, 2003, <http://www.nssl.noaa.aov/hazard/totalthreat.html> (November 30, 2004).

(ADAMS Accession No. ML043380034). .'

-----, -Solar and Meteorological Surface Observational Network (SAMSON) for Eastern U.S.

CDROM," NCDC: Asheville, North Carolina, September 1993.

Storm Event Database, "Storm Events forVirginia, 01/01/1950 through 04/30/2004,"

<http://www4.ncdc.noaa.oov/cqi-win/wwcai.dll?wwevent-ShowEvent-526500> (September 10,

2004). (ADAMS Accession No. ML043380024).

-----, Storm Event Database, "Storm Events forVirginia 01/011950 through 07/3i/2003,"

<http://www4.ncdc.noaa.qov/cqi-win/wwcai.dll?wwevent-st6rms> (November 30, 2004).

(ADAMS Accession No. ML043380029).

Jones, K., et al., Technical Report 2002-01, "The Development of a U.S. Climatology of

Extreme Ice Loads," National Climatic Data Center:' Asheville, North Carolina,' December 2002.

National Hurricane Center

Beven, J. and H. Cobb. uTropical Cyclone Report, Hurricane Isabel, 6-19 September 2003,"

National Hurricane Center: Miami, Florida, January 2004,

<htto://www.nhc.noaa.gov/2003isabel.shtml?text> (December 2, 2004). (ADAMS Accession

No. ML043380299). '

C-3
II Is

National Oceanic and Atmospheric Administration (NOAA)

, Hydrometeorological Report No. 51, "Probable Maximum Precipitation Estimates. United

States East of the 105th Meridian," NOAA: Washington, D.C., June 1978.--

-----, Hydrometeorological Report No. 52, "Application of Probable Maximum Precipitation

Estimates - United States East of the 105th Meridian," NOAA: Washington, D.C., August 1982.

Hydrometeorological -, Report No. 53, "Seasonal Variation of 10-Square-Mile Probable

Maximum Precipitation Estimates. United States East of the 105th Meridian," NOAA:

Washington, D.C., April 1980.

'What was the highest tsunami?" Frequently Asked Questions, Tsunami Research

Program, <http://www.pmel.noaa.gov/tsunami/Faq/xO05jhighest> (November 15, 2004).

Korshover, J., NOAA Technical Memorandum ERL ARL-55, "Climatology of Stagnating

Anticyclones East of the Rocky Mountains, 1936-1975," NOAA Environmental Research

Laboratories: Silver Spring, Maryland, March 1976.

Landreneau, D., NOAA Technical Memorandum NWS SR-206, "Atlantic Tropical Storms and

Hurricanes Affecting the United States: 1899-2002," Scientific Services Division: Fort Worth,

Texas, June 2003.

Southeast Regional Climatic Center

----- , -Charlottesville, Virginia, Period of Record Monthly Climate Summary, Period of Record:

08/05/1948 to 03/31/2004," <http://cirrus.dnr.state.sc.us/cgi-bin/sercc/cliMAIN.pl?va'l593>

(November 30, 2004).. (ADAMS Accession No. ML043380051).

"Louisa, Virginia, Period of Record Monthly Climate Summary, Period of Record:

08/01/1948 to 03/31/2004," <http://cirrus.dnr.state.sc.us/cgi-bin/sercc/cliMAI N.pl?va5050>

(November 30, 2004). (ADAMS Accession No. ML043380040).

"Partlow, Virginia, Period of Record Monthly Climate Summary, Period of Record:

06/01/1952 to 12/31/1976," <http://cirrus.dnr.state.sc.us/cgi-bin/sercc/cliMAIN.plva6533>

(November 30, 2004). (ADAMS Accession No. ML043380046).

U.S. Army Corps of Engineers

---- , EM 1110-2-1100 (Revision 1), "Coastal Engineering Manual," Department of the Army:

Washington, D.C., July 2003.

-- a-, "HEC-1 Download," U.S. Army Corps of Engineers Hydrologic Engineering Center, 1998,

<http://www.hec.usace.army.mil/software/legacysoftware/hecl /hec1 -download.htm>

(September 1, 2004).

-, "Ice Jam Database," <http://www.crrel.usace.army.miVierd/ijdb/> (August 2, 2004).

C-4
, "Major Dams of the United States," <http://nationalatlas.gov/damsm.html> (July 27, 2004).

----- "National - Inventory of Dams," <http:i/crunch.tec.army.miVnid/webpages/nid.cfm>

(September 15, 2004).

---- , Technical Manual 5-1300, "Structures to Resist the Effects of Accidental Explosions,"

Department of the Army: Washington, D.C., November 19,1990.

U.S. Atomic Energy Commission (AEC)

-----, Safety Evaluation Report of the North Anna Power Station, Units 3 and 4," Supplement 3,

AEC: Washington, D.C., February 1974.

