JJooiinntt PPeerrmmiitt AApppplliiccaattiioonn ffoorr aann IInnddiivviidduuaall PPeerrmmiitt PPrrooppoosseedd UUnniitt 33 NNoorrtthh AAnnnnaa PPoowweerr SSttaattiioonn MMiinneerraall,, VVAA 2233111177 LLoouuiissaa,, OOrraannggee,, SSppoottssyyllvvaanniiaa,, HHaannoovveerr,, CCaarroolliinnee,, aanndd KKiinngg WWiilllliiaamm CCoouunnttiieess,, VViirrggiinniiaa AAddddeenndduumm 11 RReessppoonnssee ttoo AAddddiittiioonnaall RReegguullaattoorryy IInnffoorrmmaattiioonn RReeqquueessttss Prepared by: EA Engineering, Science, and Technology, Inc. 15 Loveton Circle Sparks, MD 21152 Prepared for: Dominion Virginia Power 5000 Dominion Boulevard Glen Allen, VA 23060 September 2010 1 JOINT PERMIT APPLICATION FOR AN INDIVIDUAL PERMIT PROPOSED UNIT 3 NORTH ANNA POWER STATION LOUISA, ORANGE, SPOTSYLVANIA, HANOVER, CAROLINE, AND KING WILLIAM COUNTIES, VIRGINIA ADDENDUM 1 RESPONSE TO ADDITIONAL REGULATORY INFORMATION REQUESTS Prepared by: EA Engineering, Science, and Technology, Inc. Prepared for: Dominion Virginia Power September 2010 UNIT 3 NORTH ANNA POWER STATION JOINT PERMIT APPLICATION ADDENDUM 1 TABLE OF CONTENTS RESPONSE TO COMMENTS NARRATIVE ATTACHMENTS ATTACHMENT A REVISED GRID SHEETS ATTACHMENT B TABLE AND FIGURES B-1 Table 6. Permanent and Temporary Wetland and Stream Impact Details B-2 Other Referenced Figures ATTACHMENT C REVISED APPLICATION SECTIONS C-1 Revised JPA Section 2 C-2 JPA Sections 15 and 16 – Roll-Off Component of the Large Component Transport Route C-3 JPA Section 16 – Intake Structure ATTACHMENT D WETLAND AND STREAM MITIGATION D-1 Woodford Mitigation Bank Credit Availability Letter D-2 Figures D-3 Revised Form 3s ATTACHMENT E ADJACENT PROPERTY OWNER INFORMATION ATTACHMENT F RESTORATION PLAN FOR WALKERTON LANDING Dominion Virginia Power Proposed Unit 3 North Anna Power Station Mineral, Louisa County, Virginia RESPONSE TO COMMENTS In response to a letter from the Virginia Department of Environmental Quality (VDEQ) dated July 29, 2010, an email from the U.S. Army Corps of Engineers (USACE) dated July 27, 2010, and a site visit with Virginia Marine Resources Commission (VMRC) on August 19, 2010, Dominion received requests for additional information to support continued regulatory review of our Joint Permit Application (JPA) submitted to the agencies on July 16, 2010. This addendum is intended to provide the agencies with their requested information to facilitate regulatory processing of the JPA. USACE COMMENTS 1a. Please provide the names and physical locations of the facilities in which Dominion will make information available for adjacent property owner review. Name of Facility Address Phone # Location Jefferson-Madison Regional 201 E Market Street Louisa County, (434)-979-7151 Library Charlottesville, VA 22902 Virginia 881 Davis Highway Louisa County, Louisa County Public Library (540)-894-5853 Mineral, VA 23117 Virginia 7527 Library Drive Hanover County, Hanover Branch Library (804)-365-6210 Hanover, VA 23069 Virginia 146A Madison Road Orange County, Orange County Public Library Orange, VA 22960 (540)-672-3811 Virginia 2607 Salem Church Road Spotsylvania Salem Church Library (540)-785-9267 Fredericksburg, VA 22407 County, Virginia C. Melvin Snow Memorial 8740 Courthouse Road Spotsylvania (540)-507-7565 Branch Spotsylvania, VA 22553 County, Virginia North Anna Nuclear Information 1022 Haley Drive Louisa County, (540)-894-2029 Center (NANIC) Mineral, VA 23117 Virginia 1b. Is it Dominion's intention to make a copy of the Joint Permit Application available or only the public notice and drawing attachments? A complete copy of the Joint Permit Application will be available at the six libraries mentioned above, the NANIC, and Dominion’s website. Dominion will also make this Addendum #1 available at each of these public locations. See comment #3 for the website address. 