August 18, 2005
Mr. Jack Cushing & Ms. Rani Franovich
Environmental Project Managers for North Anna ESP Site Application
U.S. Nuclear Regulatory Commission, Washington D.C. 20555
(Via Fax) (301) 415-2002 & Email to JXC9@NRC.GOV & RLF2@NRC.GOV
Nuclear North LLC Application for the North Anna ESP Site
Dear Mr. Cushing,
We are writing to request your help in addressing several safety and
health concerns we have about the proposed expansion of Dominion Resources North
Anna nuclear power which affects Lake Anna.
These concerns are outlined in the attached letter written to Mrs. Ellie
Irons, Environmental Impact Review Program Manager for the Commonwealth of
We realize that the public comment period has ended, however these
concerns were triggered by a July 30, 2005 briefing by Dr. Judson White
(Dominionís Environmental Policy Manager) to the Lake Anna Civic Association
and left many questions and no firm answers.
This in turn, triggered many follow-up discussions with various Dominion
representatives to get specific confirmation of facts in their ESP request,
including Mr. Tony Banks (Dominionís ESP Program Manager). Dominion briefed current water temperatures that are not
consistent with those we experience while living on the lake, which also raised
concerns about the health and safety of humans, fish, and wildlife that use the
lake, together with water flow concerns.
It also triggered conferences with the following Virginia departments
with primary reference to the Waste Heat Treatment Facility (WHTF), also known
as the warm side or public side:
The Department of Game and Inland Fisheries plays two different roles
(private pond and public body of water)
The local State Health Department officials in Louisa indicate they do
not check on the water health/safety or water temperatures that may affect the
people using Lake Anna.
The Virginia Department of Environmental Quality officials indicate they
also treat the warm side as a private pond.
They look at it similar to a sewage treatment facility, where what
happens within the facility is Dominionís concern and they will monitor what
comes out of the warm side (WHTF) at the third dike.
This then begs the question Ė who in the federal and state government
is looking out for the interests (human, fish, wildlife) for the thousands of
landowners and millions of dollars invested on the land that surrounds the 200
plus miles on the shoreland of Lake Anna?
Please call if we can be of any further assistance.
We will look forward to your kindly consideration of our concerns (as
stated on attached memo) as you process Dominionís ESP and your response.
Harry Ruth for the Board of Director
Ruth Estates Property Owners Association
C/O 230 Heather Drive, Bumpass, Va. 23024 Ė ph (540)-872-3632
17 Aug 05 letter to Mrs. Ellie Irons, Environmental Review Program Manager
CC: Mrs. Ellie Irons, Virginia Environmental Review Program Manager (via fax 804-698-4319)
17 August 2005
Mrs. Ellie Irons, Environmental Impact Review Program
Virginia Department of Environmental Quality
629 East Main Street
Richmond, VA 23219
Dear Ms. Irons:
We request your help in addressing several concerns we have about the
proposed expansion of Dominion Resourcesí North Anna nuclear power plant which
affects Lake Anna. Lake Anna is
Virginiaís 3rd largest lake and a major recreational resource. Many communities (with thousands of landowners) have been
built on the 200 plus mile shoreline. Our
health and safety concerns are related to (1) the expected increase in the water
temperature and (2) the increased water flow through the plant.
Our properties are on the waste heat treatment facility (WHTF) containing
approximately 3,500 acres of water (also called the warm side or private side of
Lake Anna) and apply mostly to that part of the lake; however, the other part of
the lake (cool side, public side) could also be adversely affected.
We have no problem with the general idea of expanding the plant; our
concerns are that the current proposal would adversely affect our use of the
lake and our property. In addition,
the proposal would also affect the fish and wildlife that also use the lake.
We believe conditions need to be added to Dominionís permit to prevent
these adverse effects.
It has been stated that Dominion owns the warm side (WHTF) and should be
allowed to do anything to this part of the lake it wants.
We believe this statement is not valid.
If Dominion wanted complete freedom to do whatever it wanted with the
waste heat treatment facility, it should not have allowed anyone else to have
access to this part of the lake.
Dominion long ago (30 plus years) decided to allow nearby property owners
complete access to the waste heat treatment facility and should not now be
allowed to take actions which will have serious adverse consequences for these
property owners, fish, birds, wildlife, etc.
Parts of the warm side (WHTF) are
currently experiencing water temperatures over 104 F. This is occurring in the Aspen Hill subdivision, which is the
community nearest the power plantís discharge canal. Hot tub manufacturers warn that the water in the hot tub
should not exceed 104 F because higher temperatures can place a dangerous strain
on the cardiovascular system. They
also warn that people with a medical history of heart disease, circulatory
problems, diabetes, and high blood pressure and pregnant women should consult a
physician before using a hot tub.
We understand that Dominion has requested approval for water being
discharged from the plant to reach as hot as 113 F for the 3rd
reactor. Dominion also plans a 60
percent increase (approximately 1.2 million gallons per minute additional) in
the volume of water being discharged. These
changes could make large parts of the lake unusable by humans for the portions
of the year when most people expect to use the lake the most (during the summer
months), as described below.
(Increase in water
temperatureís up to 113 F concerns)
1. The average temperature increase for the warm side (WHTF) could be about 5 F. The water might not cool as much because it would be moving faster with the increased flow. Water above 104 F is probably not healthy for humans.
2. These high temperatures would seem more friendly to bacterial growth and associated health problems to humans, fish, wildlife..
3. Dominion measures water temperatures about 1 meter (39 inches) below the surface. Humans, birds, and other animals are mostly above this depth where the temperatures are higher. The reporting of this temperature by Dominion may not consider the publicís health..
4. Additional fish could be killed. We observed over 1,000 dead fish on lagoon 1 in July 2005.
5. Harm to wildlife (birds Ė(bald eagle/protected species), deer, beaver, etc. who use the lake.
in water flow rate concerns)
6. The water level on the waste heat treatment facility could rise significantly.
a. Currently (with 2 reactors), the waste heat treatment facility water level lowers 7 inches when the plantís circulation pumps are shut off and rises 7 inches when they are turned on.
All current boat houses, piers, sea walls, etc. are sized to the current level on the cooling lagoon.
b. It would appear that if a 60% increase in flow rate is achieved, this would increase the water level during the cooler months.
c. A few inches increase could result in putting many decks of boat houses, piers, and sea walls under water causing much property damage.
During the summer months, the increase temperature and flow would create
much more evaporation, which could actually lower the lake level and possibly
cause some areas to have no water (similar to a drought condition).
(Additional Impacts) All
of these factors could result in a major loss of property values and the
associated loss of taxes to local government.
If a health warning ever had to be issued because of the factors
described above, property values would plummet quickly for all of Lake Anna and
the recreational use of one of Virginiaís finest resources could be
We have tried, unsuccessfully, to
have our concerns addressed by various Commonwealth of Virginia and federal
agencies, as described below. These
unsuccessful attempts have made us wonder who is looking out for our interests.
4. The Department of Game and Inland Fisheries plays two different roles. The state biologist indicates they treat the warm side as a private pond, even though there are over a thousand landowners and fisherman here. They do not monitor the fish population or fish kills, rather relying on Dominion Power to monitor this. However the Law Enforcement section patrols the lake for boating violations, fishing licenses, and water marker enforcement.
5. The local State Health Department officials in Louisa indicate they do not check on the water health/safety or water temperatures affecting people using Lake Anna. They focus on wells, sewage permits, major health outbreaks, etc.
6. The Virginia Department of Environmental Quality officials indicate they also treat the warm side as a private pond. They look at it similar to a sewage treatment facility, where what happens within the facility is Dominionís concern and they will monitor what comes out of the warm side (WHTF) at dike 3.
The Federal Nuclear Regulatory Commission is concerned mainly with the
safety of the nuclear materials and associated equipment and relyís on
Virginia for water usage, health &, safety issues.
Dominion has been a good steward
of the lake during the past 30 years, but we want to make sure that water
temperature and water flow rate concerns, together with the related impacts, are
addressed by our Virginia government representatives. We want to insure that our lives and property are not damaged
by a possible Dominion profit motivated design decision that could affect the
warm side (WHTF) landowners, with a cascading affect to all Lake Anna property
owners and their capital investments of millions of dollars.
These millions of dollars of capital investments were sanctioned by
Dominion throughout the past 30 years, so it would appear they may have some
major responsibility if the health, safety, and property of Virginia citizens
are adversely affected by a new nuclear reactor.
As proposed, adding the third
reactor could have a cascading effect on the main lake.
Although not discussed in this letter, parts of the public side of Lake
Anna could also experience significantly increased water temperatures because
much of the water exiting the waste heat treatment facility at dike 3 travels
back up lake to the plant intake during the water cooling circulation process.
Thus, the part of the main lake between dike 3 and the plant could also
see significant water temperature increases of 5 plus degrees due to the
increased flow rate. Also, problems
associated with the warm side (WHTF) may not be distinguishable by the general
public which many do not appear to understand the difference between the public
side and the private side.
We are not opposed to a new 3rd
and 4th nuclear reactor, if the water temperature of the warm side (WHTF)
is not increased past its current levels and water levels remain the same.
However, we do need some written guarantees to protect our interests as the
permit process moves ahead.
Thank you in advance for your help in this matter.
We apologize for this late submittal, but the concerns in this letter
were triggered by a July 30, 2005 briefing by Dr. Judson White (Dominionís
Environmental policy manager) to the Lake Anna Civic Association and left many
questions and no firm answers. This
in turn, triggered many follow-up discussions with various Dominion
representatives to get specific confirmation of facts in their ESP, including
Mr. Tony Banks (Dominionís ESP Program Manager). It also triggered conferences with the Virginia agencies and
the Nuclear Regulatory Commission referenced in this letter. .
We understand that your comments must be sent to Dominion by September
22, 2005 with a copy to the Nuclear Regulatory Commission. Our understanding is also that your comments indicate whether
the Commonwealth of Virginia is in agreement that Dominionís ESP request is
compliant/consistent with the Federal Coastal Zone Management Act.
Further, that the NRC cannot issue a ESP permit until Dominion becomes
compliant with the Coastal Zone Management Act.
Please call if we can be of any further assistance. We will look forward
to your response.
Harry Ruth for the Board of Directors
Ruth Estates Property Owners Association
Phone (540) 872-3632