TI D-1 4844, "Calculation of Distance Factors for Power and Test Reactor Sites," AEC:

Washington, D.C., March 1962. (ADAMS Accession No. ML021750625).

U.S. Census Bureau

----- , "Census 2000 Data for the State of Virginia,"

<www.census.pov/census2000/states/va.html>

U.S. Code of Federal Regulations

-----, Title 10, Energy, Part 20, "Standards for Protection Against Radiation.'

Title -, 10, Energy, Part 21, "Reporting of Defects and Noncompliance."

Title -, 10, Energy, Part 50, "Domestic Licensing of Production and Utilization Facilities."

-----, Title 10, Energy, Part 52, "Early Site Permits; Standard Design Certifications; and

Combined Licenses for Nuclear Power Plants."

Title 10, Energy, Part 73, 'Physical Protection of Plants and Materials."

-----, Title 10, Energy, Part 100, "Reactor Site Criteria."

----- , Title 44, Emergency Management and Assistance, Part 350, "Review and Approval of

State and Local Radiological Emergency Plans and Preparedness."

U.S. Environmental Protection Agency (EPA)

-----, EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for

Nuclear Incidents," EPA: Washington, D.C., May 1992.

Testing Standard SW-846, Revision 1, 'Test Methods for Evaluating Solid Waste,

Physical/Chemical Methods," EPA: Washington, D.C., December 1996.

C-5
l X

Holzworth, C., AP-101, "Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution

throughout the Contiguous United States," EPA, Office of Air Programs: Research Triangle

Park, North Carolina, January 1972.

U.S. Geological Survey

"Beaverdam, Virginia 7.5 Minute Quadrangle, topographic map," US Geological Survey:

Reston, Virginia, 1989.

-----, .Belmont, Virginia 7.5 Minute Quadrangle, topographic map," US Geological Survey:

Reston, Virginia, 1989.

"Brokenburg, Virginia 7.5 Minute Quadrangle, topographic map," US Geological Survey:

Reston, Virginia, 1989.

-- , .Buckner, Virginia 7.5 Minute Quadrangle, topographic map," US Geological Survey:

Reston, Virginia, 1989.

-----, "Lahore, Virginia 7.5 Minute Quadrangle, topographic map," US Geological Survey:

Reston, Virginia, 1977.

------ "Lake Anna East, Virginia 7.5 Minute Quadrangle, topographic map," US Geological

Survey: Reston, Virginia, 1989.

------, Lake Anna West, Virginia 7.5 Minute Quadrangle, topographic map," US Geological

Survey: Reston, Virginia, 1983.

,"Mineral, Virginia 7.5 Minute Quadrangle, topographic map," US Geological Survey:

Reston, Virginia, 1973.

, .Online ----- 1-Meter Aerial Imagery of the Lake Anna, Virginia Region," (Imagery data

collected in March and April, 1994) US Geological Survey: Reston, Virginia,

<http://terraserver-usa.com> (2004).

-----, "Peak Streamflow for the Nation, USGS 01670400 NORTH ANNA RIVER NEAR

PARTLOW, Virginia,"

<http:Hlnwis.waterdata.usgs.gov/nwis/peak?siteno=01 670400&agency.cd=USGS&format=htm

I> (August 11, 2004).

------, Peak Streamflow for the Nation, USGS 01671000 NORTH ANNA RIVER NEAR

DOSWELL, Virginia,"

<httpJ/nwis.waterdata.usgs.gov/nwis/peak?siteno=0 1671 000&agencycd=USGS&format=htm

I> (August 11, 2004).

-----, uPendleton, Virginia 7.5 Minute Quadrangle, topographic map," US Geological Survey:

Reston, Virginia, 1989.

C-6
Bollinger, G. A., Bulletin 2017, 'Specification of Source Zones, Recurrence Rates, Focal

Depths, and Maximum Magnitudes for Earthquakes Affecting the Savannah River Site in South

Carolina," U.S. Geological Survey: Reston, Virginia, 1992.

Crone, A. J. and R. L. Wheeier, Open'-File Report 00-260, "Data for Quatemary Faults,

Liquefaction Features, and Possible Tectonic Features in the Central and Eastern United

States, East of the Rocky Mountain Front," U.S. Geological Survey: Reston, Virginia, 2000.

<http://pubs.usgs.gov/of/2000/ofr-00-0260/>

Frankel, A. D., et al., Open-File Report 02-420 "Documentation for the 2002 Update of the -

National Seismic Hazard Maps," U.S. Geological Survey: Reston, Virginia,2002. :

<http://pubs.usgs.gov/of/2002/ofr-02-420/OFR-02-420.pdf>

Mixon, R. B., et al., Geologic Investigations Series Map 1-2607, "Geologic Map of the,-.

Fredericksburg 30' x 60' Quadrangle, Virginia and Maryland," U.S. Geological Survey: Reston,

Virginia, 2000. <http://pubs.usgs.gov/of/2002/ofO2-437/>

Trapp, H., Jr. and M.A. Horn, uGround Water Atlas of the United States, Segment 11,

Delaware, Maryland, New Jersey, North Carolina, Pennsylvania, Virginia, West Virginia,"

Hydrologic Investigations Atlas 730-L, U.S. Geological Survey: Reston, Virginia, 1997.