2. On grid sheet 12 showing impacts for the intake structure, does "open water" refer to Lake Anna? Is it correct that the temporary cofferdam, culverts and rip rap will be placed in Lake Anna? Joint Permit Application 1 September 2010 Addendum 1 Dominion Virginia Power Proposed Unit 3 North Anna Power Station Mineral, Louisa County, Virginia Open water refers to Lake Anna on Grid Sheet 12. The temporary cofferdam, culverts, and rip-rap shown on Grid Sheet 12 will be placed in Lake Anna. A revised Grid Sheet is located in Attachment A. 3. Please see the attached notations on the Unit 3 site impacts for the printed public notice. It will not be feasible to place all drawings in the public notice itself, so it will be important to convey information about the project sufficient for commenting. Does your agency have the capacity to host a website to make attachments D- 1 and D-2 viewable electronically? If so, how would we go about accomplishing that and what would that web address be? Dominion has developed an environmental component within the existing North Anna website to make the entire JPA (including Attachment D of the JPA submitted on July 16, 2010) available for the public notice. Information on the potential third unit at NAPS can be found by visiting http://dom.com, keyword “Unit 3” or by visiting http://dom.com/about/stations/nuclear/north-anna/north-anna-3.jsp. 4. The Corps' is evaluating options to complete the printing and mailing of the public notice. You have already provided printed mailing labels, but we would like to know if it is possible for Dominion to provide an Excel or Access file with each line of the address in a separate column. For example column 1 is the NAME, 2 is the Company name (if applicable), 3 is the street address, etc. for the adjacent property owners. An electronic copy in Excel format will be provided under separate cover. For additional reference, Attachment E contains a revised version of the adjacent property owner information. VDEQ COMMENTS Large Component Transport Route Related 1. Based upon staff's review of the Joint Permit Application (JPA) in regards to proposed activities associated with the Roll-off Location at Walkerton Bridge of the Large Component Transport Route, we have the following comments: 1a. Based upon Grid No. 13, it appears that all impacts to surface waters are not accounted for in the JPA. The impacts map depicts a temporary bulkhead and cofferdam that will be placed within the Mattaponi River, but these areas are not shown as impacted. Please update the impacts table and map to depict these areas of the stream channel as being impacted. A revised impact table can be found in Attachment B-1. Revised Grid Sheets, including Grid Sheet 13, are located in Attachment A. 1b. Complete Sections 15 (Boat Ramps) and 16 [Tidal/Nontidal Shoreline Stabilization Structures Marsh Toe Stabilization, Groins, Jetties, and Breakwaters, Etc.)] for the boat ramp and cofferdam activities. Joint Permit Application 2 September 2010 Addendum 1 Dominion Virginia Power Proposed Unit 3 North Anna Power Station Mineral, Louisa County, Virginia Please see Attachment C-2 for JPA Sections 15 and 16. 1c. Explain the activities associated with the roll-on and roll-off ramp so that we can determine if the proposed activity will impact the stream channel The structures associated with the roll-off component of the Large Component Transport Route will be in place for approximately 3 years. Construction of the roll-off component will begin during the second half of 2013 and will be in use until 2017. In 2018, the location of the roll- off component will be restored to pre-construction contours. Temporary wetland and stream impacts associated with the roll-off facility are depicted in Table 6 located in Attachment B-1. A plan view and cross section of the roll-off facility shown in Grid Sheet 13, located in Attachment A. A restoration plan for the Walkerton Landing roll-off area is located in Attachment F. The general sequence of construction activities is as follows: Dominion Sheet Pile Construction Sequence: 1. Locate and mark existing utilities 2. Construct perimeter erosion and sediment controls for proposed work area and contractor staging area 3. Construct turbidity curtain 4. Locate and mark existing boating channel 5. Install shoreline protection 6. Drive sheet piles 7. Place wales, anchors and tie-rods (if necessary) 8. Drive timber pilings (exterior to sheet piles) for tying off purposes (number of pilings contingent on design) 9. Pump interior of sheet pile wall dry (intermittently) 10. Backfill interior of sheet pile wall with clean gravel in