ML18092A515

Reader'S Guide for the Draft Environmental Impact Statement for an Early Site Permit at the Clinch River Nuclear Site.

ML18092A515
Person / Time
Site:	Clinch River
Issue date:	04/25/2018
From:	Tami Dozier, Patricia Vokoun NRC/NRO/DNRL
To:
Vokoun P
References
Download: ML18092A515 (48)

Text

(Photo courtesy of Joseph Colaccino, NRC)

Readers Guide for the Draft Environmental Impact Statement for an Early Site Permit at the Clinch River Nuclear Site April 2018

NRC ADAMS Accession Number: ML18092A515 THE EARLY SITE PERMIT AT THE CLINCH RIVER NUCLEAR SITE The Tennessee Valley Authority (TVA) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) on May 12, 2016, for an early site permit (ESP) for the Clinch River Nuclear Site (CRN Site) in Oak Ridge, Roane County, Tennessee, for new nuclear power units demonstrating small modular reactor technology. The NRC has reviewed that application.

WHAT IS AN EARLY SITE PERMIT?

An ESP is Commission approval of a site for one or more nuclear power facilities.

The ESP application and review process makes it possible to evaluate and resolve safety and environmental issues related to siting before the applicant makes a large commitment of resources. If the ESP is approved, the applicant can bank the site for up to 20 years for future reactor siting and can conduct certain site preparation and preliminary construction activities as authorized by the NRC.

An ESP does not authorize the WHERE CAN I FIND MORE INFORMATION?

actual construction and

• An electronic version of the entire environmental operation of a new nuclear impact statement can be found on the disc power plant. To construct and included with this summary.

operate a nuclear power plant, the

• View an online version at holder of an ESP must obtain https://www.nrc.gov/reading-rm/doc-from the NRC a construction collections/nuregs/staff/sr2226/index.html permit and an operating license, or a combined license, each of

• Review a printed copy or disc at which are separate actions that

- Kingston Public Library at 1004 Bradford Way, require their own safety and Kingston, Tennessee 37763 environmental reviews.

- Oak Ridge Public Library at 1401 Oak Ridge WHAT IS THIS DOCUMENT? Turnpike, Oak Ridge, Tennessee 37830

• Contact the U.S. Nuclear Regulatory Commission The NRC has reviewed the Environmental Project Managers at application submitted by TVA and ClinchRiverESPEIS@nrc.gov prepared a draft environmental impact statement for an ESP for the Clinch River Nuclear Site. This document summarizes the impacts that could result from building and operating two or more small modular reactors at the Clinch River Nuclear Site as presented in the draft environmental impact statement. It also summarizes the cumulative impacts and alternatives evaluated.

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What Is Being Proposed and Why?

TVA is seeking approval of the proposed Clinch River Nuclear Site for possible future use in building and operating two or more small modular reactors to demonstrate small modular reactor technology. TVA anticipates use of two or more small modular reactors at the Clinch River Nuclear Site with a maximum total electrical output of 800 megawatts electric (MW(e)) to demonstrate the capability of small modular reactor technology.

As part of its evaluation of the environmental aspects of the ESP application, the NRC prepares an environmental impact statement in accordance with the NRCs regulatory requirements.

Even though no new nuclear reactors are being proposed for construction or operation at this time, the environmental impact statement describes the effects on the environment of building and operating two or more small modular reactors at the Clinch River Nuclear Site that are bounded by the plant parameter envelope (defined below). The applicant for an ESP need not provide a detailed design of a reactor or reactors and the associated facilities, but should provide sufficient bounding parameters and characteristics of the reactor or reactors and the associated facilities so that an assessment of site suitability can be made. Consequently, the ESP application may refer to a plant parameter envelope as a surrogate for a nuclear power plant and its associated facilities.

A plant parameter envelope is a set of values of plant design parameters that an ESP applicant NATIONAL ENVIRONMENTAL expects will bound the design characteristics of POLICY ACT the reactor or reactors that might be constructed The National Environmental Policy Act at a given site. The plant parameter envelope is a national policy for the environment values are a bounding surrogate for actual that establishes the basis for reactor design information.

considering environmental issues in the Issuing an ESP is considered a major conduct of Federal activities.

Federal action. The Act requires the following:

• Use a systematic, interdisciplinary Who Is Leading the TVA approach for decision-making about Nuclear Plant Project actions that may impact the human environment.

Review?

• Inform and involve the public in the decision-making process.

The NRC is the lead Federal agency for reviewing the ESP application. The U.S. Army

• Consider significant environmental Corps of Engineers is cooperating with the NRC impacts associated with the action.

in the preparation of information in a single

• Consider alternatives and their environmental impact statement for both impacts on the proposed action.

agencies decision-making processes. The permit decision from the NRC relates to the The environmental impact statement construction and operation of nuclear power provides the necessary information facilities. Permits from the U.S. Army Corps of required under this Act.

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Engineers may be necessary to perform building and operation activities that may affect nearby ENVIRONMENTAL IMPACT waterbodies. Both agencies must ensure that STATEMENT the National Environmental Policy Act process is properly conducted and completed An environmental impact statement is before they can provide approval for their required for any Federal action that respective Federal actions in connection with significantly affects the environment.

this project. Because the necessary An environmental impact statement environmental reviews conducted by both describes the potential for project agencies are similar, having both agencies work effects on the environment and is used together saves time when reviewing an to help determine if an action should application. Both agencies work together to be permitted.

produce a draft environmental impact statement (EIS), which describes the effects on the environment that could result from building and operating two or more small modular reactors.

The NRC staff (including its contractor staff at Pacific Northwest National Laboratory) and U.S.

Army Corps of Engineers staff reviewed TVAs application and environmental information and collectively determined the environmental impact levels. The NRC staff, the U.S. Army Corps of Engineers staff, and contractor experts are known as the review team.

A detailed description of how the NRC determines whether to issue a permit to TVA is explained in the following sections. After the U.S. Army Corps of Engineers has completed its review of any future permit application in connection with the Clinch River Nuclear Site, it will issue a Record of Decision.

What Is the U.S. Nuclear Regulatory Commissions Process for Reviewing an Application for an Early Site Permit?

Once an application has been accepted, two separate reviews are prepared that address safety and environmental impacts.

Exhibit A shows the complete process for an ESP review. The final product from the safety review is a safety evaluation report that details reactor design and safety issues. The final product from the environmental review is an EIS that describes the environmental effects of building and operating a new nuclear plant at the site in question. Both reviews are addressed in a mandatory hearing before a decision is made about whether to grant an ESP. The Atomic Safety and Licensing Board also may conduct a contested hearing if a member of the public or an organization successfully files a petition that raises safety or environmental concerns.

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EXHIBIT A. EARLY SITE PERMIT PROCESS SAFETY REVIEW PROCESS The purpose of the safety review is to ensure that the site approval complies with NRC regulations and requirements. The review includes an evaluation of certain design alternatives, siting requirements, quality assurance programs, physical security, and certain major features of emergency preparedness. Additional information included in the analysis describes radioactive waste management and radiation protection. There are opportunities for public participation during the safety review process. The NRCs analysis is documented in the safety evaluation report. TVA anticipates using the Clinch River Nuclear Site for two or more small modular reactors that have a maximum total electrical output of 800 MW(e), to demonstrate the capability of small modular reactor technology.

The Advisory Committee on Reactor Safeguards reviews each application ADVISORY COMMITTEE ON REACTOR and the NRCs safety evaluation report SAFEGUARDS (see Exhibit B), and provides advice to The Advisory Committee on Reactor the NRCs five-member Commission Safeguards is composed of non-U.S. Nuclear about the potential hazards and the Regulatory Commission technical experts. It acceptability of the proposed site.

is structured so that experts representing many technical areas can provide Exhibit B shows the steps involved in the independent advice to the U.S. Nuclear safety review process leading up to the Regulatory Commission.

mandatory hearing and potential permit issuance.

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EXHIBIT B. SAFETY REVIEW PROCESS ENVIRONMENTAL REVIEW PROCESS The environmental review includes a careful COUNCIL ON look at the potential environmental impacts of ENVIRONMENTAL QUALITY building and operating new nuclear reactors at the proposed site and the potential mitigation The Council coordinates measures for reducing environmental effects. environmental efforts between The NRC applies the National Environmental Federal agencies and White House Policy Act and the NRCs Environmental offices to develop environmental Standard Review Plan, which provides detailed policies. The Chair of the Council instructions for the review of each serves as the environmental policy environmental subject area (e.g., water, human advisor to the President.

health, ecology). Environmental effects are explained using descriptions from the Council on Environmental Quality.

IMPACT CATEGORIES The environmental review includes consultation and coordination with local, State, and Federal

• SMALL - Environmental effects are agencies and Tribal Nations, as well as not detectable or are so minor that independent evaluations by the NRC, U.S. Army they will neither destabilize nor Corps of Engineers, and contractor experts (i.e., noticeably alter any important attribute of the resource.

the review team). These experts review the applicants information about the environment;

• MODERATE - Environmental effects visit and tour the proposed site; request further are sufficient to alter noticeably, but information from the applicant as needed; review not to destabilize, important attributes other published studies and reports; and, when of the resource.

necessary, perform additional analyses to confirm the applicants conclusions. The review

• LARGE - Environmental effects are teams analysis of the environmental impacts is clearly noticeable and are sufficient to documented in the EIS. destabilize important attributes of the resource.

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In addition, the environmental review includes input from the public by inviting comments before the draft EIS is prepared, and again after the draft EIS is issued. The NRC addressed public comments during the scoping process in the draft EIS and will address public comments on the draft EIS in the final EIS. Impacts are categorized as SMALL, MODERATE, LARGE, or a range of these categories, which are the accepted descriptions from the Council on Environmental Quality. Exhibit C shows a more detailed process flow for environmental reviews leading up to the mandatory hearing and potential license issuance.