Weems, R. E., Open-File Report 98-374, "Newly Recognized En Echelon Fall Lines in the

Piedmont and Blue Ridge Provinces of North Carolina and Virginia, With a Discussion of Their

Possible Ages and Origins,." U.S. Geological Survey:- Reston, Virginia, 1998.

U.S. Nuclear Regulatory Commission (NRC)

Draft Regulatory Guides

----- Draft Regulatory Guide DG-1101, Sitenvestigations for Foundations of Nuclear Power

Plants," NRC: Washington, D.C., February 28, 2001 (ADAMS -Accession No. MLO010510162).

Draft Regulatory Guide DG-1 105, "Procedures and Criteria for Assessing Seismic Soil

Liquefaction at Nuclear Power Plant Sites," NRC: Washington, D.C., March 31, 2001 (ADAMS

Accession No. ML010650295).

-----, Draft Regulatory Guide DG-1109, "Laboratory Investigations of Soils for Engineering

Analysis and Design of Nuclear'Power Plants," NRC: Washington, D.C., August 31, 2001

(ADAMS Accession No. ML012420328)

NUREG-Series Reports.

-----, NUREG-0053, "Safety.Evaluation Report related to the operation of North Anna Power

Station, Unit 2," NRC: Washington, D.C., August1980.

-----, NUREG-75/014, "Reactor Safety Study: An Assessment of Accident Risk in U.S.

Commercial Nuclear Power Plants," NRC: Washington, D.C., October 1975.

C-7
---- , NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power

Plants," Washington, D.C., November 1980.

-----, NUREG-0654/FEMA-REP-1, Revision 1, Supplement 2, "Criteria for Preparation and

Evaluation of Radiological Emergency Response Plans and Preparedness in Support of

Nuclear Power Plants - Criteria for Emergency Planning in an Early Site Permit Application -

Draft Report for Comment," NRC: Washington, D.C., April 1996.

---- , NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, "Criteria for Preparation and

Evaluation of Radiological Emergency Response Plans and Preparedness in Support of

Nuclear Power Plants - Criteria for Protective Action Recommendations for Severe Accidents -

Draft Report for Interim Use and Comment," NRC: Washington, D.C., July 1996.

---- NUREG-0696, "Functional Criteria for Emergency Response Facilities - Final Report,"

NRC: Washington, D.C., February 1981.

---- , NUREG-0737, "Clarification of TMI Action Plan Requirements," NRC: Washington, D.C.,

October 1980.

-----, NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis

Reports for Nuclear.Power Plants," NRC: Washington, D.C., July 1981.

----- , NUREG-0917, 'Nuclear Regulatory Commission Staff Computer Programs for Use with

Meteorological Data," NRC: Washington, D.C., July 1982.

-, NUREG-1 811, "Draft Environmental Impact Statement for an Early Site Permit (ESP) at

the North Anna ESP Site," NRC: Washington, D.C., November 2004.

-----, NUREG/CR-2858, "PAVAN: An Atmospheric Dispersion Program for Evaluating Design

Basis Accidental Releases of Radioactive Materials from Nuclear Power Stations," NRC:

Washington, D.C., November 1982.

A--, NUREG/CR-2919, "XOQDOQ Program for the Meteorological Evaluation of Routine

Effluent Releases at Nuclear Power Stations," NRC: Washington, D.C., September 1977.

----- , NUREG/CR-3759, "Lightning Strike Density for the Contiguous United States from

Thunderstorm Duration Records," NRC: Washington, D.C., May 1984.

---- , NUREG/CR-4013, "LADTAP II - Technical Reference and User Guide," April 1986.

-----, NUREG/CR-4653, "GASPAR II - Technical Reference and User Guide," March 1987.

-----, NUREG/CR-6372, "Recommendations for Probabilistic Seismic Hazard Analysis:

Guidance on Uncertainty and Use of Experts," NRC: Washington, D.C., November 1997.

C-8

l l l 1
Regulatory Guides ,

Regulatory Guide 1.3, Revision 2, "Assumptions Used for Evaluating the Potential

Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors," NRC:

Washington, D.C., June 1974. (ADAMS Accession No. ML003739601).

Regulatory Guide 1.5, "Assumptions Used for Evaluating the Potential Radiological

Consequences of a Steam Line Break Accident for Boiling Water Reactors," NRC:

Washington, D.C., March 1971. (ADAMS Accession No. ML003739923).

-----, Safety Guide 23, "Onsite Meteorological Programs," NRC: Washington, D.C., February

1972. (ADAMS Accession No. ML020360030). --

Safety Guide 23, Proposed Revision 1, 'Onsite Meteorological Programs," NRC:

Washington, D.C., September 1980.