two-foot lifts 11. Construct roadway extension to tie existing road into cofferdam 12. Place steel plates over gravel 13. Remove perimeter erosion and sediment controls 14. Remove turbidity curtain Dominion Sheet Pile Restoration Sequence: 1. Locate and mark existing utilities 2. Construct perimeter erosion and sediment controls 3. Construct turbidity curtain that effectively encloses the area to be developed 4. Locate and mark existing boating channel 5. Remove steel plates 6. Excavate/remove aggregate 7. Remove wales, anchors and tie-rods. 8. Remove sheet piles 9. Remove timber piles Joint Permit Application 3 September 2010 Addendum 1 Dominion Virginia Power Proposed Unit 3 North Anna Power Station Mineral, Louisa County, Virginia 10. Restore bathymetry of river 11. Restore vegetation 12. Remove perimeter erosion and sediment controls 13. Remove turbidity curtain Materials of Construction: 1. Erosion and sediment control materials (e.g., silt fence, super silt fence, rip rap, stabilized construction entrance, turbidity curtain) 2. Heavy-gauge steel sheetpile 3. Timber piles 4. Clean aggregate backfill 1d. Temporary impacts to 115 linear feet of stream channel are listed in the impacts table and mentioned under Attachment C in the mitigation plan; however, the Narrative section of the JPA does not mention these temporary impacts. Please explain this discrepancy, the activities proposed to temporarily impact the stream channel, and revise the narrative to include a complete description of the proposed activities at this location. The design for the Large Component Transport Route has been modified since the July 16, 2010 JPA submittal as a result of the recent field SAV and bathymetry surveys. In order to accommodate a wider barge, the roll-off facility was re-designed. Temporary impacts associated with the roll-off component of the Large Component Transport Route are shown in Table 6 located in Attachment B-1. The roll-off component will temporarily impact approximately 10,577 square feet (0.24 acres) of wetlands, approximately 210 linear feet of stream channel due to a temporary cofferdam and temporary shoreline stabilization, and approximately 305 linear feet of stream channel due to timber pilings. Table 6 has been updated to depict the temporary impacts. Please see Attachment B-1 for the revised Table 6. Grid Sheet 13, located in Attachment A, depicts the roll-off facility. 2. The Large Component Transport Route proposes to cross the North Anna River just north of the bridge for Route 30. Based upon the information provided, staff is unable to determine if surface waters impacts are associated with the proposed structure that will span the river. If any portion of the spanning structure or support structures (such as riprap) is proposed to be placed within the river, these activities require authorization. Please provide a plan view of the proposed crossing and a narrative discussing the proposed activities, including the proposed length of time structures are proposed to be in-place and any actions that will be taken to restore the areas to preconstruction contours and elevations and reestablish any lost vegetation. Figure 1 in Attachment B-2 depicts the proposed bridge to cross the North Anna River. No impacts (including instream work) will occur at this crossing because no portion of the spanning structure or support structures is proposed to be placed within the North Anna River. The temporary bridge will be in place for approximately 3 years. Afterwards, the upland locations of the proposed bridge will be restored to pre-construction contours, where necessary. Joint Permit Application 4 September 2010 Addendum 1 Dominion Virginia Power Proposed Unit 3 North Anna Power Station Mineral, Louisa County, Virginia Water Intake Structure Related 3. The activities proposed with the water intake structure for Unit No. 3 appear to include riprap stabilization. Please complete Section 16 [Tidal/Nontidal Shoreline Stabilization Structures (including Bulkheads and Associated Backfill, Riprap Revetments and Associated Backfill, Marsh Toe Stabilization, Groins, Jetties, and Breakwaters, Etc.)] of the JPA for these activities at this location. Section 16 of the JPA has been completed for the proposed Unit 3 water intake structure, and is included as Attachment C-3 to this Addendum. 