EXHIBIT C. ENVIRONMENTAL REVIEW PROCESS COMMISSION REVIEW AND DECISION ATOMIC SAFETY AND LICENSING BOARD A mandatory hearing examining both safety Members of the Atomic Safety and Licensing and environmental issues will be conducted Board panel are employees of the U.S. Nuclear prior to making a decision about the Regulatory Commission who act as issuance of an ESP. In addition, a administrative judges on behalf of the contested hearing may be held by the Commission. This panel rules over contested Atomic Safety and Licensing Board public hearings.

panel if a member of the public or organization successfully files a petition that raises safety or environmental concerns about permitting the site. The Atomic THE COMMISSION Safety and Licensing Board then makes a The U.S. Nuclear Regulatory Commission has decision about disposition of the issues five Commissioners that are selected by raised in the contested hearing, and this presidential appointment. The Commission decision may be appealed to the develops policies and regulations for nuclear Commission.

reactors and nuclear materials safety, issues The NRCs five-member Commission licenses, and rules on legal matters.

makes the final decision about whether or not to grant an ESP.

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Who Else Did the AGENCIES AND TRIBES INVOLVED WITH U.S. Nuclear THIS PROJECT Regulatory

• Advisory Council on Historic Preservation

• Absentee Shawnee Tribe, Shawnee, Oklahoma Commission Work

• Alabama-Coushatta Tribe of Texas

• Alabama-Quassarte Tribal Town with on this EIS?

• Alabama Department of Conservation and Natural Resources A large number of Federal agencies;

• Auburn University, Auburn, Alabama agencies of the States of Tennessee,

• Anderson County Chamber of Commerce Alabama, and Kentucky; Tribal and

• Anderson County Economic Development Association

• Anderson County Sheriffs Department local agencies; and community

• Cherokee Nation of Oklahoma organizations were contacted during

• City of Knoxville the development of the draft EIS.

• City of Oak Ridge, Oak Ridge, Tennessee These parties provided comments

• The Chickasaw Nation and information used to develop a

• Choctaw Nation of Oklahoma good understanding of the

• Coushatta Tribe of Louisiana environmental resources in the area

• Eastern Band of the Cherokee Indians

• Eastern Shawnee Tribe of Oklahoma and the potential for environmental

• Georgia Department of Natural Resources impacts. Detailed information about

• Governor of Tennessee consultations can be found in

• Huntsville Utilities Appendix F of the draft EIS.

• Jena Band of the Choctaw Indians, Jena, Louisiana

• Kialegee Tribal Town, Wetumka, Oklahoma See Appendix C of the draft EIS for

• Kentucky State Nature Preserves Commission more information about how the NRC

• Knox County Government, Knoxville, Tennessee

• Loudon County Economic Development Agency staff coordinated with Federal, States

• Loudon County Government of Tennessee, Alabama, and

• Morgan County Government Kentucky, Tribal, and local agencies.

• Mississippi Band of Choctaw Indians

• Muscogee (Creek) Nation of Oklahoma In addition to an ESP from the NRC,

• Oak Ridge National Laboratory TVA may need many other

• Poarch Band of Creek Indians, Atmore, Alabama environmental permits and

• Quapaw Tribe of Oklahoma

• Roane Alliance certifications potentially required by

• Roane County Government, Kingston, Tennessee Federal, State, regional, local, and

• Roane County Sherriffs Office, Kingston, Tennessee affected Native American Tribal

• Seminole Tribe of Florida agencies related to site preparation,

• Seminole Nation of Oklahoma, Wewoka, Oklahoma construction, and operation of two or

• Shawnee Tribe of Oklahoma, Miami, Oklahoma more small modular reactors at the

• Tennessee Department of Environment and Conservation Clinch River Nuclear Site. Some of

• Tennessee Department of Environment and these permits are listed in Exhibit D. Conservation, Knoxville Field Office, Tennessee Appendix H of the draft EIS contains

• Tennessee Department of Transportation, Region 1 a comprehensive list of all the permits

• Tennessee Emergency Management Agency and requirements TVA would need to

• Tennessee Historical Commission build and operate new nuclear

• Tennessee Housing Development Agency

• Tennessee Wildlife Resource Agency facilities.

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EXHIBIT D. SOME PERMITS AND AUTHORIZATIONS REQUIRED IF SMALL MODULAR REACTORS WERE TO BE BUILT AT THE CLINCH RIVER NUCLEAR SITE Federal

• Aquatic Resource Alteration Permit/Section 401 Water Quality Certification, level Tennessee Department of Environment and Conservation

• Department of the Army Permit Section 404 and Section 10 Permit, U.S. Army Corps of Engineers

• Early site permit or combined license or Limited Work Authorization, NRC State

• Compliance with National Historic Preservation Act, State Historic Preservation Office level Tribal Preservation Officer

• National Pollutant Discharge Elimination System Permit, Tennessee Department of Environment and Conservation

• Aquatic Resource Alteration Permit, Tennessee Department of Environment and Conservation Local

• Site Plan Approval, City of Oak Ridge level

• Building Permit, Roane County Description of the Project The Clinch River Nuclear Site, for which an ESP application has been submitted, is located in Oak Ridge (Roane County), Tennessee, approximately 25 miles west-southwest of Knoxville.

For the Clinch River Nuclear Site ESP, the TVA used a plant parameter envelope approach to estimate the potential environmental impacts of building and operating two or more small modular reactors that have a maximum electric output of 800 MW(e) at the site. TVA developed its plant parameter envelope using information provided by four small modular reactor vendors, along with site-specific information, and specific requirements provided in regulatory guidance.

TVAs Environmental Report states that the plant parameter envelope represents a surrogate plant that can bound two or more [small modular reactor] technologies. The plant parameter envelope for the Clinch River Nuclear Site ESP is provided in Appendix I of the EIS. The 935-acre Clinch River Nuclear Site is not currently used for power-generating activities. Exhibit E is a conceptual figure of two small modular reactor units superimposed on the Clinch River Nuclear Site.

EXHIBIT E. ARCHITECTURAL RENDERING OF TWO SMALL MODULAR REACTOR UNITS SUPERIMPOSED ON THE CLINCH RIVER NUCLEAR SITE 8

Parts of the Environment that Might Be Affected The Clinch River Nuclear Site is located in Oak Ridge, Roane County, Tennessee (Exhibit F).

The site is located on the Clinch River arm of the Watts Bar Reservoir, adjacent to the existing U.S. Department of Energys Oak Ridge Reservation. The Clinch River Nuclear Site is situated in the southwestern part of the city limits of Oak Ridge approximately 10 miles south of the Oak Ridge urban center; 16 miles west of Knoxville, Tennessee; and 7 miles east of Kingston, Tennessee. The primary source of cooling water would be the Clinch River. The ultimate heat sink for the Clinch River Nuclear small modular reactors would be the atmosphere, using mechanical draft cooling towers.

EXHIBIT F. LOCATION OF CLINCH RIVER NUCLEAR SITE 9

What Are the Concerns of Those Interested?

To learn about the concerns of interested groups and individuals across the country, PUBLIC PARTICIPATION public comments were invited for 60 days

• Scoping meetings were held on May 15, through a notice in the Federal Register, 2017, in Oak Ridge, Tennessee, at the mailings, and news releases about the Pollard Technology Conference Center scope of this project. Auditorium. All EIS subjects were discussed.

Most of the concerns that were within the

• All scoping comments received and their scope of the EIS centered on the following corresponding responses were included issues: as Appendix D in the draft EIS.

• Why arent alternative energy sources

• Two public meetings for comments on evaluated in the EIS? the draft EIS will be held on June 5, 2018, in Kingston, Tennessee, at the

• Are small modular reactors water- Noahs Event Venue. Comments intensive? received and their corresponding responses will be included as Appendix E

• What impact does radiation have on in the final EIS.

the soil, the air, and the water, and noise?

How Does the Project Affect the Environment?

The building and operation of two or more small modular reactors at the Clinch River Nuclear Site would affect multiple environmental and regional resources. The EIS considers the potential for impact on each resource.

LAND-USE IMPACTS The review team concluded that noticeable land-use impacts from construction and preconstruction would result from the proposed project, primarily because of the conversion of substantial areas of undeveloped naturally vegetated land to a developed condition, and because of the long-term dedication of a 935-acre tract of Federally owned land in an industrial setting that would have otherwise been available for other industrial or urban uses. The barge/traffic area is a portion of the Oak Ridge Reservation immediately north of the Clinch River Nuclear Site where TVA proposes to build various road improvements and transportation facilities to serve the new reactors. The review teams conclusion also reflects noticeable land-use impacts from highway interchange reconstruction in the barge/traffic area, as well as brief but locally noticeable land-use impacts from rebuilding a 12.7-mile transmission line segment, especially where the right-of-way traverses residential landscapes. However, because the changes would take place in an area where energy generation and development projects are common and would not be incompatible with existing land uses, and because the changes would not substantially interfere with anticipated regional growth, the review team does not believe that the land-use impacts would be destabilizing to land resources in the region.

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The land-use impacts of operating a new nuclear power plant on the Clinch River Nuclear Site would be minor. The review team expects that the land-use impacts from operation and maintenance of the affected transmission lines and in other offsite areas would be minor.

WATER-RELATED IMPACTS Water-related impacts associated with building a nuclear plant on the Clinch River Nuclear Site are similar to impacts that would be associated with the development of any large industrial site.

Prior to initiating onsite activities, including any site preparation work, TVA would be required to obtain the appropriate authorizations regulating alterations to the hydrologic environment.

The site preparation and building activities that could affect surface-water quality include land-surface clearing and grading, road improvements, and building structures on the Clinch River Nuclear Site. Land-surface modifications and road improvements would also occur in the barge/traffic area and offsite transmission corridors. These activities would alter the land surface, the surface cover, and surface-drainage patterns and increase the potential for runoff and erosion.

Work occurring on the shoreline of the Clinch River arm of Watts Bar Reservoir would disturb sediment containing contaminants from historical practices or spills that occurred offsite at upstream locations. Because engineering controls (e.g., best management practices, silt fences/curtains, detention/retention basins, cofferdam) regulated by a combination of Tennessee Department of Environment and Conservation and U.S. Army Corps of Engineers permitting, and the Watts Bar Interagency Agreement, would be in use during building activities, the building-related impacts would be controlled, localized, and temporary.

Inadvertent spills of fluids such as gasoline have the potential to contaminate groundwater.