Safety Guide 24, "Assumptions Used for Evaluating the Potential Radiological

Consequences of a Pressurized Water Reactor Radioactive Gas Storage Tank Failure," NRC:

Washington, D.C., March 1972.

Regulatory Guide 1.25 (Safety Guide 25), "Assumptions Used for Evaluating the Potential

Radiological Consequences of a Fuel Handling Accident in the Fuel Handling and Storage

Facility for Boiling and Pressurized Water Reactors," NRC- Washington, D.C., March 1972.

(ADAMS Accession No. ML003769781).

Regulatory Guide 1.27, Revision 2, uUltimate Heat Sink for Nuclear Power Plants," NRC:

Washington, D.C., January 1976. (ADAMS Accession No. ML003739969).

-----, Regulatory Guide 1.28; Revision 3, "Quality Assurance Program Requirements (Design

and Construction)," NRC: Washington, D.C., August 1985. (ADAMS Accession

No. ML003739981).

-----, Regulatory Guide 1.29, Revision 3, "Seismic Design Classification," NRC: Washington, D.C., September 1978. (ADAMS Accession No. ML003739983).

-----, Regulatory Guide 1.33, Revision 2, "Quality Assurance Program Requirements

(Operation)," NRC: Washington, D.C., February 1978. (ADAMS Accession

No. ML003739995). -

, Regulatory Guide 1.38, Revision 2, "Quality Assurance Requirements for Packaging,

Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants,"

NRC: Washington, D.C., May 1977. (ADAMS Accession No. ML003740057).

-----, Regulatory Guide 1.59, Revision 2, "Design Basis Floods for Nuclear Power Plants," NRC:

Washington, D.C., August 1977. (ADAMS Accession No. ML003740388).

,Regulatory Guide 1.70, Revision 3, "Standard Format and Content of Safety Analysis

Reports for Nuclear Power Plants - LWR Edition," NRC: Washington, D.C., November 1978.

(ADAMS Accession Nos. ML003740072, ML003740108, & ML003740116).

C-9
a~~ I

Regulatory Guide 1.76, "Design Basis Tornado for Nuclear Power Plants," NRC:

Washington, D.C., April 1974. (ADAMS Accession No. ML003740273).

Regulatory Guide 1.77, "Assumptions Used for Evaluating a Control Rod Ejection Accident

for Pressurized Water Reactors," NRC: Washington, D.C., May 1974. (ADAMS Accession

No. ML003740279). -

-----, Regulatory Guide 1.78, Revision 1, "Evaluating the Habitability of a Nuclear Power Plant

Control Room During a Postulated Hazardous Chemical Release," NRC: Washington, D.C.,

December 2001. (ADAMS Accession No. ML01 3100014).

-----, Regulatory Guide 1.88, Revision 2, "Collection, Storage, and Maintenance of Nuclear

Power Plant Quality Assurance Records," NRC: Washington, D.C., October 1976.

-----, Regulatory Guide 1.91, Revision 1, "Evaluations of Explosions Postulated to Occur on

Transportation Routes Near Nuclear Power Plants," NRC: Washington, D.C., February 1978.

(ADAMS Accession No. ML003740286).

Regulatory Guide 1.102, Revision 1, "Flood Protection for Nuclear Power Plants," NRC:

Washington, D.C., September 1976. (ADAMS Accession No. ML003740308).

-----, Regulatory Guide 1.109, Revision 1, "Calculation of Annual Doses to Man from Routine

Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50,

Appendix]l," NRC: Washington, D.C., October 1977. (ADAMS Accession No. ML003740384).

-----, Regulatory Guide 1.111, Revision 1, uMethods for Estimating Atmospheric Transport and

Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors,"

NRC: Washington, D.C., July 1977. (ADAMS Accession No. ML003740354).

-----, Regulatory Guide 1.112, "Calculation of Releases of Radioactive Materials in Gaseous

and Liquid Effluents from Light-Water-Cooled Power Reactors," NRC: Washington, D.C., May

1977. (ADAMS Accession No. ML003740361).

----- , Regulatory Guide 1.113, Revision 1, "Estimating Aquatic Dispersion of Effluents from

Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," NRC:

Washington, D.C., April 1977. (ADAMS Accession No. ML003740390).

-----, Regulatory Guide 1.125, Revision 1, "Physical Models for Design and Operation of

Hydraulic Structures and Systems for Nuclear Power Plants," NRC: Washington, D.C., October

1978. (ADAMS Accession No. ML003739388).

-----, Regulatory Guide 1.132, Revision 1, "Site Investigations for Foundations of Nuclear Power

Plants," NRC: Washington, D.C., March 1979. (ADAMS Accession No. ML003740350).

-----, Regulatory Guide 1.138, "Laboratory Investigations of Soils for Engineering Analysis and

Design of Nuclear Power Plants," NRC: Washington, D.C., April 30,1978. (ADAMS Accession

No. ML003740184).