4. It is unclear if the proposed activities associated with the water intake structure for Unit No. 3 will result in temporary impacts to surface waters. The Narrative section of the JPA does not discuss temporary impacts; however, page 5 of the compensation plan under Attachment C of the JPA indicates temporary impacts are associated with this activity. Based upon our review of Grid No. 12, we have the following comments: 4a. On the Lake Anna side of the berm, a temporary cofferdam is proposed. Use of a cofferdam is an activity that requires authorization. Please update the impacts table and map accordingly. The cofferdam proposed at the intake structure is considered a temporary impact. Temporary impacts associated with the cofferdam include approximately 22,356 square feet (0.51 acres). Table 6 has been revised and is located in Attachment B-1. 4b. It is unclear if the area on the side of the berm opposite of Lake Anna is a surface water (i.e. open water). If this area is surface water, activities within this area require authorization. Please clarify the proposed activity and associated impacts in this location and update the impacts table and map accordingly. The USACE – Norfolk District did not take jurisdiction on the side of the berm opposite of Lake Anna. Also, VDEQ does not consider the side of the berm opposite of Lake Anna as an open water feature. Thus, the area opposite of Lake Anna is not considered a jurisdictional surface water, and compensatory mitigation is not required. The impacts associated with breaching the berm are accounted for on the Lake Anna side of the berm. Cooling Tower Location and Route 700 Parcels Related 5. Two parallel dark lines are shown on the "Wetland and Stream Impacts Grid Key Sheet" dated July 2010 to extend from existing transmission lines near Grid No. 8 to Grid No. 5 and potentially on to Grid No. 2 (extent of the lines is unclear due to change in the weight of the line drawing). Do these parallel lines represent proposed or existing overhead transmission lines? If the lines are proposed, will non-impacted surface waters crossed by these lines be impacted? For instance, if the systems are palustrine forested wetlands, will trees be cut? If so, conversion of a wetland is a permanent impact that requires authorization and compensation. Joint Permit Application 5 September 2010 Addendum 1 Dominion Virginia Power Proposed Unit 3 North Anna Power Station Mineral, Louisa County, Virginia The parallel lines represent existing overhead transmission lines. The line weights in the Grid Sheets have been made consistent throughout. The set of revised Grid Sheets are located in Attachment A. Compensation Related 6. The compensation plan proposes to purchase credits from two approved mitigation banks, one of which is New Kent Environmental Bank. Portions of the impact sites located within Louisa County are outside of the service area for this bank. DEQ staff initiated coordination on your staff's behalf with the Interagency Review Team (IRT) during the pre-application stage of this project on October 19, 2009. Staff was informed by email received November 10, 2009, that the request for out-of-service area approval was denied and this decision was provided to your staff on the same date. DEQ staff has not received more recent correspondence indicating a reversal of the IRT's decision. If written IRT approval has been obtained, please submit this documentation. If not, please propose another approved mitigation bank as the second bank proposed, Woodford Mitigation Bank, does not have sufficient stream credits available to meet the project's needs. Woodford Mitigation Bank is in the process of obtaining additional stream credits that will service the Unit 3 project area. A revised Credit Availability Letter (dated 9 September 2010) is located in Attachment D-1. Dominion proposes to purchase all necessary wetland and stream credits from Woodford Mitigation Bank. If mitigation requirements cannot be completely satisfied with Woodford Mitigation Bank, Dominion proposes to satisfy the remaining compensation requirements through a trust fund. 7. Preservation