TVA would implement an Integrated Pollution Prevention Plan at the Clinch River Nuclear Site, which would include the use of best management practices to minimize the occurrence of spills and limit their effects. Groundwater-quality impacts identified would be localized and temporary, because groundwater discharges would be regulated by the National Pollutant Discharge Elimination System permit and best management practices would be used to minimize and control inadvertent spills.

The primary water-related impacts during operation would be associated with the cooling-water system for each new plant. The review team determined that the impacts of operations activities on the quality of surface water in the area would be limited for the following reasons:

• Stormwater and plant wastewater discharges would be subject to National Pollutant Discharge Elimination System permit requirements.

• Stormwater best management practices would be implemented, and the stormwater runoff from the site would be small compared to the flow of the Clinch River arm of Watts Bar Reservoir.

• Thermal and chemical mixing zones would be established in the National Pollutant Discharge Elimination System permit for plant wastewater discharges.

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• Maintenance dredging is not anticipated, but if needed, would meet permit and oversight requirements.

In addition, the effects of the discharge would be limited due to the mitigating action of a continuous flow of 400 cubic feet per second in the Clinch River arm of the Watts Bar Reservoir provided by the Melton Hill Dam bypass.

TERRESTRIAL ECOLOGY IMPACTS TVA has indicated that site preparation and development of project facilities would be conducted according to Federal and State regulations, permit conditions, and established best management practices. The site preparation and development-related impacts would affect a total of approximately 539 acres of terrestrial habitats, as well as additional lands in various existing transmission line corridors. These impacts would be spatially extensive, noticeably alter the terrestrial ecology of the local landscape, and may affect several adjacent important habitats on the Oak Ridge Reservation. Habitat loss and fragmentation would reduce the quality of mature forest for the Federally listed Indiana bat (Exhibit G), northern long-eared bat, and gray bat; as well as the unlisted tri-colored bat and little brown bat, which are petitioned for listing under the Endangered Species Act; one other bat species considered rare in Tennessee; and forest interior birds.

Based on information provided by TVA and the review teams independent evaluation, the review team concluded that the impacts of construction and preconstruction activities on terrestrial ecological resources would be MODERATE. This impact level is driven primarily by noticeable impacts on upland forests and other terrestrial habitats on and adjacent to the Clinch River Nuclear Site and barge/traffic area and associated impacts on wildlife, particularly Federally listed and rare species. TVA stated it would revegetate temporarily disturbed areas.

Wetland impacts would be mitigated in accordance with a wetland mitigation plan developed by TVA and reviewed by the U.S. Army Corps of Engineers before deciding whether to issue any permit, and reviewed by the NRC before deciding whether to issue any (Photo courtesy of Andrew King, U.S. Fish and Wildlife Service) combined construction EXHIBIT G. CLUSTER OF HIBERNATING INDIANA BATS permit and 12

operating license or combined license. All of the NRC-authorized construction actions would occur in areas disturbed as part of site preparation and development of the Clinch River Nuclear Site. However, the NRC-authorized construction would continue to introduce substantial noise and human activity into a predominantly natural surrounding landscape.

The potential impacts of operating activities at the Clinch River Nuclear Site and the associated cooling system (mechanical draft cooling towers) on terrestrial resources would be minor. The potential impacts of transmission line operation, including those from electromagnetic fields, and transmission line corridor maintenance on important species and habitats, including wetlands and floodplains, are considered minor, due to their limited spatial extent and assuming related best management practices are implemented.

AQUATIC ECOLOGY IMPACTS Aquatic habitats and organisms in the Clinch River could be affected by installation of the intake structure, discharge structure, improvements to the barge facility, and installation of a new culvert under the road in the Grassy Creek embayment. The embayment is part of the Clinch River arm of the Watts Bar Reservoir.

Based on its review of TVAs Environmental Report and other relevant information, the review team determined that the impacts of building the project facilities on aquatic resources would be SMALL. The review teams conclusion reflects the expectation that TVA would minimize the footprint of disturbance and implement appropriate best management practices to minimize sedimentation, erosion, and other disturbances to the reservoir, ponds, and streams. The conclusion also reflects an expectation that TVA would implement mitigation requirements established by the U.S. Army Corps Engineers as part of a Department of the Army permit for any physical disturbance of streams and other aquatic habitat on the Clinch River Nuclear Site and any streams crossed by building the proposed 69-kV underground transmission line to the Bethel Valley Substation. The conclusion also rests on an assumption that work on offsite overhead transmission lines would be limited to existing right-of-ways.

The potential impacts of operating activities at the Clinch River Nuclear Site and associated facilities would be minor. The potential impacts include temporary and permanent removal of water from the Clinch River, entrainment and impingement of biota during intake operation, thermal and chemical discharges from the discharge, and maintenance on transmission lines.

The review team expects that TVA would adhere to U.S. Environmental Protection Agency regulations on cooling-water intakes and would apply for and follow the requirements of a National Pollutant Discharge Elimination System permit issued by the State of Tennessee.

PROTECTED SPECIES TVA has indicated that site preparation and development of project facilities would be conducted according to Federal and State regulations, permit conditions, and commonly implemented best management practices. The site preparation and development-related impacts would affect a total of approximately 539 acres of terrestrial habitats. These impacts would be spatially extensive, noticeably alter the terrestrial ecology of the local landscape, and may affect several adjacent important habitats on the Oak Ridge Reservation. Habitat loss and 13

PROTECTED SPECIES Some species and/or critical habitat are protected by Federal laws, such as the Endangered Species Act of 1973. If a listed, protected species is found, the Federal agency must consult with either the U.S. Fish and Wildlife Service or National Marine Fisheries Service or both to determine if there is an adverse effect on the species or habitat.

fragmentation would reduce the quality of mature forest for roosting and foraging by three Federally listed bat species, including the Indiana bat, northern long-eared bat, and gray bat; as well as the tri-colored bat and little brown bat, which are petitioned for listing under the Endangered Species Act; and one other bat species considered rare in Tennessee. The impacts would also reduce the local availability of habitat for forest interior birds.

The U.S. Fish and Wildlife Service also provided a list of aquatic Federally protected species potentially located in the vicinity of the Clinch River Nuclear Site that it wanted to be considered in the EIS. The review team determined that aquatic Federally listed species (specifically the pink mucket, sheepnose mussel, and the Spotfin Chub) are likely not present at or in the vicinity of the Clinch River Nuclear Site and barge/traffic area. The review team has determined that building the new facilities at the Clinch River Nuclear Site and barge/traffic area would not likely affect aquatic Federally listed species, and would not substantially affect the commercial and recreational species and other important species. The U.S. Fish and Wildlife Service also recommended consideration of the hellbender, a large salamander that is currently petitioned for listing. Building activities would not likely affect the hellbender because it is unlikely to be present in the areas subject to disturbance.

SOCIOECONOMIC IMPACTS Physical impacts on workers and the general public would include those related to noise levels, air quality, existing buildings, transportation resources, and aesthetics. Physical impacts from noise would be mitigated with standard noise mitigation practices required by local ordinances, but still would affect the local residents in close proximity to the site, directly across the Clinch River from the Clinch River Nuclear Site. The increased pace of roadway degradation would require more frequent maintenance activities to mitigate the impacts. Impacts on visual aesthetics also would affect those living in close proximity to the site, those transiting local roadways, and recreationists using the Clinch River and other nearby recreation sites. These impacts would not be mitigated.

Infrastructure and community services impacts span issues associated with traffic, recreation, housing, public services, recreation resources, and education. Traffic impacts are expected to be localized, temporary, and adverse.

The review team has assessed the activities related to operating a new nuclear power plant at the Clinch River Nuclear Site and the potential socioeconomic impacts in the region and economic region. Physical impacts on workers and the general public include those on noise 14

levels and air quality. Other physical impacts apply to damage and soiling to existing structures, transportation infrastructure degradation (roads, water, and rail routes), and aesthetics.

Infrastructure and community services impacts span issues associated with traffic, recreation, housing, public services, and education. Recreational impacts would be higher in close proximity to the proposed site because of impacts on viewsheds from the increased industrial character of the Clinch River Nuclear Site, which would not be amenable to mitigation.

ENVIRONMENTAL JUSTICE IMPACTS The review team evaluated the impacts of building activities at the Clinch River Nuclear Site on environmental justice populations. The review team did not identify any potential environmental pathways by which the identified minority or low-income populations in the economic region would likely experience disproportionately high and adverse human health, environmental, physical, or socioeconomic effects as a result of building activities.

Based on the preceding analysis, and because the NRC-authorized construction activities represent only a part of the analyzed activities, the review team concluded that there would be no disproportionately high and adverse impacts on minority and low-income populations resulting from building activities at the Clinch River Nuclear Site.

The review team evaluated the impacts of proposed operations activities at the Clinch River Nuclear Site on environmental justice populations. The review team did not identify any potential environmental pathways by which the identified minority or low-income populations within a 50-mile demographic region or in the economic region would likely experience disproportionately high and adverse human health, environmental, physical, or socioeconomic effects as a result of operations activities.

HISTORIC AND CULTURAL RESOURCES Building and operation of a nuclear plant requires looking at the potential for effects on archaeological sites, historic buildings, and traditional places important to local groups. The NRC has determined that the direct-effects area of potential effect within its authority is the area at the Clinch River Nuclear Site and its immediate environs that may be directly or indirectly affected by activities associated with building and operating a new nuclear power plant. The offsite direct-effects area of potential effect is confined to the Melton Hill Dam structure, and the indirect-effects area of potential effect is defined as a 0.5-mile area around the Melton Hill Dam.

Building activities occurring in offsite areas have the potential to impact offsite historic and cultural resources. These activities include installation of a new 69-kV underground line within an existing TVA transmission line right-of-way, upgrades to existing TVA transmission right-of-ways, borrow area developments, and installation of a bypass at the Melton Hill Dam.

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The review team considered

• NRCs ongoing consultation with 20 American Indian Tribes and the Tennessee Historical Commission

• TVAs executed Programmatic Agreement describing its ongoing National Historic Preservation Act (NHPA) Section 106 compliance, including commitments to avoid, minimize, mitigate, and resolve adverse effects on National Register of Historic Places (NRHP)-

eligible resources that cannot be avoided and AREAS OF POTENTIAL EFFECT NHPA and Native American Graves Protection and Repatriation Act inadvertent discovery and A geographic area in which an action notification provisions may change the character or use of a historic property.