C-10
-, Regulatory Guide 1.145, Revision 1, "Atmospheric Dispersion Models for Potential

Accident Consequence Assessments at Nuclear Power Plants," NRC: Washington, D.C.,

February 1983. (ADAMS Accession No; ML003740205).

-----, Regulatory Guide 1.165, "Identification and Characterization of Seismic Sources and

Determination of Safe-Shutdown Earthquake Ground Motion," NRC: Washington, D.C., March

1997. (ADAMS Accession No. ML003740084).

Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design

Basis Accidents at Nuclear Power Reactors," NRC: Washington, D.C., July 2000. (ADAMS

Accession No. ML003716792).

Regulatory Guide 1.198, "Procedures and Criteria for Assessing Seismic Soil Liquefaction

at Nuclear Power Plant Sites," NRC: Washington, D.C., November 2003. (ADAMS Accession

No. ML033280143).

-----, Regulatory Guide 4.2, Revision 2, 'Preparation of Environmental Reports for Nuclear

Power Stations," NRC: Washington, D.C., July 1976. (ADAMS Accession No. ML003739519).

----- , Regulatory Guide 4.4, "Reporting Procedure for Mathematical Models Selected to Predict

Heated Effluent Dispersion in Natural Water Bodies," NRC: Washington, D.C., May 1974.

(ADAMS Accession No. ML003739535).

-----, Regulatory Guide 4.7, Revision 2, "General Site Suitability Criteria for Nuclear Power

Stations," NRC: Washington, D.C., April 1998. (ADAMS Accession No. ML003739894).

NRC Letters

-----, May 6, 2003, Letter from James E. Lyons, NRC to Joseph D. Hegner, Dominion Energy,

Inc., Subject: Nuclear Regulatory Commission (NRC) Guidance on Addressing Security

Measures in the early site permit (ESP) at the North Anna site. (ADAMS Accession

No. ML030980003).

Other NRC Documents

---- , "Order for Interim Safeguards and Security Measures for - North Anna Power Station,

Units 1 & 2," February 25, 2002. (ADAMS Accession No. ML020510635).

NRR Review Standard, RS-002, "Processing Applications for Early Site Permits," NRC:

Washington, D.C., May 3,2004. (ADAMS Accession No. ML040700236).

"Dominion Nuclear North Anna, LLC, NRC Inspection of Applicant and Contractor Quality

Assurance Activities Involved with Preparation of the Application for an Early Site Permit,

Report 05200008/2003001," January 12, 2004. (ADAMS Accession No. ML040150170).

C-1I
Virginia Electric and Power Company

"North Anna Independent Spent Fuel Storage Installation Final Safety Analysis Report,"

Revision 3, Virginia Electric and Power Company: Richmond, Virginia, June 25, 2002.

"North Anna Power Station Units I & 2 Updated Final Safety Analysis Report Revision 38,"

Virginia Electric and Power Company: Richmond, Virginia, September 24, 2002.

"North Anna Power Station Emergency Plan," Revision 28, Virginia Electric and Power

Company: Richmond, Virginia, July 1, 2003.

"Supplemental Geologic Data," Virginia Electric and Power Company: Richmond, Virginia,

August 17, 1973. (PDR Microform Address 50406-76).

Other References

Corporate Authors

Bechtel Corporation, Bechtel Nuclear Quality Assurance Manual, Revision 4, November 1, 2002

(ADAMS Accession No. ML042290099).

Dominion Energy, Inc., Bechtel Document Number 24830-001-GQP-GAQ-00001 -001, "Quality

Assurance Program Plan (QAPP)," North Anna Early Site Permit Project, 2003. (ADAMS

Accession No. ML042290094).

Dominion Virginia Power and Teledyne Brown Engineering Services, "Radiological

Environmental Monitoring Program, 2001 Annual Report, North Anna Power Station," Dominion

Virginia Power: Richmond, Virginia, 2001.

Flow Science, Incorporated., "Flow-3D User's Manual," Flow Science, Inc.: Santa Fe, NM,

2003.

Innovative Emergency Management, Inc., 1EM/TEC01-220, "Evacuation Time Estimates for the

North Anna Power Station and Surrounding Jurisdictions," IEM, Inc: Baton Rouge,

November 2, 2001.

Medical College of Virginia Hospitals/Virginia Commonwealth University (MCVHNCU),

"Radiation Emergency Plan-Virginia Power," MCVHNCU: Richmond, Virginia, February 16,

2000. (ADAMS Accession No. 041190477).

Platts, "POWERmap," Platts: Boulder, Colorado, 2004.

Individual Authors

Bakun, W. H. and M. G. Hopper, "The 1811-1812 New Madrid, Missouri, and the 1886

Charleston, South Carolina Earthquakes," Bulletin of the Seismological Society of America,

Vol. 94, No. 1, pp. 64-75, 2004.