of surface waters is proposed as a component of the stream compensation plan presented under Attachment C of the JPA. In accordance with 9 VAC 25-2 10- 80.B.k(5)(c), please provide draft deed restriction language. Note that DEQ accepts the draft language used by the U.S. Army Corps of Engineers (USACE); however, the language should reflect the following: 7a. It shall be written so that no activity will be performed on the property in any area designated as a compensation site or non- impacted surface water, with the exception of maintenance or corrective action measures authorized by DEQ. 7b. Unless otherwise authorized by DEQ, the restrictions apply to ditching, land clearing, or the discharge of dredge or fill material. The language shall include in the restricted activities the specific phrase "ditching, land clearing, or discharge of dredge or fill material." WHEREAS, (_________) is the owner of the Property more fully described on Exhibit A attached hereto; and, Joint Permit Application 6 September 2010 Addendum 1 Dominion Virginia Power Proposed Unit 3 North Anna Power Station Mineral, Louisa County, Virginia WHEREAS, (_________) desires to impose on said Property restrictive covenants expressing (_________) 's intent to preserve ______acres of said property as shown on Exhibit B and as described as _____ stream channels totaling _____ linear feet with associated 200-foot riparian buffer areas subject to restrictive covenants (e.g. “wetlands subject to restrictive covenants”) in perpetuity in its natural state as detailed below. These covenants are imposed by Owner freely and voluntarily, in order to assure that the aquatic impacts pursuant to permit #_______ shall be minimal. NOW THEREFORE THIS DECLARATION WITNESSETH: (___________) does hereby declare, covenant and agree, for itself and its successors and assigns, that said Property described as ________________ shown on Exhibit B shall be hereafter held, leased, transferred, and sold subject to the following conditions and restrictions which shall run with the land and be binding on all parties and persons claiming under them. Covenants and Restrictions. The Property described as ___________ shown on Exhibit B attached hereto shall be preserved in perpetuity in its natural state, by prohibiting the following activities: 1. Destruction or alteration of the preservation area shown on Exhibit B with the exception of maintenance or corrective action measures or other alterations authorized by the Norfolk District, U.S. Army Corps of Engineers (USACE) and/or the Virginia Department of Environmental Quality (DEQ) under Permit Number _________; 2. Construction, maintenance or placement of any structures or fills including but not limited to buildings, mobile homes, fences, signs other than those which currently exist. (OPTIONAL EXCEPTION: However, boardwalks, wildlife management structures, observation decks, one informative sign, and unpaved foot trails may be placed within the preservation area provided that any such structure permits the natural movement of water and preserves the natural contour of the ground and subject to prior written approval by the USACE and/or DEQ); 3. Ditching, draining, diking, damming, filling, land clearing, excavating, grading, plowing, flooding/ponding, mining, drilling, placing of trash and yard debris or removing/adding topsoil, sand, or other materials or the discharge of dredge or fill material (except as may be necessary on a case-by-case basis with prior written approval by USACE and/or DEQ); 4. Cultivating, harvesting, cutting, logging, planting, and pruning of trees and plants, or using fertilizers and spraying with biocides (except as may be necessary on a case-by- case basis with prior approval by USACE and/or DEQ); Amendment The covenants contained herein shall not hereafter be altered in any respect without the express written approval and consent of the Owner or its successor in interest and the USACE and DEQ. The Owner or its successor may apply to the USACE and DEQ for vacation or modification of this declaration; however, after recording, these restrictive covenants may only Joint Permit Application 7 September 2010 Addendum 1
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