• potential irretrievable damage to 16 NRHP potentially eligible archaeological sites, 1 NRHP-eligible archaeological site, and deeply buried archaeological deposits if in situ stabilization is not possible

• potential impacts on the NRHP-eligible Melton Hill Dam Historic District (Exhibit H) and on other historic and cultural resources that could be located in other offsite areas (i.e.,

transmission lines and borrow areas).

While some impacts as a result of project activities are not within NRCs regulatory authority, the NRC staff has reviewed TVAs NHPA Section 106 compliance activities for all project activities and estimated impacts at the Clinch River Nuclear Site. TVA has concluded that its undertaking to obtain an ESP for future demonstration of the suitability of the Clinch River Nuclear Site for potential future building and operation of two or more small modular reactors has the potential to adversely affect an unknown number of the 16 potentially NRHP-eligible properties and 1 NRHP-eligible site (40RE233) and has executed a Programmatic Agreement to address its ongoing NHPA Section 106 responsibilities because specific plans have not been finalized.

(Photo courtesy of the TVA)

EXHIBIT H. MELTON HILL DAM 16

METEOROLOGICAL AND AIR-QUALITY IMPACTS The review team evaluated potential impacts on air quality associated with criteria pollutants and greenhouse gas emissions during Clinch River Nuclear Site building activities and determined that the impacts would be minimal.

The review team evaluated potential impacts on air quality associated with criteria pollutants and greenhouse gas emissions from operating a new nuclear power plant at the Clinch River Nuclear Site. The review team also evaluated potential impacts of cooling-system emissions.

In each case, the review team determined that the impacts would be minimal.

NONRADIOLOGICAL HEALTH IMPACTS The review team evaluated health impacts on the public and workers from the proposed cooling system, noise generated by plant operations, acute and chronic impacts of electromagnetic fields, and transporting operations and outage workers to and from the proposed Clinch River Nuclear Site. Health risks to workers are expected to be dominated by occupational injuries at rates higher than the average U.S. industrial rates. However, the review team determined that the higher occupational injury rate would not result in a noticeable impact. Health impacts on the public from noise generated by plant operations would be minor. Health impacts on the public and workers from disease-causing agents and acute impacts of electromagnetic fields would be minimal. The review team reviewed available scientific literature about the chronic effects of electromagnetic field on human health and found that the scientific evidence regarding the chronic effects of extremely low frequency-electromagnetic field exposure on human health does not conclusively link extremely low frequency-electromagnetic field exposure to adverse health impacts.

RADIOLOGICAL HEALTH IMPACTS If small modular reactors at the Clinch River Nuclear Site become operational, the sources of radiation exposure from normal operations for plant workers at the Clinch River Nuclear Site would include direct radiation exposure and gas and liquid effluent releases. The public, plants, and animals nearby could also receive a radiation dose from the nuclear units through direct exposure, gas effluent releases (breathing or by eating food grown or raised in the vicinity upon which radioactive material dispersed in the atmosphere may have been deposited), and liquid effluent releases (by drinking water or eating aquatic foods where discharged radioactive material became mixed with local surface water and groundwater), as shown in Exhibit I and Exhibit J.

TVA estimated the annual collective total body dose within a 50-mile radius of the Clinch River Nuclear Site to be 68 person-rem/yr. These risks are well below NRC safety goals. The review team concluded there would be no observable health impacts on the public from normal operation of the proposed new units.

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EXHIBIT I. EXPOSURE PATHWAYS TO MAN 18

EXHIBIT J. EXPOSURE PATHWAYS TO WILDLIFE AND PLANTS 19

NONRADIOLOGICAL WASTE IMPACTS Nonradioactive waste that would be generated, handled, and disposed of include construction debris, spoils, stormwater runoff, municipal and sanitary waste, dust, and air emissions.

Solid, liquid, and gaseous wastes generated during building and operation at the Clinch River Nuclear Site would be handled according to county, State, and Federal regulations. County and State standards and regulations for handling and disposal of solid waste would be obtained and implemented. A National Pollutant Discharge Elimination System permit that would include a stormwater pollution prevention plan for surface-water runoff and groundwater quality, and the use of temporary, portable facilities for sanitary waste systems during the construction period would ensure compliance with the Clean Water Act and the State of Tennessee standards.

Discharges to the Clinch River of liquid effluents used for operations, including wastewater and stormwater, would be controlled and limited via a National Pollutant Discharge Elimination System permit. Air emissions from unit operations would be compliant with local, State, and Federal air-quality standards and regulations. The impacts of mixed-waste generation, storage, and disposal during operation of proposed units would be compliant with requirements and standards.

SUMMARY

OF ENVIRONMENTAL IMPACT LEVELS Exhibit K lists the impacts associated with the building and operation of small modular reactors at the Clinch River Nuclear Site on each resource area. A determination of NONE for environmental justice analyses does not mean there are no adverse impacts on minority or low-income populations from the proposed project. Instead, an indication of NONE means that while adverse impacts do exist, they do not affect minority or low-income populations in any disproportionate manner relative to the general population. Additional information about resource impacts may be found in the EIS.

EXHIBIT K. IMPACTS ON RESOURCES Resource Category Building Operation Land use MODERATE SMALL Water-related Surface-water use SMALL SMALL Groundwater use SMALL SMALL Surface-water quality SMALL SMALL Groundwater quality SMALL SMALL Ecology Terrestrial ecosystems MODERATE SMALL Aquatic ecosystems SMALL SMALL Socioeconomic Physical impacts SMALL to MODERATE SMALL to MODERATE (aesthetics) 20

EXHIBIT K. IMPACTS ON RESOURCES (CONTD)

Resource Category Building Operation Demography SMALL SMALL Economic impacts on the SMALL SMALL (beneficial to community (beneficial to the region) the region)

Infrastructure and community SMALL (for all categories except SMALL to services traffic) and MODERATE to LARGE MODERATE (for traffic) (recreation)

Environmental justice NONE NONE Historic and cultural resources MODERATE to LARGE SMALL Air quality SMALL SMALL Nonradiological health SMALL to MODERATE SMALL to MODERATE Radiological health SMALL SMALL Nonradiological waste SMALL SMALL Postulated accidents NA SMALL Fuel cycle, transportation, and NA SMALL decommissioning How Can the Impacts Be Reduced?

Many of the SMALL impacts are considered minimal because monitoring and use of environmental practices and safeguards would reduce any negative effects on an environmental resource. However, some of the impacts greater than SMALL can be reduced or compensated, or prevented from becoming disruptive.

HISTORIC AND CULTURAL RESOURCES TVA has executed a Programmatic Agreement describing its ongoing NHPA Section 106 compliance. The Agreement includes commitments to avoid, minimize, mitigate, and resolve adverse effects on NRHP-eligible resources that cannot be avoided. It also contains inadvertent discovery and notification provisions related to NHPA and Native American Graves Protection and Repatriation Act.

MEASURES AND CONTROLS TO LIMIT ADVERSE IMPACTS In its evaluation of potential environmental impacts caused during building and operation of two or more small modular reactors at the Clinch River Nuclear Site, the review team relied on TVAs compliance with the following measures and controls that would limit adverse environmental impacts:

• compliance with applicable Federal, State, and local laws, ordinances, and regulations intended to prevent or minimize adverse environmental impacts (e.g., solid waste management, erosion and sediment control, air emissions control, noise control, stormwater management, discharge prevention and response, hazardous material management) 21

• compliance with applicable requirements of permits or licenses required for construction of a new nuclear power plant at the Clinch River Nuclear Site (e.g., Department of the Army Section 404 Permit, National Pollutant Discharge Elimination System permit)

• compliance with existing TVA processes and/or procedures applicable for environmental compliance activities during construction and preconstruction at the Clinch River Nuclear Site (e.g., solid waste management, hazardous waste management, and discharge prevention and response)

• incorporation of environmental requirements into construction contracts

• identification of environmental resources and potential impacts during the ESP process and the development of revisions to the TVA Environmental Report.

The review team considered these measures and controls in its evaluation of the impacts of plant building and operation. They are fully analyzed in Sections 4.11 and 5.12 of the EIS. For many environmental resource area, some kind of coordination with another Federal, State, or local agency is required to gain permission to build and operate small modular reactors at the Clinch River Nuclear Site. The required permits and certifications are listed in Appendix H of the EIS. Exhibit L provides a summary of some of the planned activities to help minimize environmental effects from building and operating two or more small modular reactors at the Clinch River Nuclear Site within the plant parameter envelope. Exhibit L is derived from EIS Tables 4-13 and 5-19.

EXHIBIT L.

SUMMARY

OF PLANNED MEASURES AND CONTROLS TO MINIMIZE ENVIRONMENTAL IMPACTS Resource Area Impact Minimization Plan Land Use

• Use stormwater management plans to control erosion and runoff.

• Return temporarily disturbed lands to former uses upon completion of construction.

• Offset loss of wetland impacts by mitigation expected to be required by the Department of the Army Permit.

• Allow temporarily disturbed wetland areas to return to former conditions upon completion of construction.

• Limit ground disturbances to the smallest amount of area necessary to construct and maintain the plant.

• Perform ground-disturbing activities in accordance with regulatory and permit requirements; use adequate best management practices erosion-control measures to minimize impacts.

• Restrict soil stockpiling and reuse to designated areas.

• Use best management practices and stormwater management plans to control erosion and runoff, minimize clearing, wetlands impacts, and vegetation impacts.

• Limit ground-disturbing activities such as vegetation removal to established transmission line corridors.

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EXHIBIT L. PLANNED MEASURES AND CONTROLS TO MINIMIZE ENVIRONMENTAL IMPACTS (CONTD)

Resource Area Impact Minimization Plan Water-Related

• Comply with applicable regulations, permits, and plans.

Impacts

• Grout fractures, cavities, and solution openings in the excavated rock face.

Monitor effects of dewatering using groundwater wells.

• Establish and implement a stormwater pollution prevention plan.

• Use best management practices in addition to TVA, U.S. Army Corps of Engineers, and Tennessee Department of Environment and Conservation controls to protect affected waterbodies.