C-12

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Bierschwale, J. G. and K. H. Stokoe, Geotechnical Engineering Report GR-84-15, "Analytical

Evaluation of Liquefaction Potential of Sands Subjected to the 1981 Westmoreland

Earthquake," Civil Engineering Department, University of Texas: Austin, Texas, 1984.

Bouwer, H. and R. C. Rice, "A Slug Test Method for Determining Hydraulic Conductivity of

Unconfined Aquifers with Completely or Partially Penetrating Wells," Water Resources

Research, Vol. 12, No. 3, pp. 423-428,1976.

Bowles, J. E., Foundation Analysis and Design, Third Edition, McGraw-Hill Book Company:

New York, 1982.

Bradford, S., uNumerical simulation of surf zone dynamics," Journal of Waterway, Port, Coastal,

and Ocean Engineering, Vol. 126, No.1, 2000.

Chow, V. T., Handbook of Applied Hydrology, McGraw-Hill: New York, 1964.

Chow, V. T., Open Channel Hydraulics, McGraw-Hill: New York, 1959.

Chapman, M. C., and F. Krimgold, Seismic Hazard Assessment for Virginia, Virginia Tech

Seismological Observatory, Department of Geological Sciences: Blacksburg, Virginia, February

1994.

Chapman, M. C., et al., "A Statistical Analysis of Earthquake Focal Mechanisms and Epicenter

Locations in the Eastern Tennessee Seismic Zone," Bulletin of the Seismological Society of

America, Vol. 87, No. 6, pp. 1522-1536,1997.

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Earthquakes, National Academy Press: Washington, D.C., 1985.

Davie, J. R. and M. R. Lewis, "Settlement of Two Tall Chimney Foundations," Proceedings,

Second lntemational Conference on Case Histories in Geotechnical Engineering, St. Louis,

Missouri, June 1988.

Heaps, N. S., uVertical structure of current in homogenous and stratified waters,", Ed. K. Hutter,

Hydrodynamics of Lakes, pp.153-207, Springer Verlag: New York,1984.

Hirt, C. and B. Nichols, "Volume of Fluid (VOF) Method for the Dynamics of Free Boundaries,"

Journal of Computational Physics, Vol. 39.-pp.-201-255, 1981.

Ho, E. and E. E. Adams, "Final Calibration of the Cooling Lake Model for North Anna Power

Station," Report No. 295, Ralph M. Parsons Laboratory, Aquatic Science and Environmental

Engineering, Department of Civil Engineering, Massachusetts Institute of Technology:

Cambridge, MA, August 1984.

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Review, pp. 319-339, September 1961. - -

C-13
Johnston, A. C., "Seismic Moment Assessment of Earthquake in Stable Continental Regions -

III. New Madrid 1811-1812, Charleston 1886 and Lisbon 1755," Geophysical Journal

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Kramer, S. L., Geotechnical Earthquake Engineering. Prentice-Hall, Inc.: Upper Saddle River,

NJ, 1996.

Linsley Jr., R. K., M. A. Kohler, and J.L.H. Paulhus, Hydrology for Engineers, Third Edition,

McGraw-Hill: New York, 1982.

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Eastern United States," The International Journal of the Tsunami Society, Vol. 20, No. 3, 2002.

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Carolina Coastal Plain from an Examination of River Morphology and Elevation Data," Geology,

Vol. 21, pp. 651-654,1993.

Martin, J. R. And R. J. Fragaszy, "Soil Failure/Liquefaction Susceptibility Analysis for North

Anna Power Station Seismic Margin Assessment," Report by Geotechnics for Virginia Power

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Central Virginia During the Late and Middle Holocene Time [abs]," Eos Transactions of the

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C-14
Pratt, T. L., C. Coruh, and J. K. Costain, "A Geophysical Study of the Earth's Crust in Central

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C-15
APPENDIX D

PRINCIPAL CONTRIBUTORS

Name Responsibility

Anand, Raj

Araguas, Christian

Bagchi, Goutam

Campe, Kazimieras

Harvey, Robert B.

Klementowicz, Stephen

Lee, Jay

Munson, Cliff

Musico, Bruce

Pichumani, Raman

Prescott, Paul

Scott, Michael

Segala, John

Sosa, Belkys

Tardiff, Albert

Project Management

Project Management

Hydrology

Site Hazards

Meteorology

Normal Radiological Dose Analyses

Accident Analyses

Geology and Seismology

Emergency Planning

Geotechinical Engineering

Quality Assurance

Project Management

Project Management

Project Management

Security

Contractors Technical Area

Federal Emergency Management Agency

Pacific Northwest National Laboratory

U.S. Geologic Survey

Emergency Planning

Hydrology, Meteorology, and Site Hazards

Geology and Seismology

D-1
APPENDIX E

REPORT BY THE ADVISORY COMMITTEE ON REACTOR

SAFEGUARDS

UNITED STATES

NUCLEAR REGULATORY COMMISSION

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS ACRSR-2141

WASHINGTON. DC 20666 -0001

July 18. 2005

The Honorable Nils J. Diaz

Chairman

U.S. Nuclear Regulatory Commission

Washington. D.C. 20555-0001

SUBJECT: DOMINION NUCLEAR NORTH ANNA, LLC, EARLY SITE PERMIT

APPLICATION AND THE ASSOCIATED NRC FINAL SAFETY EVALUATION

REPORT

Dear Chairman Diaz:

