ML18003A405

Part 03 Environmental Report (Rev. 1) - Part 3 - Er - Chapter 1 - Introduction to the Environmental Report

ML18003A405
Person / Time
Site:	Clinch River
Issue date:	12/15/2017
From:	James Shea Tennessee Valley Authority
To:	Office of New Reactors
Fetter A
References
TVACLINCHRIVERESP, TVACLINCHRIVERESP.SUBMISSION.4, CRN.P.PART03, CRN.P.PART03.1
Download: ML18003A405 (17)

Text

Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report CHAPTER 1 INTRODUCTION TO THE ENVIRONMENTAL REPORT This Environmental Report (ER) is prepared and submitted as part of the Tennessee Valley Authority (TVA) application for an Early Site Permit (ESP) under Title 10 of the Code of Federal Regulations (10 CFR) Part 52 for the Clinch River Nuclear (CRN) Site in Oak Ridge, Roane County, Tennessee. The ESP would represent U.S. Nuclear Regulatory Commission (NRC) approval of the CRN site for new nuclear power units demonstrating small modular reactor (SMR) technology. This is separate from the filing of a combined license application (COLA) for such a facility. The site location is shown in Figure 1.1-1. In accordance with NRC regulations, TVA has prepared this ER to analyze the environmental effects of construction, operation, and decommissioning of two or more SMRs at the CRN Site. The NRC uses this ER to develop an Environmental Impact Statement to meet the requirements of the National Environmental Policy Act (NEPA) for federal agencies to consider the environmental effects of their action (e.g.,

issuance of an ESP).

1.1 THE PROPOSED ACTION The proposed federal action is the NRC issuance, under the provisions of 10 CFR Part 52, of an ESP to TVA approving the CRN Site as a suitable site for future demonstration of the construction and operation of two or more SMRs. In this ESP application (ESPA), TVA identifies a proposed site suitable for deployment of two or more SMRs. The SMR technology is designed with inherent enhanced safety and security features. SMR deployment will demonstrate that the technology is capable of incrementally supplying clean, secure, reliable power that is less vulnerable to disruption to facilities owned by federal agencies (e.g., U.S. Department of Energy (DOE), U.S. Department of Defense (DoD), TVA, etc.).

This ER provides an analysis of the effects on the environment from site preparation, construction, operation, and decommissioning of two or more SMRs at the CRN Site. The proposed action does not include any decision or approval to build the facility. As TVA is not requesting limited work authorization as part of this ESPA, an NRC-issued combined license (COL) is required prior to initiation of construction.

1.1.1 Purpose and Need The purpose and need for the NRC proposed action, issuance of the ESP, is to provide for early resolution of site safety and environmental issues, which provides stability in the licensing process.

TVA proposes to deploy two or more SMRs with a maximum total electrical output of 800 megawatt electric (MWe) for the site, to demonstrate the capability of SMR technology. SMRs provide the benefits of nuclear-generated power in situations where large nuclear units, with an approximate electrical output exceeding 1000 MWe, are not practical, because of transmission system constraints, limited space or water availability, or constraints on the availability of capital for construction and operation.

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Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report In 2009, Executive Order (EO) 13514 was issued on Federal Leadership in Environmental, Energy, and Economic Performance. EO 13514 directed all Federal Agencies to reduce their greenhouse gas (GHG) emissions by 28% by 2020 (Reference 1-1). This was followed by EO 13693 (March 2015), Planning for Federal Sustainability in the Next Decade (Reference 1-2),

which called for further reduction of Federal facility GHG emissions to 40 percent by 2025, and identified SMRs as one of the alternative energy options for meeting clean energy goals.

In 2013, Executive Order (EO) 13636 was issued on Improving Critical Infrastructure Cybersecurity and Presidential Policy Directive (PPD) 21 on Critical Infrastructure Security and Resilience (Reference 1-3). EO 13636 and PPD-21 are designed to strengthen the security and resilience of critical infrastructure against evolving threats and hazards.

TVA and DOE, based on a Memorandum of Understanding, began working together to explore various options under which TVA could license, construct, operate, and maintain two or more SMR units (Reference 1-4).

By letter dated February 17, 2016, DOE expressed its support to TVA for the development and licensing of SMRs as a means to meet DOE goals of improving the environmental, economic, and energy security outlook for the United States (Reference 1-5). DOE believes that SMR deployment near federal facilities could provide enhanced reliability and other benefits, by providing continued operation during a widespread and extended loss of the electrical power grid, meeting reliability needs with clean energy that supports carbon reduction directives. DOE specifically requested TVA to assess, as a part of the deployment project planning and licensing process, the ability of SMRs to continue to supply electricity to nearby offsite customers during a disruption to offsite power supplies. This includes electricity transmission to those customers in a manner less vulnerable to intentional destructive acts and natural phenomena that could disrupt the power supply.

The main objectives of the Clinch River (CR) SMR Project are to demonstrate that:

• Power generated by SMRs could be used for addressing critical energy security issues.

Their use on or immediately adjacent to DoD or DOE facilities, using robust transmission (e.g., armored transformers, underground transmission), could address national security needs by providing reliable electric power in the event of a major grid disruption. A more reliable electric power supply could be accomplished by the SMR operation in power island mode with robust transmission to critical facilities. In addition, intentional destructive acts (e.g., terrorist attacks) and natural phenomena (e.g., tornadoes, floods, etc.) could disrupt the grid and the ability to restore most generation sources. SMRs can provide reliable energy for extended operation. Because nuclear reactors require fuel replenishment less frequently than other power generation sources (coal, gas, wind and solar), SMRs are less vulnerable to interruptions of fuel supply and delivery systems. TVA could demonstrate this power islanding and secure supply concept as part of the CR SMR project by utilizing controls, switching, and transmission capabilities to disconnect the SMR power plant from the electrical grid while maintaining power from the SMR power plant to a specified DOE 1-2 Revision 1

Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report power need. Such a demonstration would show that SMR technology is capable of supplying reliable power that is less vulnerable to disruption from intentional destructive acts and natural phenomena.

• SMR technology can assist federal facilities with meeting carbon reduction objectives.

Energy-related carbon dioxide (CO2) emissions account for more than 80 percent of GHG emissions in the United States (Reference 1-6). Studies show that on average coal combustion generates approximately 894-975 grams of CO2 per kilowatt-hour (g/kWh) of electricity generated. Natural gas generates an estimated 450-519 g/kWh. Nuclear power emission rates have been calculated to range from 6 - 26 g/kWh. (Reference 1-7)

• SMR design features include underground containment and inherent safe-shutdown features, longer station blackout coping time without external intervention, and core and spent fuel pool cooling without the need for active heat removal. These key features advance safety by eliminating several design basis accident scenarios. Development of a security-informed design efficiently provides the same or better protection against the threats large reactors must consider. Physical security is designed into the SMR plant architecture, incorporating lessons learned from significant shifts in security posture since 2001, and the opportunity to build more inherently secure features into the initial design.

• SMR power generating facilities are designed to be deployed in an incremental fashion to meet the power generation needs of a service area. Generating capacity can be added in increments to match load growth projections. For the CR SMR project, two or more SMRs would be constructed and brought into operation incrementally to achieve up to 800 MWe.

1.1.2 Proposed Project This subsection provides a brief description of the proposed project, the applicant and owner, the site location, the selected reactor types and other plant design features, preapplication public participation activities, and major project activity dates.

1.1.2.1 The Applicant and Owner TVA is the applicant and owner and sole point of contact with the NRC in all matters related to this ESPA. TVA is a corporate agency of the United States that provides electricity for business customers and local power distributors serving 9 million people in parts of seven southeastern states. As authorized by the Tennessee Valley Authority Act, TVA is committed to maintaining a national leadership role in technological innovation (Reference 1-8). Innovation is a part of the agency's mission as set forth by the TVA Act, and an important element of its mission to be a leader in the generation of affordable, clean power and a conservator of the Tennessee Valley's precious natural resources. Compared to a large nuclear plant, small modular reactors offer advantages in enhanced safety, less construction time and reduced expenditures. TVA's work on a deployment of this technology demonstrates its leadership in a movement toward cleaner, lower-cost, and more reliable electricity for our customers.

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Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report 1.1.2.2 Site Location The CRN Site is located on the northern bank of the Clinch River arm of the Watts Bar Reservoir in Oak Ridge, Roane County, Tennessee from approximately Clinch River Mile (CRM) 19 to approximately CRM 14.5 (Reference 1-9). The CRN Site is approximately 7 miles (mi) east of Kingston, Tennessee and approximately 25 mi west-southwest of Knoxville, Tennessee. Figure 1.1-1 shows the location of the CRN Site. Additional information regarding the CRN Site location is provided in Section 2.1, Site Location.

1.1.2.3 Reactor Information This ESPA is intended to demonstrate the suitability of the CRN Site for the deployment of two or more SMRs to demonstrate the capability of SMR technology. TVA has not yet selected a specific SMR technology. However, the design characteristics of four SMR designs under consideration were used to develop a plant parameter envelope (PPE) to describe the proposed plant. Additional information regarding the description of the PPE is provided in Section 3.1, External Appearance and Plant Layout. An SMR is a nuclear power generating unit with an electrical output of no more than 300 MWe, which is considerably less than the electrical output of approximately 1000 MWe provided by a typical commercial reactor in the United States.

SMRs are manufactured in factories as large, fabricated components and shipped to the facility site. Therefore, less onsite construction is required for installation of SMRs than for installation of a typical commercial reactor. SMRs may provide the benefits of nuclear-generated power in situations where large nuclear units are not practical because of transmission system constraints, limited space or water availability, or limited available capital for construction and operation. Additional information regarding SMRs is provided in Section 3.2, Reactor Power Conversion System.

1.1.2.4 Cooling System Information The SMRs being considered for deployment at the CRN Site use a recirculating (closed-cycle) cooling water system. Mechanical draft cooling towers are most suitable for use at the CRN Site. A new shoreline intake structure would supply makeup water from the Clinch River arm of the Watts Bar Reservoir to the facility. A new discharge structure located downstream of the intake structure would convey cooling tower blowdown and other planned discharges to the Clinch River arm of the Watts Bar Reservoir. Additional information regarding the cooling system is provided in Section 3.4, Cooling System.

1.1.2.5 Transmission System Information The CRN Site would be served by a new 500-kilovolt (kV) switchyard. The Watts Bar NP-Bull Run FP 500 kV line is to be looped in with approximately 0.7 mi of double circuit transmission line. In addition, a new 161-kV switchyard may be constructed for auxiliary station service and looped in to the Kingston FP-Fort Loudoun HP#1 161-kV transmission line with approximately 0.2 mi of double circuit transmission line. Additional transmission system upgrades would be 1-4 Revision 1

Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report required to support the added generation capacity to the system. A portion of the Kingston FP -

Fort Loudoun HP #1 161-kV transmission line is to be relocated within the CRN Site.

A new 69-kV underground transmission line (approximately 5 mi) could be constructed to connect the CRN Site switchyard via 500 kV to 69 kV transformers to the Bethel Valley Substation. This 69-kV transmission line would follow the existing Watts Bar NP - Bull Run FP 500-kV transmission line corridor on DOE property.

Additional information regarding the transmission system is provided in Section 3.7, Power Transmission System.

1.1.2.6 Preapplication Public Involvement The possibility of deployment of SMRs at the CRN Site and SMR development in general has been publicized widely in the local and national press, trade journals, electronic media, and professional conferences. NRC and TVA have participated in numerous preapplication public meetings at NRC headquarters in Rockville, Maryland. These meetings have occurred since 2010 and covered various technical topics, including regulatory framework meetings that preceded TVAs change from a construction permit application to an ESPA in 2014. At the time of submittal of the application, no public outreach meetings specifically designed to comply with NEPA requirements have been conducted.

1.1.2.7 Construction Start Date The ESP does not constitute a decision or approval to build new units. A limited work authorization application under NRC regulation 10 CFR 50.10 is not included with this ESPA.

At this time, TVA has not established a date for preconstruction activities. It is estimated that site preparation activities (preconstruction) will take between 6 and 18 months to complete.

Based on estimates provided by the reactor vendors, assuming that appropriate licenses are obtained, actual construction of the SMR units is expected to take between three and five years.

1.2 STATUS OF REVIEWS, APPROVALS AND CONSULTATIONS Numerous federal, state, regional, and local and affected Native American tribal agencies environmental protection licenses, permits, reviews, approvals, and/or consultations (collectively referred to as authorizations) are required to support the preconstruction, construction, and operation phases of the project. Tables 1.2-1 and 1.2-2 identify, for each authorization, the following information:

• Permit/authorization

• Responsible agency

• Applicable law, ordinance, or regulation 1-5 Revision 1

Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report

• Principal environmental factors covered by the authorization Appropriate consultations with federal, state, and local agencies have been initiated. However, authorizations from federal, state, and local authorities for construction and operation are not yet necessary because an ESP is limited to establishing the acceptability of the CRN Site for future development. TVA plans to apply for and receive any required authorizations prior to initiating preconstruction, construction, and operational activities. The following subsections describe the activities to be authorized.

1.2.1 ESP Issuance The following statutes summarize the agency consultations necessary for the ESP. Table 1.2-1 lists ESP authorizations required prior to NRC issuance of an ESP.

Endangered Species Act: The Endangered Species Act requires federal agencies to ensure that agency action is not likely to jeopardize any species that is listed or proposed for listing as endangered or threatened. The Endangered Species Act requires consultation with the U.S.

Fish and Wildlife Service (USFWS). In addition, as a matter of policy, the NRC consults with states regarding state-protected species.

National Historic Preservation Act: The National Historic Preservation Act requires federal agencies having the authority to license any major federal action, prior to issuing the license, to take into account the effect of the undertaking on historic properties and to afford the Advisory Committee on Historic Preservation an opportunity to comment on the undertaking. Committee regulations provide for establishing an agreement with any State Historic Preservation Officer (SHPO) to substitute state review for Committee review (36 CFR 800.7). The NRC consults with the Tennessee SHPO.

Coastal Zone Management Act: The Federal Coastal Zone Management Act imposes requirements on applicants for a federal license to conduct an activity that could affect a states coastal zone. The Coastal Zone Management Act requires the applicant to certify to the licensing agency that the proposed activity is consistent with the states federally-approved coastal zone management program. Tennessee does not have any coastal barrier resource areas; therefore no action is required.

Clean Air Act: The Clean Air Act imposes regulatory requirements on federally-licensed projects where construction and operation may have an impact on state and regional air quality. The portion of Roane County in which the CRN Site is located is in attainment for all air pollutants.

The NRC consults with the Tennessee Department of Environmental Control (TDEC) Division of Air Pollution Control on nonattainment issues.

Clean Water Act/Rivers and Harbors Act: The Clean Water Act requires that federal agencies consider the potential impacts to jurisdictional waters of the United States. Section 401 of this Act regulates the issuance of a Water Quality Certification, Section 402 regulates point source and non-point source discharges under the National Pollutant Discharge Elimination System, 1-6 Revision 1

Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report and Section 404 regulates the placement of fill in waters of the United States. The U. S. Army Corps of Engineers (USACE) regulates dredge and fill activities in navigable waters pursuant to Section 10 of the Rivers and Harbors Act. As a matter of policy, the NRC consults with the USACE and TDEC regarding potential impacts to waters of the United States.

1.2.2 Preconstruction, Construction, and Operation Activities Permits and authorizations for future construction and operation of two or more SMRs are to be obtained in accordance with applicable statutes and regulations. Applications for these authorizations are to be developed after a reactor technology has been selected and detailed design is initiated. Table 1.2-2 lists authorizations that are anticipated for preconstruction, construction, and operation of two or more SMRs.

1.3 METHODOLOGY NRC regulation 10 CFR 52.17(a)(2), Contents of Applications; Technical Information, specifies the contents of an ER for an ESPA. Regulatory Guide (RG) 4.2, Preparation of Environmental Reports for Nuclear Power Stations, Revision 2, July 1976, provides guidance to applicants preparing ERs for nuclear power stations. NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Environmental Standard Review Plan, provides guidance to the NRC staff when conducting environmental reviews of applications related to nuclear power plants. Attachment 3 of NRCs Office of Nuclear Reactor Regulation Review Standard (RS) -002, Processing Applications for Early Site Permits provides guidance to NRC staff when conducting environmental reviews associated with ESPs.

In preparing this ER, TVA used NUREG-1555 and RS-002 for guidance in establishing the format and content of its ER and NRC RG 4.2 for guidance on the preparation of the ER. Table 1.3-1 lists regulatory requirements and where in the ER each requirement is addressed.

1.4 REFERENCES

Reference 1-1. The White House, "Executive Order 13514: Federal Leadership in Environmental, Energy, and Economic Performance," The White House, Office of the Press Secretary, EO 13514, October 5, 2009.

Reference 1-2. The White House, "Executive Order 13693 - Planning for Federal Sustainability in the Next Decade," EO 13693, March 19, 2015.

Reference 1-3. The White House, "Executive Order 13636 - Improving Critical Infrastructure Cybersecurity," EO 13636, February 19, 2013.

Reference 1-4. Tennessee Valley Authority and U.S. Department of Energy, "Memorandum of Understanding: Construction of Small Modular Nuclear Reactors and Power Supply Arrangements," May 31, 2012.

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Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Reference 1-5. U.S. Department of Energy, Secure Supply of Electricity from SMRs to Oak Ridge Facilities, February 17, 2016.

Reference 1-6. U.S. Energy Information Administration, Emissions of Greenhouse Gases in the U.S., Website: http://www.eia.gov/environment/emissions/ghg_report/ghg_carbon.cfm, March 31, 2011.

Reference 1-7. World Nuclear Association, Energy Balances and CO2 Implications, Website:

http://www.world-nuclear.org/info/Energy-and-Environment/Energy-Balances-and-CO2-Implications/, March, 2014.

Reference 1-8. United States Congress, "Tennessee Valley Authority Act," 1933.

Reference 1-9. Watts Bar - Clinch Watershed Team, Final Watts Bar Reservoir Land Management Plan, Panel 4; Alternative B "Preferred", January 23, 2009.

Reference 1-10. Not used.

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Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Table 1.2-1 Consultations Required for Early Site Permit Agency Authority Requirement Activity Covered USFWS Endangered Species Consultation regarding Concurrence with no Act , 16 U.S. Code potential to adversely adverse effect or (USC) 1536 affect protected non- consultation on appropriate marine species. mitigation measures.

Bald and Golden Consultation regarding Concurrence with no Eagle Protection Act, potential to adversely adverse effect or 16 USC 668-668c affect bald eagles. consultation on appropriate mitigation measures.

TDEC - Division Rare Species Consultation regarding Concurrence with no of Natural Protection and potential to adversely adverse effect or Heritage and Conservation Act, TN affect protected species. consultation on appropriate Tennessee Code §70-8-101 mitigation measures.

Wildlife Resources Agency Tennessee National Historic Consultation with Confirm that site Historical Preservation Act, 16 Tennessee SHPO construction and operation Commission USC 470 et seq. regarding potential to activities would not affect adversely affect historic protected historic resources resources. or would be mitigated if unavoidable.

Tennessee National Historic Section 106 Complete Tennessee SHPO Historical Preservation Act 36 Review: Consultation with Initial Review Request Commission CFR Part 800 SHPO to determine Checklist.

National Register of Historic Places listing of property.

TDEC - Division Clean Air Act, USC Consultation regarding Concurrence with no of Air Pollution 42 et seq. potential adverse effects adverse effect or Control on ozone standards. consultation on appropriate mitigation measures.

USACE Federal Clean Water Consultation regarding Concurrence with no Act, 33 CFR 330 potential to adverse adverse effect or Rivers and Harbors effects on waters of the consultation on appropriate Act, 33 USC 403 United States. mitigation measures.

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Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Table 1.2-2 (Sheet 1 of 5)

Authorizations Required for Preconstruction, Construction, and Operation Activities Agency Authority Requirement Activity Covered NRC Atomic Energy and Energy ESP and COL or Limited Work Site Licensing, including safety-related construction Reorganization Acts Authorization, in addition to activities and operation of a nuclear power facility 10 CFR 52 Subpart C or applicable By-Product License, 10 CFR 50.10(e)(1) Source Material License, and Special Nuclear Material License Federal Aviation Federal Aviation Act Construction Notice Notice of erection of structures greater than 200 feet high Administration 49 USC 1501; 14 CFR 77 that potentially may affect air navigation.

U.S. Department of Hazardous Material Transportation Certificate of Registration Transportation of hazardous materials.

Transportation Act (DOT) 49 CFR 107 Subpart G Tennessee TCA 54-5-302 Entrance Permits This includes ramps, driveways, and other access points.

Department of Requires traffic studies and engineering designs to show Transportation design and potential impacts of proposed changes (TDOT)

TDOT TCA 54-5-302 Right-of-way (ROW) permit Required for installing utilities in highway ROWs.

USACE Clean Water Act Section 404 Permit Disturbance, crossing or filling-in of wetland areas or 33 CFR 323 and 330 navigable waters from site.

Rivers and Harbors Act Section 10 Permit Construction and maintenance of intake, discharge and 33 USC 403 barge structures in navigable waters of the United States.

U.S. Coast Guard Ports and Waterways Safety Act 33 Private Aids to Navigation Permit Construction of discharge pipeline in navigable waters.

USC 1221, et seq.

U.S. Environmental Resource Conservation and Acknowledgement of Notification of Hazardous Waste Generation Protection Agency Recovery Act, Section 3010 Hazardous Waste Activity (EPA) and TDEC EPA Facility Response Plan (40 Facility Response Plan Approval Spill/Discharge Response Program CFR 9 and 112), and the EPA Hazardous Waste Contingency Plan Spill Prevention, Control and SPCC/Integrated Pollution Spill/Discharge Prevention Plan Countermeasures (SPCC) rule (40 Prevention (IPP) Plan CFR 112), Appendix F, Sections 1.2.1 and 1.2.2 1-10 Revision 1

Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Table 1.2-2 (Sheet 2 of 5)

Authorizations Required for Preconstruction, Construction, and Operation Activities Agency Authority Requirement Activity Covered USFWS Endangered Species Act Section 7 Consultation/Biological Evaluation of effects on listed species.

(16 USC 1536) Assessment USFWS Migratory Bird Act/Executive Order Responsibility of Federal Agencies TVA is exempt from the Act requirements, but complies 13186 to Protect Migratory Birds voluntarily. TVA is subject to the Executive Order City of Oak Ridge Site Plan Approval Coordination with the Planning Board and/or Zoning Board of Adjustment for development of the site in compliance with city ordinances.

Flood Encroachment Permit / Compliance With City of Oak Ridge Zoning Article IX Floodplain Permit Special Districts 9.08 a, b, c Floodway Districts, Floodway Fringe Area. Mostly covered in Stormwater Pollution Prevention Plan and grading permit.

Sanitary Sewer connection Compliance with the City Industrial Pre-treatment Program if required, or connection to the City Waste Water Treatment System Potable Water A potable water line on the SMR Site would tap into the existing City of Oak Ridge water line on Bear Creek Road. If the existing waterline has to be extended for TVA, additional planning and approvals would be necessary by the city.

Construction Permits Construction of the new plant facilities in compliance with city ordinances.

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Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Table 1.2-2 (Sheet 3 of 5)

Authorizations Required for Preconstruction, Construction, and Operation Activities Agency Authority Requirement Activity Covered TDEC Federal Clean Water Act Notice of Intent (NOI) for coverage Compliance with federal and state water quality (33 USC 1251 et seq.) and under an Individual National standards, discharges to waters of the state due to Tennessee Code Annotated (TCA) Pollution Discharge Elimination construction of the new plant, switchyards, and

§ 69-3-108: Tennessee Water System (NPDES) Permit for transmission lines (aboveground and underground).

Quality Control Act of 1977 stormwater discharges associated Construction/operation of stormwater control measures with construction activities. (detention basins, etc.). Provided that pollution prevention measures are implemented, the construction general permit covers discharges associated with:

• Construction activities

• Construction support activities (e.g., concrete or asphalt batch plants, equipment staging yards, material storage areas, excavated material disposal areas, borrow areas)

• Dewatering of work areas of collected stormwater and groundwater

• Water used to wash vehicles

• Water used to control dust

• Routine building washdown

• Uncontaminated groundwater

• Unpolluted foundation or footing drains Appropriate dewatering controls include, but are not limited to: weir tank, dewatering tank, gravity bag filter, sand media particulate filter, pressurized bag filter, cartridge filter or other control units providing the level of treatment necessary to comply with permit requirements.

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Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Table 1.2-2 (Sheet 4 of 5)

Authorizations Required for Preconstruction, Construction, and Operation Activities TDEC (continued) Federal Clean Water Act Stormwater Pollution Prevention Compliance with federal and state water quality (33 USC 1251 et seq.) and TCA § Plan, to include Common Plan of standards, discharges to waters of the state due to 69-3-108: Tennessee Water Development, Soil Erosion and construction of the new plant, switchyards, and Quality Control Act of 1977 Sediment Control Plan (structural transmission lines (aboveground and underground).

(continued) control measures, engineering design of sediment basin/controls for projects 10 acres or greater),

etc.

Aquatic Resource Alteration Permit Clinch River arm of the Watts Bar Reservoir water required for alterations of a stream required for cooling purposes. Portions of the new plant or wetland, including diversion of site, proposed causeway, switchyards, and onsite and surface waters of the state. potential offsite transmission lines may be located in freshwater wetlands and transitional areas.

NPDES Industrial Stormwater Cooling water, service water, and stormwater runoff General Permit for plant operation discharge from plant operations.

activities; EPA Application Forms 2D (Application for Permit to Discharge Process Wastewater) and 2F (Application for Permit to Discharge Stormwater Discharges Associated with Industrial Activity)

NOI for NPDES General Permit of Point source discharges of pesticides used for mosquito Discharges from the Application of and other flying insect pest control, weed and algae Pesticides (TNP100000) control, animal pest control, and forest canopy pest control to waters of the state.

Sanitary Waste Water - Portable Must use licensed wastewater hauler Facilities Permanent Sanitary Waste Water Connect to Waste Water Treatment Plant TCA §§ 69-7-301, et seq. Water Resources Notification; Surface water or groundwater withdrawal of an average of Water Withdrawal Registration 10,000 gallons or more per day.

Federal Clean Air Act, 42 USC Title V Operating Permit; Discharge of air pollutants from cooling tower(s),

7401 Prevention of Significant emergency generators, auxiliary boiler(s), and ancillary Deterioration Preconstruction equipment.

Permit 1-13 Revision 1

Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Table 1.2-2 (Sheet 5 of 5)

Authorizations Required for Preconstruction, Construction, and Operation Activities Agency Authority Requirement Activity Covered Texas Department 25 Texas Administrative Code Emergency Plan for the response to an Transportation of low level radioactive waste (LLRW) of State Health (TAC) §289.252 "Licensing of accident or incident involving shipments of to the Texas Disposal Facility.

Services , Radioactive Material" radioactive waste. Proof of financial Radiation Control responsibility such as insurance that the Program, carrier has in order to comply with DOT Radiation Safety requirements.

Licensing Branch 25 TAC §289.257 "Packaging and Provide list of approved shipping Shipping of LLRW to the Texas Disposal Facility.

Transportation of Radioactive containers along with their certificates of Material" compliance or other certifying documentation. For a shipper that manufactures their own containers they must submit their quality assurance procedures.

TDEC Division of TCA § 68-23-212; TDEC Rule Obtain a License-for-Delivery from the Transportation of radioactive waste within the State of Radiological 0400-20-10-.32 DRH (Form RHS 8-30). Persons whose Tennessee to a disposal/processing facility.

Health (DRH) activities result in the generation of radioactive waste have the primary responsibility to assure that a License-for-Delivery is obtained.

TN State Historic Section 106 of the National Historic As a Federal agency, TVA is required to Protection of archaeological and historical resources.

Preservation Office Preservation Act comply with Section 106 of the NHPA, (SHPO) Tribal which includes SHPO/TPO, and Preservation identification of potentially affected Officer (TPO) resources, i.e., a site survey.

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Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Table 1.3-1 (Sheet 1 of 2)

Environmental Report Responses to Early Site Permit Regulatory Requirements 1

No. Regulatory Requirement (10 CFR) Responsive Environmental Report Section 1 51.45(a), Signed original Transmittal letter 2 51.45(b), Description of proposed action Chapter 3, Plant Description 3 51.45(b), Statement of purpose of Section 1.1, The Proposed Project proposed action 4 51.45(b), Description of environment Chapter 2, Environmental Description affected by proposed action 5 51.45(b)(1) and 51.50(b), Environmental Chapter 4, Environmental Impacts of Construction; impact of proposed action Chapter 5, Environmental Impacts of Station Operation; Chapter 7, Environmental Impact of Postulated Accidents Involving Radioactive Materials; and Chapter 10, Environmental Consequences of the Proposed Action 6 51.45(b)(2), Unavoidable adverse impacts Section 10.1, Unavoidable Adverse Environmental Impacts 7 51.45(b)(3), Alternatives to proposed Chapter 9, Alternatives to the Proposed Action action 8 51.45(b)(4), Relationship between short- Section 10.3, Relationship Between Short-Term Uses and term use and long-term productivity Long-Term Productivity of the Human Environment 9 51.45(b)(5), Irreversible and irretrievable Section 10.2, Irreversible and Irretrievable Commitments commitments of resources of Resources 10 51.45(c) and 51.50(b), Comparison of Chapter 4, Environmental Impacts of Construction; environmental effects of proposed action Chapter 5, Environmental Impacts of Station Operation; and alternatives Chapter 7, Environmental Impact of Postulated Accidents Involving Radioactive Materials; Chapter 10, Environmental Consequences of the Proposed Action; and Chapter 9, Alternatives to the Proposed Action 11 51.45(c), Description of impacts of the Chapter 4, Environmental Impacts of Construction preconstruction activities 12 51.45(c), Alternatives for reducing or Section 4.6, Measures and Controls to Limit Adverse avoiding adverse environmental impacts Impacts During Construction; and Section 5.10, Measures and Controls to Limit Adverse Impacts During Operation 13 51.45(d), Federal permits and other Section 1.2, Status of Reviews, Approvals, and entitlements and status of compliance Consultations 14 51.45(d), Compliance with federal and Section 1.2, Status of Reviews, Approvals, and other environmental quality standards and Consultations requirements 15 51.45(d) and 51.50(b), Compliance for Section 9.3, Alternative Sites alternatives 16 51.45(e), Adverse information Section 10.1, Unavoidable Adverse Environmental Impacts 17 51.50(a), 51.50(b) and 51.51(a), Uranium Section 5.7, Uranium Fuel Cycle and Transportation fuel cycle Impacts 1-15 Revision 1

Clinch River Nuclear Site Early Site Permit Application Part 3, Environmental Report Table 1.3-1 (Sheet 2 of 2)

Environmental Report Responses to Early Site Permit Regulatory Requirements 1

No. Regulatory Requirement (10 CFR) Responsive Environmental Report Section 18 51.50(a) and 51.52, Fuel and waste Section 3.8, Transportation of Radioactive Materials transportation and Section 7.4, Transportation Accidents 19 51.50(a) and 51.50(b), Reporting and record Chapter 6, Environmental Measurements and keeping procedures Monitoring Programs 20 51.50(a) and 51.50(b), Conditions and Chapter 6, Environmental Measurements and monitoring Monitoring Programs 1

10 CFR 51.45, 10 CFR 51.50, 10 CFR 51.51, and 10 CFR 51.52 1-16 Revision 1

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Source: Hydrology, ESRI USA Water Body Types; Roads, U.S. Census Bureau; McMinn County Miles Counties/County Lines, ESRI Counties; Railroads, ESRI Railroads; Cities/City Boundaries, ESRI 72 City; 0 3 6 12 Airports, Google Earth Pro Kentucky Legend Missouri Virginia Cities Counties Interstate Site Tennessee CRN Site Rivers and Lakes Highway North Carolina City/Town Boundaries Railroad Major Road Mississippi Alabama Georgia South Carolina o Airports Bear Creek Road Figure 1.1-1. CRN Site Location Map 1-17 Revision 1