• Apply best management practices as found in stormwater regulations and procedures.

• Revegetate construction areas in a timely manner.

• Install drainage controls to direct dewatering runoff.

• Conduct any excavation along the shoreline in accordance with the terms of the 1991 Watts Bar Interagency Agreement.

• Minimize potential spills of chemicals and petroleum materials and hazardous wastes through training, spill prevention plans, and rigorous compliance with applicable regulations and procedures.

• Use best management practices to maintain equipment and prevent spills and leaks.

• Train appropriate employees in methods for preventing and/or responding to spills.

• Establish and implement an Integrated Pollution Prevention Plan for construction practices.

• Design cooling towers to limit drift and evaporative water loss.

• Follow the procedures of the TVA Drought Management Plan during drought conditions.

• Manage stormwater in accordance with a site-specific stormwater pollution prevention plan.

• Design the diffuser to meet the objectives of maximizing thermal and chemical mixing while minimizing scour and hydrologic modifications.

• Limit wastewater discharges and comply with the Tennessee Department of Environment and Conservation (TDEC) National Pollutant Discharge Elimination System permit.

• Follow the TDEC-approved Biocide/Corrosion Treatment Plan.

• Comply with State water-quality standards and TVA procedures associated with thermal discharges.

• Minimize the potential of hazardous materials/waste spills or releases through training and rigorous compliance with the Resource Conservation and Recovery Act of 1976, as amended, and applicable regulations and TVA procedures, and implementation of a site-specific Integrated Pollution Prevention Plan.

Terrestrial

• In temporarily disturbed areas, revegetate and allow natural succession, resulting Ecosystems in a reduction of long-term ecological impacts in these areas.

• To the extent feasible, plan facility construction to take place in previously disturbed areas.

• Use best management practices to prevent impacts on adjacent habitats, such as from erosion and runoff of sediment.

• To the extent feasible, plan facility locations and construction activities to avoid wetlands.

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EXHIBIT L. PLANNED MEASURES AND CONTROLS TO MINIMIZE ENVIRONMENTAL IMPACTS (CONTD)

Resource Area Impact Minimization Plan Terrestrial

• Limit vegetation removal and construction activities to construction sites, Ecosystems underground transmission line right-of-ways, and access roads. Use established (contd) procedures for minimizing erosion and revegetating terrestrial habitats not permanently used for facilities.

• Limit ground disturbance to existing right-of-way lands when upgrading offsite transmission lines and when installing the buried 69-kV transmission line. Locate transmission line towers such that wetlands and riparian areas are spanned by the conductors.

• Minimize potential impacts through compliance with permitting requirements, best management practices, and TVA procedures.

• As appropriate, train employees on how to perform work in a manner that reduces adverse environmental impacts; to the extent feasible, avoid any additional disturbances to sensitive terrestrial or wetland habitats/species.

• Identify sensitive areas requiring restrictions on types of vegetation maintenance.

• As practical, reseed cleared areas to limit erosion using noninvasive species/native plants, per TVA procedures.

• Use licensed operators to apply herbicides.

• Comply with the TDEC General Permit for Pesticide Discharges (includes herbicides).

• As practicable, use noise suppression/mufflers on vehicles/machinery and other engineering controls such as earthen berms and placing foliage between noise sources and receptors.

Aquatic

• Install cofferdams or similar engineering protective measures around the sites Ecosystems when building or installing the intake and discharge.

• Employ best management practices to minimize erosion and sedimentation.

• Attempt, to the extent feasible, to tunnel under streams when installing the buried 69-kV transmission line.

• Restore any disturbance to streams immediately after work is completed.

• Install stormwater drainage systems at large construction sites and stabilize disturbed soils.

• Maintain streamside management zones appropriately.

• Extend new conductors across waterways within the existing right-of-ways without conducting in-water work or disturbing shorelines to the extent possible.

• Minimize potential impacts through compliance with permitting requirements, best management practices, and TVA procedures.

• Identify streamside management zones and place restrictions on the type of vegetation management activities performed there.

• To the extent feasible, avoid any additional disturbances to sensitive aquatic habitats/species.

Socioeconomics

• Manage major high noise construction activities to limit and minimize noise and impacts on residences in the vicinity.

Environmental

• Use best management practices for controlling fugitive dust and proper Justice maintenance of construction equipment for controlling emissions.

• Train and appropriately protect employees and construction workers to reduce the risk of potential exposure to noise, dust, and exhaust emissions.

• To the extent possible, recycle construction wastes and dispose the remaining waste in approved landfills.

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EXHIBIT L. PLANNED MEASURES AND CONTROLS TO MINIMIZE ENVIRONMENTAL IMPACTS (CONTD)

Resource Area Impact Minimization Plan

• Stabilize cleared areas, minimize disturbance and visual intrusion, and remove construction debris in timely manner.

• Install traffic controls and roadway modifications and additional turning capacity to mitigate traffic delays; construction workforce will work in up to three shifts to spread additional construction traffic volume over a 24-hour period (one 10-hour shift and occasional night and weekend shifts).

• Provide onsite services for emergency first aid, and conduct regular health and safety monitoring.

• Stagger shifts, encourage carpooling, and time deliveries to avoid shift change or commute times.

• Erect signs alerting drivers of construction and the potential for increased construction traffic.

• Use procedures and employee training program to reduce the potential for traffic accidents.

• Operate air emissions sources and monitor release of air emissions in accordance with State and Federal regulations, air permit requirements, and TVA procedures.

• Include efficient drift eliminators to minimize drift emissions from cooling towers.

• Manage thermal discharge from cooling-water systems in accordance with requirements of the TDEC National Pollutant Discharge Elimination System permit and TVA procedures.

• Use roadway improvements from construction to offset impacts expected during operations.

Historic and

• TVA has executed a Programmatic Agreement describing its ongoing National Cultural Historic Preservation Act (NHPA) Section 106 compliance including Properties commitments to avoid, minimize, mitigate, and resolve adverse effects on National Register of Historic Places-eligible resources that cannot be avoided and NHPA and Native American Graves Protection and Repatriation Act (NAGPRA) inadvertent discovery and notification provisions.

• TVA would conduct operation and maintenance activities in compliance with NHPA Section 106 and would avoid, minimize, or mitigate potential operation-related impacts on historic and cultural resources. TVA would also comply with the NAGPRA, Archaeological Resources Protection Act, Archaeological and Historic Preservation Act, NHPA, American Indian Religious Freedom Act, Executive Orders 13007 (Indian Sacred Sites) and 13175 (Consultation and Coordination with Indian Tribal Governments).

• TVA also maintains procedures and management plans that consider impacts on historic and cultural resources during operations. If archaeological resources or human remains are encountered during operations, TVA has NHPA Section 106 and NAGPRA inadvertent discovery procedures requiring stop work and consulting party notifications.

Nonradiological

• Comply with Federal, State, and local regulations governing construction Health activities and construction vehicle emissions.

• Comply with Federal, State, and local regulations governing noise from construction activities and increased traffic in the local area.

• Comply with Federal and State occupational safety and health regulations; and implement traffic management plan.

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EXHIBIT L. PLANNED MEASURES AND CONTROLS TO MINIMIZE ENVIRONMENTAL IMPACTS (CONTD)

Resource Area Impact Minimization Plan

• Minimize potential impacts through compliance with permitting requirements; best management practices; State, local, and Federal requirements; and TVA procedures.

• Minimize night and weekend maintenance operations to reduce noise impacts.

• Use mitigation measures to decrease the electromagnetic fields related to the underground transmission line.

• Maintain vertical clearance from the ground for overhead transmission lines and safety procedures to prevent direct contact with the underground transmission line.

Radiological

• Train construction workers in radiation safety procedures.

Health

• Develop work plans that consider methods for reducing radioactive exposures to levels that are as low as reasonably achievable.

• Monitor doses received by construction workers to ensure they are within regulatory limits.

• Confirm doses from planned releases of radiation are less than the limits prescribed under Title 10 of the Code of Federal Regulations (10 CFR) 20.1301 and 40 CFR Part 190.

• Implement a radiological environmental monitoring program to monitor specified exposure pathways.

• Minimize effluent discharges in accordance with applicable regulations.

• Confirm calculated doses for biota other than humans are within National Council on Radiation Protection and Measurements and International Atomic Energy Agency guidelines.

• Implement an annual offsite radiological environmental monitoring program to evaluate potential exposures and doses to biota other than humans and the environment.

Nonradioactive

• Manage hazardous and nonhazardous solid wastes according to county, State, Waste and Federal handling and transportation regulations.

• Implement recycling and best management practices to minimize waste generation.

• Establish procedures for, and perform audits to verify, waste disposal according to applicable regulations such as the Resource Conservation and Recovery Act of 1976, as amended.

• Establish a waste minimization program.

• Develop and follow a waste minimization plan to reduce the amount of waste that is generated.

• Release hazardous air emissions according to limits imposed by the Clean Air Act Amendments of 1977, as amended, the Clean Air Act regulations, and TVA procedures.

• Release hazardous water effluents according to limits imposed by the Clean Water Act/Federal Water Pollution Control Act and National Pollutant Discharge Elimination System program and permit requirements, and TVA procedures.

• Manage, treat, and dispose of hazardous waste according to Resource Conservation and Recovery Act regulations and TVA procedures.

• Generate and dispose of nonhazardous nonradioactive waste according to applicable local, State, and Federal regulations, including the Solid Waste Disposal Act, as amended, 40 CFR Part 261, Identification and Listing of Hazardous Waste, and TVA procedures.

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EXHIBIT L. PLANNED MEASURES AND CONTROLS TO MINIMIZE ENVIRONMENTAL IMPACTS (CONTD)

Resource Area Impact Minimization Plan

• Perform inspections for compliance with applicable waste management laws and regulations and TVA procedures.

• As appropriate, train employees to follow applicable procedures and waste regulations.

• Comply with current Waste Minimization Plan developed for existing TVA reactors to address hazardous waste management, treatment (decay in storage),

work planning, waste tracking, and awareness training.

What Is the Relationship of this Project with Other Projects in the Area?

Cumulative impacts may result when the environmental effects associated with the proposed project are added to the temporary or permanent effects associated with past, present, and near-future projects. Cumulative impacts can result from the combination of effects that might have been minor by themselves, but become more noticeable when affecting the same resource over a period of time.

The review team developed Exhibit M, which shows the major projects near the Clinch River Nuclear Site that were considered relevant in the analysis of cumulative impacts. The review team used this information, the environmental setting discussed in EIS Chapter 2, and impacts described in EIS Chapters 4 and 5 to perform an independent evaluation of cumulative impacts of the proposed action at the Clinch River Nuclear Site.

EXHIBIT M. PROJECTS AND OTHER ACTIONS CONSIDERED IN THE CUMULATIVE IMPACTS ANALYSIS FOR THE CLINCH RIVER NUCLEAR SITE Project Name Summary of Project Federal Facilities Oak Ridge Reservation Federally owned 13,547-hectare (33,476-acre) site, comprising government and contractor-operated facilities; includes laboratories, support facilities, environmental cleanup sites, training facilities, and research entities Oak Ridge National Laboratory Science and energy U.S. Department of Energy laboratory; supercomputers, neutron science and nuclear energy research; Transuranic Waste Processing Center Y-12 National Security Complex Produces and stores U.S. enriched uranium for nuclear weapons and (Y-12 Complex) the Navy East Tennessee Technology Originally part of the K-25 site (produced enriched uranium during the Park Manhattan Project), it covers 2,200 acres. Restoration of the area, including environmental cleanup, facility deactivation and decommissioning, waste disposition, and reindustrialization is ongoing.

Environmental Management An engineered landfill consisting of six disposal cells; accepts low-level, Waste Management Facility mixed low-level, and hazardous wastes from Oak Ridge Reservation sites 27

EXHIBIT M. PROJECTS AND OTHER ACTIONS CONSIDERED IN THE CUMULATIVE IMPACTS ANALYSIS FOR THE CLINCH RIVER NUCLEAR SITE (CONTD)

Project Name Summary of Project Uranium Processing Facility Will produce enriched uranium at the Y-12 Complex at Oak Ridge Bear Creek Valley Low-Level Comprehensive Environmental Response, Compensation, and Waste Landfill Liability Act disposal facility on the Oak Ridge Reservation with a potential capacity of 2.2 to 2.8 million cubic yards Energy Projects Nuclear Watts Bar Nuclear Generating Two operating pressurized water reactors rated at 3,459 MW(t) each Station Units 1 and 2 Sequoyah Nuclear Generating Two operating pressurized water reactors rated at 3,455 MW(t) each Station Units 1 and 2 Coal-Fired Kingston Fossil Plant 1,400-MW net-capacity coal-fired plant Bull Run Fossil Plant 881-MW net-capacity coal-fired plant Natural Gas-Fired University of Tennessee Steam 3.7-MW net-capacity combustion turbine Plant Tate and Lyle Loudon Facility Two 33-MW gas turbines and two generators for heat and power Co-Generation Plant Landfill Methane Gas Alcoa/ Maryville/ Blount County 1-MW capacity, reciprocating engine Landfill Chestnut Ridge Landfill 4.8-MW capacity, reciprocating engine Meadow Branch Landfill Landfill gas-collection system; delivered 1,400 MMBtu/day in 2011; Methane Recovery Project 4,000 scfm processing capability Volunteer Regional Landfill Landfill gas-collection system; 0.76 Mscf/day collected in 2012 Solar Oak Ridge Solar Park Installed capacity 49.8 kWp DC, 42 kW AC; annual yield 94,000 kWh Wind Buffalo Mountain Energy Center Wind turbines with a 27-MW capacity Hydropower Melton Hill Hydroelectric Facility Two generating units at the Melton Hill Dam with a net capacity of 79 MW upstream on the Clinch River Fort Loudoun Dam Four generating units with a net capacity of 162 MW on the Tennessee River Norris Dam Two generating units with a net capacity of 110 MW upstream on the Clinch River Smoky Mountain Hydro Four hydro dams: Chilhowee (three generating units with a total capacity of 52.2 MW), Calderwood (three generating units with a total capacity of 140.4 MW), Cheoah (five generating units with a total capacity of 140 MW), and Santeetlah (two generating units with a total capacity of 40.4 MW) on the Little Tennessee River 28

EXHIBIT M. PROJECTS AND OTHER ACTIONS CONSIDERED IN THE CUMULATIVE IMPACTS ANALYSIS FOR THE CLINCH RIVER NUCLEAR SITE (CONTD)

Project Name Summary of Project Watts Bar Dam Five generating units with a net capacity of 182 MW on the Tennessee River downstream of Clinch River Fontana Dam Three generating units with a net capacity of 304 MW on the Little Tennessee River Douglas Dam Four generating units with a net capacity of 111 MW on the French Broad River Transmission Lines/Substations Rugby-Sunbright Transmission Construction of a new Rugby Substation plus 7.25 miles of power System line consisting of steel pole structures on a 100-foot right-of-way Plateau 500-kV Substation Clearing and grading of the site began in 2015; site completion and linkage to the Wilson-Roane and West Cookeville-Rockwood transmission lines scheduled for 2018 Roane-Pineville 500-kV 70-mile-long transmission line Transmission Line Mining Projects Coal Mining Miscellaneous surface and deep mining projects Endsley Quarry Marble quarry Lhoist North America Crushed and broken limestone Apac Atlantic Inc. Harrison Sand and gravel Division Sand Mine 1 Vulcan Construction Materials Concrete, asphalt, aggregates, crushed rock, and lime manufacturing Aggregates USA Crushed and broken limestone Various gas and oil projects Gas and oil wells Parks and Recreation Activities Federal Manhattan Project National Includes the X-10 Graphite Reactor Historic Landmark, Buildings Historical Park (Three Sites) 9731 and 9204-3 at the Y-12 Complex, and the site of the K-25 building at the Oak Ridge Reservation Big South Fork National River Consists of 125,000 acres of the Cumberland Plateau; the area and Recreation Area offers, hiking, biking, whitewater paddling, horseback riding, rock climbing, camping, and other recreation Great Smoky Mountains National Includes over 522,400 acres in Tennessee and North Carolina; the Park park offers camping, hiking, picnicking, fishing, and other recreation Daniel Boone National Forest Offers hiking, biking, fishing, rock climbing, boating, target shooting, camping, and picnicking State Frozen Head State Park Consists of over 24,000 acres of wilderness, included backpacking and day hiking trails Fort Loudoun State Historic Park A 1,200-acre National Historic Landmark and site of an early British fortification built in 1756 Norris Dam State Park Located on the shores of Norris Lake; offers recreational boating, skiing, fishing, hiking, camping, and a museum; consists of more than 4,000 acres 29

EXHIBIT M. PROJECTS AND OTHER ACTIONS CONSIDERED IN THE CUMULATIVE IMPACTS ANALYSIS FOR THE CLINCH RIVER NUCLEAR SITE (CONTD)

Project Name Summary of Project Cove Lake State Park A 717-acre park that offers scenic nature trails for walking and biking, fishing, and camping Big Ridge State Park A 3,687-acre park that offers hiking trails, camping, swimming, and recreation Cumberland Mountain State A 1,720-acre park offering hiking, swimming, camping, and Park interpretive programs Seven Islands State Birding Park Consisting of 416 acres along the French Broad River, the park is a wildlife refuge and research and educational facility for schools Hiwassee/Ocoee Scenic River Consisting of 23 river miles of the Hiwassee and Ocoee Rivers, the State Park park offers rafting, fishing, and camping Non-Hydroelectric Dams Tellico Dam Flood control and recreation on the Little Tennessee River; the reservoir offers 357 miles of shoreline and 15,560 acres of water surface for recreation Transportation Projects Airports Several airports including Knoxville Downtown Island, Raby Airpark, Skyranch, Oliver Springs, and McGhee Tyson airports Oak Ridge Airport General aviation airport Chickamauga Lock Construction of a lock to replace the current transportation lock at Chickamauga Dam Miscellaneous transportation Road and traffic projects; bridge replacements projects Other Actions/Projects Tellico West Industrial Park 5- to 260-acre sites for industrial development Rockwood Iron and Metal Former ironworks and metals operations; non-National Priorities List Superfund (Brownfields) site Smoky Mountain Smelters Former fertilizer and smelting operations; Superfund National Priorities List Air emissions sources EnergySolutions, LLC Bear Low-level radioactive waste processing facility Creek Facility Diversified Scientific Services, Hazardous waste-treatment, storage and disposal facility Inc.

Materials and Energy Mixed-waste processing facility Corporation Carlisle Tire Tire manufacturer Toho Tenax America, Inc. Manufacturer of carbon fibers Various hospitals and industries Medical and other industrial isotopes that use radioactive materials Various wastewater-treatment Sewage treatment plant facilities 30

EXHIBIT M. PROJECTS AND OTHER ACTIONS CONSIDERED IN THE CUMULATIVE IMPACTS ANALYSIS FOR THE CLINCH RIVER NUCLEAR SITE (CONTD)

Project Name Summary of Project Future Urbanization Construction of housing units and associated commercial buildings, roads, bridges and rail; and water-treatment and distribution facilities and associated pipelines as described in local planning documents Manufacturing Proton Power Manufacturer of a renewable energy system that produces hydrogen using biomass and waste LeMond Composites Manufacturer of carbon fiber composites Nuclear Lead Co, Inc. Manufacturer of lead shielding for the nuclear industry Manufacturing Sciences Manufacturer and processor of technology metals Corporation Canberra Producer of germanium crystals Advanced Measurement Manufacturer of scientific instruments and electronic parts for various Technology radiation detector components Tate and Lyle Loudon Facility Manufacturer of corn syrup and fuel alcohol ArcelorMittal LaPlace, LLC Manufacturer of steel shapes Kimberly-Clark Corporation Manufacturer of paper towels and bath tissue Kimble Chase Life Science and Manufacturer of reusable, disposable, and specialty glassware Research Products Horsehead Corporation Secondary smelting and refining of nonferrous metals Clinton Pallet Manufacturer of pallets Shawmut Advanced Material Manufacturer of laminate Solutions 3M Company Manufacturer MHF Packaging Solutions, LLC Manufacturer of metal containers PolyOne Corporation Manufacturer of plastic pellets for use in molding in the automotive, medical, and appliance industries Doral Steel Manufacturer of steel Aisin Automotive Casting Manufacturer of aluminum automotive engine parts Tennessee, Inc.

Keurig Green Mountain Production facility Various Iron Works Manufacturers of iron, including Capps Crabtree, Pips, Towe, Volunteer, and Miller Other industrial and Manufacturing and industrial plants manufacturing facilities 31

EXHIBIT N. COMPARISON OF CUMULATIVE IMPACTS AT THE PROPOSED CLINCH RIVER NUCLEAR SITE AND THREE ALTERNATIVE SITES Redstone CRN Site ORR Site 2 ORR Site 8 Arsenal Site 12 Land Use MODERATE MODERATE MODERATE MODERATE Surface Water Use MODERATE MODERATE MODERATE MODERATE Groundwater Use SMALL SMALL SMALL MODERATE Surface-Water Quality MODERATE MODERATE MODERATE MODERATE Groundwater Quality MODERATE MODERATE MODERATE MODERATE Terrestrial and Wetland Resources MODERATE LARGE LARGE MODERATE Aquatic Resources LARGE LARGE LARGE LARGE Socioeconomics Physical Impacts SMALL to SMALL to SMALL to SMALL to MODERATE MODERATE MODERATE MODERATE Demography SMALL SMALL SMALL SMALL Taxes and Economy SMALL SMALL SMALL SMALL (beneficial) (beneficial) (beneficial) (beneficial)

Infrastructure and Community MODERATE MODERATE MODERATE MODERATE to Services to LARGE to LARGE to LARGE LARGE Environmental Justice None None None None Historic and Cultural Resources MODERATE MODERATE MODERATE MODERATE to to LARGE to LARGE to LARGE LARGE Air Quality Criteria pollutants SMALL SMALL SMALL SMALL Greenhouse gas emissions MODERATE MODERATE MODERATE MODERATE Nonradiological Health SMALL to SMALL to SMALL to SMALL to MODERATE MODERATE MODERATE MODERATE Radiological Health SMALL SMALL SMALL SMALL Waste Management SMALL SMALL SMALL SMALL Postulated Accidents SMALL SMALL SMALL SMALL Cumulative impact determinations were taken from Table 9-14 in the draft EIS.

CRN = Clinch River Nuclear; ORR = Oak Ridge Reservation.

DISCUSSION OF IMPACT DIFFERENCES The environmental impact levels of a few of the environmental resource areas were determined to change from minor effects to more noticeable impacts when considered in combination with other past, present, and near-future projects near the Clinch River Nuclear Site.

• Surface-water use - The extensive past and present modification in the Clinch River basin is the primary driver of the review teams change in impact level. However, the cooling-water discharge from the Clinch River Nuclear Site by itself would have minimal effects.

• Air quality - The national and worldwide cumulative impacts of greenhouse gas emissions have noticeable effects. Small modular reactors at Clinch River Nuclear Site would not significantly contribute to greenhouse gas emissions in the region.

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What Alternatives Were Considered?

NO ACTION Under the no-action alternative the NRC would not issue the ESP. There are no environmental impacts associated with not issuing the ESP, and the impacts predicted in this EIS associated with building and operating two or more small modular reactors at the Clinch River Nuclear Site or at any one of the alternative sites would not occur. In this context, the no-action alternative would accomplish none of the benefits intended by the ESP process, which would include the following:

• early resolution of siting issues prior to large investments of financial capital and human resources in new plant design and construction

• early resolution of issues related to the environmental impacts of construction and operation of new nuclear units that fall within the plant parameters for small modular reactor nuclear generation units

• the ability to bank sites on which nuclear plants might be located

• the facilitation of future decisions about whether to construct new nuclear power-generation facilities.

ALTERNATIVE SITES Candidate areas for siting two new nuclear reactors were chosen by TVA after considering areas within TVAs Power Service Area using the following criteria:

• availability of land

• proximity to a water source

• proximity to sensitive resources such as wetlands

• proximity to transmission lines and existing transportation infrastructure

• obvious topographic concerns

• flexibility to optimize site layout and design for environmental and cost mitigation purposes.

Further review of the candidate areas by TVA included locations at which a minimum of 120 contiguous acres were available, preferably in a square configuration. Nearby parcels were evaluated for use as laydown area and parking area that could accommodate the construction of two or more small modular reactors at the alternative site. Because access to a water source is essential, preference was given to sites immediately adjacent to or within 0.5 mile of a primary water source. Easy access to transmission lines (onsite or within 5 miles) and the availability of existing transportation infrastructure were also considered. Ultimately, four candidate sites were chosen for additional site suitability analyses, which resulted in the Clinch River Nuclear Site (Oak Ridge Reservation Site 3) being chosen as the preferred site. The candidate sites are shown in Exhibit O. The remaining three sites examined are listed as alternative sites in the draft EIS:

• Redstone Arsenal Site 12 in Madison County, Alabama

• Oak Ridge Reservation Site 8 in Roane County, Tennessee

• Oak Ridge Reservation Site 2 in Roane County, Tennessee.

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The review team concluded that all of the sites were generally comparable, and it would be difficult to state that one site is preferable to another from an environmental perspective. In such a case, the proposed site prevails because none of the alternatives is clearly environmentally preferable.

EXHIBIT O. THE REGION OF INTEREST AND CANDIDATE SITES ALTERNATIVE ENERGY SOURCES Commission regulations recognize that certain matters need not be resolved at the ESP stage (e.g., an assessment of the benefits, need for power, and energy alternatives) and, thus, may be deferred until an applicant decides to apply for a construction permit or combined license.

The draft EIS does not include an assessment of the need for power or energy alternatives.

ALTERNATIVE SYSTEM DESIGNS The review team considered a variety of alternatives for heat-dissipation systems and cooling-water systems. About two-thirds of the heat from a commercial nuclear reactor is rejected as heat to the environment. The remaining one-third of the reactors generated heat is converted into electricity. Normal heat-dissipation systems transfer this rejected heat into the atmosphere as evaporation and/or heated discharge water to mix with nearby waterbodies. The majority of the heat dissipation for the proposed plant at the Clinch River Nuclear Site would be via evaporation of water in the mechanical draft (wet) cooling towers. The review team considered several alternative heat-dissipation systems, but found none to be environmentally preferable to the proposed mechanical draft wet-tower cooling system.

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Cooling-water systems withdraw water (intake) from the Clinch River, circulate the water to remove the heat, and return a slightly reduced volume of water to the receiving waterbody at a higher temperature (discharge). One of the main interactions a nuclear power plant has with the environment occurs at the intake and discharge structures. The review team concluded that the discharge from a once-through cooling system would produce a large thermal plume that would not meet the applicable temperature-related Tennessee water-quality criteria or the best available technology requirement of the Clean Water Act.

The review team considered various alternatives to the proposed heat-dissipation system, intake system, discharge system, and water supply. The review team did not identify any alternative system designs that were environmentally preferable to the proposed plant system designs.

What Are the Unavoidable Environmental Impacts?

The National Environmental Policy Act requires that an EIS include information about any negative environmental effects that cannot be avoided if the nuclear plant is built and operated.

These impacts are usually the building activities involved with clearing the land, excavating, filling wetlands, installing roads, and dredging. Exhibit P lists the unavoidable environmental impacts from building and operating small modular reactors at the Clinch River Nuclear Site.

The impacts discussed are based on information presented in Tables 10-1 and 10-2 of the EIS.

EXHIBIT P. UNAVOIDABLE IMPACTS Adverse Environmental Resource Unavoidable Adverse Impact Impacts Land Use 327 acres of a total of 494 acres would be MODERATE permanently converted from naturally vegetated land to industrial use. Thirty acres of a total of 203 acres in the barge/traffic area would be permanently affected by roadway improvements including conversion of naturally vegetated land to transportation use.

Water Use Water use for building would increase the demand on SMALL the City of Oak Ridge water supply system, which obtains water from Melton Hill Reservoir. Temporary excavation dewatering is not expected to impact groundwater use.

The maximum surface-water consumptive use would be less than 1 percent of the average flow rate in the Clinch River arm of the Watts Bar Reservoir adjacent to the Clinch River Nuclear Site. Groundwater would not be used during operations.

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EXHIBIT P. UNAVOIDABLE IMPACTS (CONTD)

Adverse Environmental Resource Unavoidable Adverse Impact Impacts Water Quality Local and temporary increase in sediments in water SMALL from increased erosion and construction stormwater runoff; construction in the Clinch River arm of the Watts Bar Reservoir; and discharge of excavation dewatering product and spills. Underwater excavation would result in minor localized changes in flow patterns along the reservoir bottom due to differences in bottom contours at the edges of the excavation zone, as well as temporary suspension of sediments during excavation.

Use of heavy equipment would introduce the possibility of petroleum and other chemical spills that could enter surface water.

Normal facility operations result in the discharge of small amounts of chemicals and radioactive effluents to the Clinch River arm of the Watts Bar Reservoir.

Routine/maintenance activities at the Clinch River Nuclear Site and along the transmission line right-of-ways may result in small episodic spills of petroleum or chemicals. Discharge of cooling water would result in a thermal plume to the Clinch River arm of the Watts Bar Reservoir. Thermal impacts would be within limits established in the National Pollutant Discharge Elimination System permit.

Terrestrial and Wetland Permanent loss of approximately 357 acres of habitat MODERATE Resources on the Clinch River Nuclear Site and in the barge/traffic area. Temporary loss of 182 acres on the Clinch River Nuclear Site and in the barge/traffic area. Total habitat disturbance on the Clinch River Nuclear Site and in the barge/traffic area of 539 acres.

A total of approximately 210 acres of right-of-way lands would be disturbed to install the offsite portion of the 69-kV underground transmission line.

Filling of approximately 1.8 acres of wetland on the Clinch River Nuclear Site and in the barge/traffic area.

Mitigation could reduce impacts.

Clearing of trees and other vegetation and grading could cause mortality or displacement of wildlife, including Federally listed bat species.

Construction noise may cause some wildlife to avoid some habitats near the source. This impact may occur intermittently throughout the construction phase.

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EXHIBIT P. UNAVOIDABLE IMPACTS (CONTD)

Adverse Environmental Resource Unavoidable Adverse Impact Impacts Terrestrial and Wetland Birds may occasionally collide with tall construction Resources (contd) equipment and suffer mortality.

Minor potential cooling-tower salt deposition impacts would occur on early successional vegetation near the towers.

Minor potential noise impacts would occur on wildlife near the towers.

There would be a minor risk of avian and bat collisions with mechanical draft cooling towers.

There would be a minor risk of avian collisions with or electrocutions by new transmission lines.

There would be a minor risk to wildlife from vegetation maintenance in new transmission line corridors.

There would be a minor risk of wildlife mortality due to increased traffic.

Aquatic Resources Removal of a perennial stream, an intermittent stream, SMALL 2 ponds, and 12 ephemeral streams.

Minimal or no unavoidable adverse impacts on the Clinch River arm of the Watts Bar Reservoir from installing the intake at the reservoirs edge and the discharge to the reservoir bottom. These actions may cause the loss of some benthic aquatic organisms and temporary degradation of habitat, as well as permanent loss of limited areas of habitat at the intake and discharge structures.

Installation of underground transmission line would involve crossing streams and may cause temporary disturbance of aquatic habitats in short stream segments within the right-of-way.

Routine facility operations result in discharge of small amounts of chemical and thermal effluents to the Clinch River arm of the Watts Bar Reservoir that could affect aquatic life over the operational life of the Clinch River Nuclear plant. Few or no unavoidable adverse impacts.

Entrainment or impingement at the water intake results in mortality and injury to various life stages of fish and other aquatic organisms. A relatively small proportion of eggs, larvae, or adults of relatively common species of aquatic species would be impacted by entrainment or impingement.

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EXHIBIT P. UNAVOIDABLE IMPACTS (CONTD)

Adverse Environmental Resource Unavoidable Adverse Impact Impacts Socioeconomic Physical Increased levels of temporary and localized noise, SMALL to exhaust emissions, and fugitive dust associated with MODERATE construction activities.

Localized visual intrusion of building activities.

The addition of new cooling towers and new reactor facilities at the Clinch River Nuclear Site, and related operations causing cooling-tower steam plumes.

Demography None SMALL Tax and SMALL None Economic (beneficial)

Impacts Infrastructure and Community Substantially increased traffic on local roadways during SMALL Services the period of peak construction employment (Months (for all 4247). categories except traffic)

Increased demand for housing, infrastructure, public to services, and education resources on a short-term MODERATE basis from the influx of construction workers and to LARGE families. Cooling-tower plumes would noticeably affect (for traffic) the aesthetic qualities from viewpoints in Anderson and Roane Counties. Recreational impacts would be adverse and not amenable to mitigation.

Environmental Justice None None Historic and Cultural Preconstruction activities could result in unavoidable SMALL to Resources adverse impacts on 16 potentially National Register of LARGE Historic Places (NHRP)-eligible archaeological resources, one NRHP-eligible archaeological resource (40RE233), deeply buried archaeological deposits, and one NRHP-eligible Melton Hill Dam District.

Unavoidable adverse impacts are possible during the life of the operating license if inadvertent discoveries result in adverse effects on places containing human remains or on historic properties.

Air Quality Temporary emissions from construction equipment SMALL firing fossil fuels, fugitive dust from soils disturbance and moving of soils, and workforce motor vehicles.

Diesel generators and other fossil fuel combustion equipment (during emergency and maintenance operations, and the auxiliary building) would contribute to air emissions. Cooling towers would emit plumes.

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EXHIBIT P. UNAVOIDABLE IMPACTS (CONTD)

Adverse Environmental Resource Unavoidable Adverse Impact Impacts Nonradiological Health Dust emissions, noise, occupational injuries, traffic SMALL to accidents. Impacts from construction activities to MODERATE worker health. Health risks to workers are expected to (for noise) be dominated by occupational injuries and would be minor. Health impacts on the public from noise generated by plant operations would be noticeable.

Radiological Health Radiation exposures to construction workers that would SMALL be within regulatory limits and as low as is reasonably achievable (ALARA). Small radiation doses to members of the public below NRC and U.S.

Environmental Protection Agency standards. ALARA doses to employees; adherence of the mitigation measures to applicable regulatory standards would reduce this exposure to ALARA. Non-human biota doses less than National Council on Radiation Protection and Measurements and International Atomic Energy Agency guidelines.

The mitigation measures would reduce the risk of radiological impacts. However, there would be unavoidable long-term commitments of land for an independent spent fuel storage installation and geological repository.

Long-term commitments of land for radwaste disposal.

Nonradioactive Waste Minor decrease in the available capacity of waste- SMALL treatment and disposal facilities. Minor stormwater, wastewater, and atmospheric discharges. Increased consumption of landfill space for disposition of wastes; increased consumption of fuels for the transportation and disposition of wastes.

Fuel Cycle, Transportation, Small impacts from fuel cycle as presented in SMALL and Decommissioning Table S-3, 10 CFR Part 51.

Small impacts from radon and technetium-99 releases.

Small radiological doses that are within the NRC and Department of Transportation regulations from transportation of fuel and radioactive waste.

Small impacts from decommissioning as presented in NUREG-0586.

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What Are the Irreversible and Irretrievable Commitments of Resources?

The term irreversible commitments of resources refers to environmental resources that would be permanently changed and could not be restored at some later time by the building or operation activities authorized by the NRC and U.S. Army Corps of Engineers permitting and licensing decisions. Exhibit Q lists the irreversible environmental resources from building and operating small modular reactors at the Clinch River Nuclear Site. The term irretrievable commitments of resources refers to environmental resources that would be used or consumed by the new units in such a way that they could not be recycled or restored for other uses. The review team expects that the use of building materials in the quantities needed for the Clinch River Nuclear Site would be irretrievable, but would be of small significance with respect to the availability of such resources.

EXHIBIT Q. IRREVERSIBLE COMMITMENTS Environmental Resource Irreversible Commitment Land Use Land committed to the disposal of radioactive and nonradioactive wastes is committed to that use and cannot be used for other purposes.

Water Use and Quality No irreversible commitments of water resources during preconstruction and construction. Approximately 12,808 gallons per minute would be irreversibly lost during operation from the Clinch River and would not be available to downstream users.

Terrestrial and Aquatic Biota Preconstruction and construction activities would permanently convert some portions of terrestrial and aquatic habitats on the Clinch River Nuclear Site and in the barge/traffic area, which overall would permanently adversely affect the abundance and distribution of local terrestrial species.

Socioeconomics No irreversible socioeconomic commitments.

Historic and Cultural Resources Preconstruction and construction activities would permanently damage an unknown number of historic and cultural resources located at the Clinch River Nuclear Site.

Air Quality The review team expects no irreversible impacts on air quality because all releases would be made in accordance with duly issued permits.

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When Will the U.S. Nuclear Regulatory Commission Decide?

After considering the environmental impacts of the proposed action, the review teams preliminary recommendation to the Commission is that the ESP be issued as proposed. This preliminary recommendation was determined using the criteria in Exhibit R.

The Commission will make a decision about whether to issue the ESP following the issuance of the staffs final EIS and final safety evaluation report and the conclusion of the hearing process.

TVA's application, including its Environmental Report Consultation with The assessments Federal, State, Tribal, summarized in the and local agencies final environmental impact statement RECOMMENDATION The consideration of The review teams public scoping and independent review draft environmental impact statement comments EXHIBIT R. BASIS OF THE REVIEW TEAMS RECOMMENDATION 41

What Is in the EIS?

CHAPTER 1 - INTRODUCTION This introductory chapter defines the proposed action and the purpose of and need for the proposed action and provides a brief outline of the NRC and U.S. Army Corps of Engineers environmental review processes.

CHAPTER 2 - AFFECTED ENVIRONMENT This chapter describes the location of the Clinch River Nuclear Site and the existing conditions at the site and surrounding area and provides the baseline for the analysis.

CHAPTER 3 - SITE LAYOUT AND PLANT DESIGN This chapter describes the proposed site layout and the key plant characteristics used for the impact analysis of the proposed actions.

CHAPTER 4 - ENVIRONMENTAL IMPACTS OF CONSTRUCTION This chapter describes the potential impacts from building the Clinch River Nuclear Site and the safeguards and controls that would limit the adverse impacts of building the new units.

CHAPTER 5 - ENVIRONMENTAL IMPACTS OF OPERATION This chapter examines the potential impacts from operating Clinch River Nuclear Site and the safeguards and controls that would limit the adverse impacts during operation over the 40-year license period.

CHAPTER 6 - FUEL CYCLE, TRANSPORTATION, AND DECOMMISSIONING This chapter addresses the environmental impacts from (1) the uranium fuel cycle and solid waste management, (2) the transportation of radioactive material, and (3) the decommissioning of Clinch River Nuclear Site.

CHAPTER 7 - CUMULATIVE IMPACTS This chapter describes the cumulative impacts that may result when the effects of building and operating the Clinch River Nuclear Site are added to, or interact with, other past, present, and reasonably foreseeable future actions on the same resources.

CHAPTER 8 - NEED FOR POWER The EIS for an ESP does not address the need for power if the application did not address the need for power. TVAs ESP application did not address the need for power.

CHAPTER 9 - ALTERNATIVES This chapter contains the evaluation of energy alternatives, site location alternatives, and nuclear plant design alternatives.

CHAPTER 10 - CONCLUSIONS AND RECOMMENDATIONS This final chapter provides the staffs preliminary recommendation about whether the ESP should be issued to TVA.

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What Are the Next Steps?

The draft EIS has been issued for a 75-day public review and comment period. All comments received on the draft statement will be considered and addressed in a final version of the EIS, which will be issued in mid-2019. A mandatory hearing will be held after both the final EIS and the final safety evaluation report are issued. The schedule for the completion of both documents can be found on the NRC public website. For additional information, please visit the NRCs Clinch River Nuclear Site website or contact Environmental Project Managers Patricia Vokoun at patricia.vokoun@nrc.gov or Tamsen Dozier at tamsen.dozier@nrc.gov.

(Courtesy of NRC Flickr) 43

April 2018