During the 524u' meeting of the Advisory Committee on Reactor Safeguards, July 6-8. 2005. we

met with representatives of the NRC staff and Dominion Nuclear North Anna, LLC (Dominion)

and discussed the final safety evaluation report of the Dominion application for the North Anna

early site permit (ESP). Our reviews of the application and the staff's safety evaluation report

were conducted to fulfill the requirement ofl10 CFR 52.23, which states that the ACRS shall

report on those portions of an early site permit application that concern safety. We had the

benefit of the documents referenced.

CONCLUSIONS

* The proposed site, subject to the permit conditions recommended by the NRC staff, can

be used for up to two nuclear power units each of up to 4300 MWth without undue risk to

the public health and safety. I-

* The staffs final safety evaluation report of the Dominion early site permit application will

contribute to the documentary basis for the mandatory public hearing concerning the

proposed early site permit.

DISCUSSION

Dominion has submitted a first-of-a-kind application for an early site permit pursuant to the

requirements of Subpart A, 'Early Site Permits," of 10 CFR Part 52. The proposed site is

entirely within the current North Anna Power Station site about 40 miles north-northwest of

Richmond, Virginia. Years ago, this site was approved for four units, but only two units (

3 -loop

Westinghouse pressurized water reactors) were constructed. Both of these units are now

operating.

The Dominion application Is to locate up to two nuclear power units on the proposed site. Each

unit is to have a power of up to 4300 MWt.. The Dominion application is based on a set of

conservative, enveloping parameters defined to allow flexibility in the selection of reactor

technology should a decision be made in the future to actually develop the site.

E-1
.~~ I

Nature of the Proposed Site

The vicinity of the proposed site is rural in nature. There are no significant industrial.

transportation, or military facilities within five miles of the site center. The major water sources

available to the site are the North Anna river and an artificial lake adjacent to the site. The dam

for this lake is under the control of the applicant. The applicant has recognized that water

availability may be insufficient for two water-cooled units and proposes air cooling for one unit

on the proposed site. The staff proposes that this be made a permit condition.

* Population in the Vicinity of the Site

The permanent population around the site is quite low. The nearest population center. Mineral.

Virginia. has a population of less than 500. The nearest significant cities are Fredericksburg (projected year 2065 population 20,950) at a distance of 22 miles, Charlottesville (year 2000

population 45,069) at 36 miles. and Richmond (year 2000 population 197.790) at 40 miles. The

applicant used methods found acceptable by the staff to show that projected populations in the

vicinity of the site through the year 2065 will still be within acceptable limits.

* Geology and Seismicity of the Site

The proposed site will have reactors founded on hard rock. Dominion has undertaken a

thorough effort to update geologic and seismic information concerning the site and has made

use of methods that are new since the construction of reactors now operating on the North

Anna site to characterize the proposed site. The staff has approved these analyses as they

have been amended in four revisions of the initial application. Because of the hard rock

foundations, reactors on the site would be subject to significant seismically-induced

accelerations at frequencies in excess of 10 Hz. Dominion originally proposed to use a new

performance-based method described in its application to derive a safe shutdown earthquake

spectrum that bounds what was determined by the staff using its own methods. The staff has

not endorsed the proposed performance-based applicant's methods. Dominion has ultimately

elected to use the staff's method as identified in Regulatory Guide 1.165. The staff concurs

with conclusions reached by the applicant.

Meteorology

The applicant has done a thorough examination of historical meteorological data to set design constraints for such things as maximum rainfall, wind velocities, snow pack and temperature

extremes. The staff has found these findings to be acceptable. The design constraints posed

by the proposed site meteorology are not severe in comparison to design parameters for

candidate reactor technologies considered in the development of the early site permit

application.

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-3-

Potential Radionuclide Releases

For the studies of radiological source terms at the proposed site, Dominion has selected two

advanced reactors that could be located on the site. These example plants (AP1000 and the

Advanced Boiling Water Reactor) have very low predicted core damage frequencies relative to

those predicted for the extant plants on the North Anna site. Dominion has used staff-approved

methods to deduce that consequences of radionuclide release at the proposed site will be less

than considered In the applications forthe design certifications of the example plants. The staff

has verified these conclusions with its own evaluations.

Emergency Plans

The applicant has elected to submit for review Just the 'major features' of emergency planning for the proposed site as Is allowed by the regulations. The staff has found these major features

to be acceptable and concludes that the proposed site does not pose significant impediments to

the development of adequate emergency plans should a decision be made to develop the site.

The staff has Identified a number of items that are treated either as permit conditions or as

actions that must be addressed at the combined license (COL) stage. The staff has developed

criteria to Identify permit conditions. Permit conditions are recommended by the staff when:

* evaluations of the site rest on an assumption that can be justified only after a site

permit has been Issued.

* a physical attribute exists for the site that is not acceptable for the design of

systems, structures and components important to safety, or

* evaluations can be completed only after some future act has taken place.

We conclude that these are appropriate criteria for the Imposition of permit conditions.

The staff has prepared a high-quality, detailed, yet readable. safety evaluation report on the

Dominion application. All open items have been resolved. The staff concludes that the site is

adequate for the proposed use subject to eight permit conditions.

The staff has also identified 30 items that need to be considered in conjunction with reviews of

a COL application should the early site permit be granted and a decision to develop the site be

made.

E-3
I a

-4.

We concur with the'staff's conclusions concerning the Dominion application for an early site

permit This first use of the early site permit process has revealed several areas where the

process can be refined and streamlined. We look forward to working with the staff to improve

the early site permit process.

Sincerely.

IRA/

Graham B. Wallis

Chairman

References:

1. U.S. Nuclear Regulatory Commission, Final Safety Evaluation Report. 'Safety

Evaluation of Early Site Permit Application in the Matter of Dominion Nuclear North

Anna. LLC, for the North Anna Early Site Permit', June 16. 2005;

2. North Anna Early Site Permit Application. Revision 3. September 2004. NRC Docket No.

51-008.

3. U.S. Nuclear Regulatory Commission, Review Standard. RS-002. "Processing

Applications for Early Site Permit Applications'. May 3, 2004.

4. Memorandum from Luis A. Reyes. NRC Executive Director for Operations, to Graham

B. Wallis, Chairman, ACRS. Subject: Interim Letter Draft Safety Evaluation Report on

North Anna Early Site Permit Application, dated June 3, 2005.

5. U.S. Nuclear Regulatory Cormrnission, Regulatory Guide 1.165. Identification and

Characterization of Seismic Sources and Determination of Safe Shutdown Earthquake

Ground Motion." dated March 1997.

E-4
NRC FORM 335 US. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers. If any.)

BIBLIOGRAPHIC DATA SHEET

(See istrucfions on the reverse) NUREG-1 835

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Safety Evaluation Report for an MONTH YEAR

Early Site Permit (ESP) at the

North Anna ESP Site September2005

4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Indfuse Dates)

B. PERFORMING ORGANIZATION - NAME AND ADDRESS (It NRC provide Dvision Offte or Region. U.S. Nuclear Regulatory Commission and maing address: . contracor.

provide narme and making address.)

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (ItNIC. tye Same as aove-;icontractor.provvideRCDivkhn. OftfeorF~eplon. US. NucfearflegulatoryCormmissibn,

and mafrit address.)

Same as above

10. SUPPLEMENTARY NOTES

Docket No. 52-008, Proiect No. 719

11. ABSTRACT (200 words or less)

This safety evaluation report (SER) documents the U.S. Nuclear Regulatory Commission (NRC) staffs technical review of the

site safety analysis report and emergency planning information included in the early site permit (ESP) application submitted by

Dominion Nuclear North Anna, LLC (Dominion or the applicant), for the North Anna ESP site. By letter dated September 25,

2003, Dominion submitted the ESP application for the North Anna ESP site in accordance with Subpart A, 'Early Site Permits,"

of Title 10, Part 52, 'Early Site Permits; Standard Design Certifications; and Combined Ucenses for Nuclear Power Plants," of

the Code of Federal Regulations.

The North Anna ESP site is located approximately 40 miles north-northwest of Richmond, Virginia, and is adjacent to two

existing nuclear power reactors operated by Virginia Electric and Power Company, which, like Dominion Nuclear North Anna,

LLC, is a subsidiary of Dominion Resources, Inc. In its application, Dominion seeks an ESP that could support a future

application to construct and operate one or more additional nuclear power reactors at the ESP site, with a total nuclear

generating capacity of up to 8600 megawatts (thermal). This SER presents the results of the staffs review of information

submitted in conjunction with the ESP application. The staff has identified, in Appendix A to this SER, certain site-related items

that will need to be addressed at the combined license or construction permit stage, should an applicant desire to construct one

or more new nuclear reactors on the North Anna ESP site. Appendix A to this SER also identifies the proposed permit

conditions that the staff recommends the Commission impose, should an ESP be issued to the applicant.

12. KEY WORDSIDESCRIPTORS (List words orphrases that wiftassistresearchers in locating the report) 13. AVAILABILITY STATEMENT

Early Site Permit (ESP) unlimited

Combined License (COL) 14. SECURITY CLASSIFICATION

Permit Conditions (This Page)

COL Action Items unclassified

Site Characteristics (This Report)

Bounding Parameters unclassified

North Anna ESP Site

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (9-2004) PRINTED ON RECYCLED PAPER
HIIl

Federal Recycling Program
UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS