Text

NUREG-2226, Dfc, Vol. 2, Environmental Impact Statement for an Early Site Permit (ESP) at the Clinch River Nuclear Site, Draft Report for Comment, Appendices A-M
	ML18100A223
Person / Time
Site:	Clinch River
Issue date:	04/30/2018
From:	Tami Dozier; Office of New Reactors, US Dept of the Army, Corps of Engineers, Nashville District
To:	;
	Meyd, Donald
References
	NUREG-2226, DFC, Vol. 2
	Download: ML18100A223 (385)
	v • d • e

NUREG-2226, Vol. 2 Environmental Impact Statement for an Early Site Permit (ESP) at the Clinch River Nuclear Site Draft Report for Comment Appendices A-M U.S. Nuclear Regulatory Commission Office of New Reactors Washington, DC 20555-0001 U.S. Army Corps of Engineers Nashville District Nashville, Tennessee 37203

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NUREG-2226, Vol. 2 Environmental Impact Statement for an Early Site Permit (ESP) at the Clinch River Nuclear Site Draft Report for Comment Appendices A-M Manuscript Completed: April 2018 Date Published: April 2018 Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Nashville District U.S. Army Corps of Engineers Nashville, Tennessee 37203

1 COMMENTS ON DRAFT REPORT 2 Any interested party may submit comments on this report for consideration by the NRC staff.

3 Comments may be accompanied by additional relevant information or supporting data. Please 4 specify the report number NUREG-2226 in your comments, and send them by the end of the 5 comment period specified in the Federal Register notice announcing the availability of this 6 report.

7 Addresses: You may submit comments by any one of the following methods. Please include 8 Docket ID NRC-2016-0119 in the subject line of your comments. Comments submitted in writing 9 or in electronic form will be posted on the NRC website and on the Federal rulemaking website 10 http://www.regulations.gov.

11 NRC Project E-mail Address: Electronic comments may be sent by email to the NRC at 12 ClinchRiverESPEIS@nrc.gov.

13 Federal Rulemaking Website: Go to http://www.regulations.gov and search for documents filed 14 under Docket ID NRC-2016-0119. Address questions about NRC dockets to Jennifer Borges at 15 301-287-9127 or by e-mail at Jennifer.Borges@nrc.gov.

16 Mail comments to: May Ma, Division of Administrative Services, Office of Administration, Mail 17 Stop:TWFN-07-A60, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

18 For any questions about the material in this report, please contact: Tamsen Dozier, 19 Environmental Project Manager, 301-415-2272 or by email at Tamsen.Dozier@nrc.gov or 20 contact Patricia Vokoun, Environmental Project Manager, 301-415-3470 or by email at 21 Patricia.Vokoun@nrc.gov.

22 Please be aware that any comments that you submit to the NRC will be considered a public 23 record and entered into the Agencywide Documents Access and Management System 24 (ADAMS). Do not provide information you would not want to be publicly available.

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1 ABSTRACT 2 This draft environmental impact statement (EIS) has been prepared in response to an 3 application submitted to the U.S. Nuclear Regulatory Commission (NRC) by the Tennessee 4 Valley Authority (TVA) for an early site permit (ESP) for a site in Oak Ridge, Roane County, 5 Tennessee, for new nuclear power units demonstrating small modular reactor (SMR) 6 technology. The proposed action related to the TVA application is the issuance of an ESP for 7 the Clinch River Nuclear (CRN) Site approving the site as suitable for the future demonstration 8 of the construction and operation of two or more SMRs with characteristics presented in the 9 application. The Nashville District, Regulatory Division, U.S. Army Corps of Engineers (USACE) 10 is a cooperating agency with the NRC to verify that the information presented in this draft EIS is 11 adequate to support a Department of the Army permit application, should TVA submit a 12 Department of the Army permit application at a future date. The USACE is cooperating in the 13 preparation of this draft EIS to streamline regulatory review processes, avoid unnecessary 14 duplication of effort, and ensure issues and concerns related to impacts on waters of the United 15 States and navigable waters of the United States are identified and addressed early in the 16 NRCs review process. The NRC, its contractors, and USACE make up the review team.

17 This draft EIS documents the review teams preliminary analysis, which considers and weighs 18 the environmental impacts of building and operating two or more SMRs at the CRN Site and at 19 alternative sites, including measures potentially available for reducing or avoiding adverse 20 impacts. This draft EIS also addresses Federally listed species, cultural resources, and plant 21 cooling system design alternatives.

22 This draft EIS includes the evaluation of the proposed actions impacts on waters of the United 23 States pursuant to Section 404 of the Clean Water Act and Section 10 of the Rivers and 24 Harbors Appropriation Act of 1899. Upon receipt of an application, the USACE will conduct a 25 public interest review in accordance with the guidelines promulgated by the U.S. Environmental 26 Protection Agency under the authority of Section 404(b) of the Clean Water Act. The public 27 interest review, which will be addressed in the USACE permit decision document, will include an 28 alternatives analysis to determine the least environmentally damaging practicable alternative.

29 After considering the environmental aspects of the proposed action before the NRC, the NRC 30 staffs preliminary recommendation to the Commission is that the ESP be issued as proposed.

31 This recommendation is based on (1) the application, including the Environmental Report (ER),

32 and supplemental information submitted by TVA; (2) consultation with Federal, State, Tribal, 33 and local agencies; (3) the review teams independent review; (4) the consideration of public 34 scoping comments received as part of the environmental review process; and (5) the 35 assessments summarized in this draft EIS, including the potential mitigation measures identified 36 in the ER and this draft EIS.

37 38 39 40 41 42 43 44 45 46 NUREG-2226 has been reproduced from the best available copy.

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1 TABLE OF CONTENTS 2 ABSTRACT ................................................................................................................................. iii 3 TABLE OF CONTENTS ............................................................................................................... v 4 LIST OF FIGURES .................................................................................................................... xix 5 LIST OF TABLES .................................................................................................................... xxiii 6 EXECUTIVE

SUMMARY

......................................................................................................... xxix 7 ABBREVIATIONS AND ACRONYMS .................................................................................. xxxix 8

1.0 INTRODUCTION

.............................................................................................................. 1-1 9 1.1 Background .............................................................................................................. 1-1 10 1.1.1 Plant Parameter Envelope............................................................................ 1-2 11 1.1.2 NRC ESP Application Review ...................................................................... 1-3 12 1.1.2.1 Overview of the CRN ESP Application Environmental Review...... 1-5 13 1.1.3 USACE Review of the TVA ESP Application ................................................ 1-6 14 1.1.4 Preconstruction Activities ............................................................................. 1-6 15 1.1.5 Cooperating Agencies .................................................................................. 1-7 16 1.1.6 Concurrent NRC Reviews ............................................................................ 1-8 17 1.2 The Proposed Federal Action................................................................................... 1-9 18 1.3 The Purpose and Need for the Proposed Action...................................................... 1-9 19 1.4 TVAs Proposed Project ......................................................................................... 1-10 20 1.5 The Future USACE Permit Action .......................................................................... 1-11 21 1.6 Alternatives to the Proposed Actions ..................................................................... 1-12 22 1.7 Compliance and Consultations............................................................................... 1-12 23 1.8 Report Contents ..................................................................................................... 1-13 24 2.0 AFFECTED ENVIRONMENT ........................................................................................... 2-1 25 2.1 Site Location............................................................................................................. 2-1 26 2.2 Land Use .................................................................................................................. 2-5 27 2.2.1 Site and Vicinity ............................................................................................ 2-5 28 2.2.1.1 Barge/Traffic Area ........................................................................ 2-10 29 2.2.2 Transmission Lines and Other Offsite Areas .............................................. 2-11 30 2.2.2.1 Existing Transmission Lines ........................................................ 2-12 31 2.2.2.2 Rail Offloading Area and Rail Spur .............................................. 2-12 32 2.2.2.3 Offsite Borrow Pits ....................................................................... 2-12 33 2.2.3 The Region ................................................................................................. 2-15 34 2.3 Water ...................................................................................................................... 2-18 35 2.3.1 Hydrology ................................................................................................... 2-18 36 2.3.1.1 Surface-Water Hydrology ............................................................ 2-19 37 2.3.1.2 Groundwater Hydrology ............................................................... 2-28 38 2.3.2 Water Use................................................................................................... 2-38 v

TABLE OF CONTENTS (CONTINUED) 1 2.3.2.1 Surface-Water Use ...................................................................... 2-38 2 2.3.2.2 Groundwater Use ......................................................................... 2-39 3 2.3.3 Water Quality .............................................................................................. 2-41 4 2.3.3.1 Surface-Water Quality ................................................................. 2-41 5 2.3.3.2 Groundwater Quality .................................................................... 2-46 6 2.3.4 Water Monitoring ........................................................................................ 2-48 7 2.3.4.1 Surface-Water Monitoring ............................................................ 2-48 8 2.3.4.2 Groundwater Monitoring .............................................................. 2-49 9 2.4 Ecology................................................................................................................... 2-49 10 2.4.1 Terrestrial and Wetland Ecology ................................................................ 2-49 11 2.4.1.1 Terrestrial Resources - Site and Vicinity ..................................... 2-49 12 2.4.1.2 Upland Plant Communities and Habitat Types ............................ 2-51 13 2.4.1.3 CRN Site ...................................................................................... 2-52 14 2.4.1.4 BTA .............................................................................................. 2-54 15 2.4.1.5 Underground 69-kV Transmission Line Route ............................. 2-55 16 2.4.1.6 Wetlands ...................................................................................... 2-55 17 2.4.1.7 Wetlands Along Underground 69-kV Transmission Line Route... 2-57 18 2.4.1.8 Floodplains .................................................................................. 2-58 19 2.4.1.9 Wildlife ......................................................................................... 2-58 20 2.4.1.10 Terrestrial Resources - Offsite Areas .......................................... 2-62 21 2.4.1.11 Important Species and Habitats ................................................... 2-64 22 2.4.2 Aquatic Ecology .......................................................................................... 2-92 23 2.4.2.1 Site and Vicinity ........................................................................... 2-92 24 2.4.2.2 Offsite Areas .............................................................................. 2-100 25 2.4.2.3 Important Species and Habitats ................................................. 2-100 26 2.4.2.4 Protected Species ...................................................................... 2-102 27 2.5 Socioeconomics ................................................................................................... 2-108 28 2.5.1 Demographics .......................................................................................... 2-109 29 2.5.1.1 Resident Population ................................................................... 2-110 30 2.5.1.2 Transient Population .................................................................. 2-114 31 2.5.1.3 Migrant Labor ............................................................................. 2-115 32 2.5.2 Community Characteristics ....................................................................... 2-115 33 2.5.2.1 Economy .................................................................................... 2-115 34 2.5.2.2 Economic Region ....................................................................... 2-116 35 2.5.2.3 Taxes ......................................................................................... 2-119 36 2.5.2.4 Transportation ............................................................................ 2-122 37 2.5.2.5 Aesthetics and Recreation ......................................................... 2-124 38 2.5.2.6 Housing ...................................................................................... 2-125 39 2.5.2.7 Public Services .......................................................................... 2-126 40 2.6 Environmental Justice .......................................................................................... 2-131 41 2.6.1 Methodology ............................................................................................. 2-131 42 2.6.2 Scoping and Outreach .............................................................................. 2-137 43 2.6.3 Special Circumstances of the Minority and Low-Income Populations ...... 2-137 44 2.6.3.1 High-Density Communities ........................................................ 2-137 45 2.6.3.2 Subsistence ............................................................................... 2-137 46 2.6.4 Migrant Populations .................................................................................. 2-138 vi

TABLE OF CONTENTS (CONTINUED) 1 2.6.5 Environmental Justice Summary .............................................................. 2-138 2 2.7 Historic and Cultural Resources ........................................................................... 2-138 3 2.7.1 Cultural Background ................................................................................. 2-142 4 2.7.2 Historic and Cultural Resources at the CRN Site and Offsite Areas ........ 2-143 5 2.7.2.1 Historic and Cultural Resources Located within the Onsite 6 Direct- and Indirect-Effects APE ................................................ 2-143 7 2.7.2.2 Historic and Cultural Resources Located within the Offsite 8 Direct- and Indirect-Effects APE ................................................ 2-155 9 2.7.3 Federal Requirements .............................................................................. 2-156 10 2.7.4 Consultation.............................................................................................. 2-156 11 2.8 Geology ................................................................................................................ 2-158 12 2.9 Meteorology and Air Quality ................................................................................. 2-163 13 2.9.1 Climate ..................................................................................................... 2-164 14 2.9.1.1 Wind ........................................................................................... 2-164 15 2.9.1.2 Temperature .............................................................................. 2-164 16 2.9.1.3 Atmospheric Water Vapor .......................................................... 2-164 17 2.9.1.4 Precipitation ............................................................................... 2-165 18 2.9.1.5 Severe Weather ......................................................................... 2-165 19 2.9.1.6 Atmospheric Stability ................................................................. 2-167 20 2.9.2 Air Quality ................................................................................................. 2-167 21 2.9.3 Atmospheric Dispersion............................................................................ 2-168 22 2.9.3.1 Projected Air Quality .................................................................. 2-168 23 2.9.3.2 Restrictive Dispersion Conditions .............................................. 2-168 24 2.9.3.3 Short- and Long-Term Dispersion Estimates from Power Plant 25 Operation ................................................................................... 2-169 26 2.9.4 Meteorological Monitoring ........................................................................ 2-170 27 2.9.4.1 Instrumentation .......................................................................... 2-172 28 2.9.4.2 Data Recording .......................................................................... 2-173 29 2.9.4.3 Instrument Maintenance ............................................................ 2-173 30 2.9.4.4 Operational Monitoring .............................................................. 2-174 31 2.10 Nonradiological Environment ............................................................................... 2-174 32 2.10.1 Public and Occupational Health ............................................................... 2-174 33 2.10.1.1 Air Quality .................................................................................. 2-174 34 2.10.1.2 Occupational Injuries ................................................................. 2-175 35 2.10.1.3 Etiological Agents ...................................................................... 2-175 36 2.10.2 Noise ........................................................................................................ 2-176 37 2.10.3 Transportation .......................................................................................... 2-179 38 2.10.4 Electromagnetic Fields ............................................................................. 2-181 39 2.11 Radiological Environment..................................................................................... 2-181 40 2.12 Related Federal Projects and Consultation .......................................................... 2-182 41 3.0 SITE LAYOUT AND PROJECT DESCRIPTION ............................................................. 3-1 42 3.1 External Appearance and Site Layout ...................................................................... 3-1 43 3.2 Proposed Plant Structures and Plant Parameter Envelope ..................................... 3-2 44 3.2.1 Reactor Power-Conversion System ............................................................. 3-2 45 3.2.2 Structures with a Major Environmental Interface .......................................... 3-2 vii

TABLE OF CONTENTS (CONTINUED) 1 3.2.2.1 Landscape and Stormwater Drainage ........................................... 3-4 2 3.2.2.2 Cooling System .............................................................................. 3-5 3 3.2.2.3 Other Structures with a Permanent Environmental Interface......... 3-8 4 3.2.2.4 Other Structures with a Temporary Environmental Interface ....... 3-11 5 3.2.3 Structures with a Minor Environmental Interface ........................................ 3-11 6 3.2.3.1 Power Block and Other Buildings in the Main Plant Area ............ 3-11 7 3.2.3.2 Cranes and Footings ................................................................... 3-12 8 3.2.3.3 Pipelines ...................................................................................... 3-12 9 3.2.3.4 Support and Laydown Areas ....................................................... 3-12 10 3.2.3.5 Parking ......................................................................................... 3-12 11 3.2.3.6 Fill Source (Borrow) Areas ........................................................... 3-12 12 3.3 Construction and Preconstruction Activities ........................................................... 3-12 13 3.3.1 Major Activity Areas .................................................................................... 3-14 14 3.3.1.1 Landscape and Stormwater Drainage ......................................... 3-14 15 3.3.1.2 Main Plant Area ........................................................................... 3-14 16 3.3.1.3 Cooling-Water Intake Structure ................................................... 3-15 17 3.3.1.4 Cooling-Water Discharge System ................................................ 3-15 18 3.3.1.5 Roads .......................................................................................... 3-15 19 3.3.1.6 Barge-Unloading Facility .............................................................. 3-15 20 3.3.1.7 Rail Lines ..................................................................................... 3-15 21 3.3.1.8 Pipelines ...................................................................................... 3-15 22 3.3.1.9 Concrete Batch Plant ................................................................... 3-16 23 3.3.1.10 Laydown and Parking Areas ........................................................ 3-16 24 3.3.1.11 Cranes and Crane Footings ......................................................... 3-16 25 3.3.1.12 Miscellaneous Buildings .............................................................. 3-16 26 3.3.1.13 Transmission Lines ...................................................................... 3-16 27 3.3.1.14 Melton Hill Dam Bypass ............................................................... 3-17 28 3.3.2 Summary of Resource Parameters during Construction and 29 Preconstruction........................................................................................... 3-17 30 3.4 Operational Activities.............................................................................................. 3-18 31 3.4.1 Description of Cooling System Operational Modes .................................... 3-18 32 3.4.2 Plant-Environment Interfaces during Operation ......................................... 3-18 33 3.4.2.1 Stormwater-Management System ............................................... 3-18 34 3.4.2.2 Circulating-Water System ............................................................ 3-19 35 3.4.2.3 Other Environmental Interfaces during Operation ....................... 3-19 36 3.4.3 Radioactive Waste-Management System .................................................. 3-21 37 3.4.4 Nonradioactive Waste-Management Systems ........................................... 3-22 38 3.4.4.1 Solid-Waste Management............................................................ 3-22 39 3.4.4.2 Liquid-Waste Management .......................................................... 3-22 40 3.4.4.3 Gaseous Waste Management ..................................................... 3-23 41 3.4.4.4 Hazardous- and Mixed-Waste Management ............................... 3-24 42 3.4.5 Summary of Resource Parameters during Operation ................................ 3-25 43 4.0 CONSTRUCTION IMPACTS AT THE PROPOSED SITE ............................................... 4-1 44 4.1 Land-Use Impacts .................................................................................................... 4-3 45 4.1.1 Site and Vicinity ............................................................................................ 4-3 viii

TABLE OF CONTENTS (CONTINUED) 1 4.1.2 Offsite Areas ................................................................................................. 4-9 2 4.1.3 Summary of Land-Use Impacts .................................................................... 4-9 3 4.2 Water-Related Impacts........................................................................................... 4-10 4 4.2.1 Hydrologic Alterations................................................................................. 4-11 5 4.2.1.1 Surface Water .............................................................................. 4-12 6 4.2.1.2 Groundwater ................................................................................ 4-14 7 4.2.2 Water-Use Impacts ..................................................................................... 4-15 8 4.2.2.1 Surface-Water Use ...................................................................... 4-15 9 4.2.2.2 Groundwater Use ......................................................................... 4-16 10 4.2.3 Water Quality .............................................................................................. 4-16 11 4.2.3.1 Surface-Water Quality ................................................................. 4-16 12 4.2.3.2 Groundwater Quality .................................................................... 4-17 13 4.2.4 Water Monitoring ........................................................................................ 4-18 14 4.2.4.1 Surface-Water Monitoring ............................................................ 4-18 15 4.2.4.2 Groundwater Monitoring .............................................................. 4-18 16 4.3 Ecology................................................................................................................... 4-18 17 4.3.1 Terrestrial and Wetland Impacts ................................................................. 4-18 18 4.3.1.1 Site and Vicinity ........................................................................... 4-18 19 4.3.1.2 Offsite Areas ................................................................................ 4-28 20 4.3.1.3 Important Species and Habitats ................................................... 4-30 21 4.3.1.4 Monitoring .................................................................................... 4-35 22 4.3.1.5 Mitigation ..................................................................................... 4-36 23 4.3.1.6 Summary ..................................................................................... 4-36 24 4.3.2 Aquatic Impacts .......................................................................................... 4-36 25 4.3.2.1 Site and Vicinity ........................................................................... 4-37 26 4.3.2.2 Offsite Areas ................................................................................ 4-39 27 4.3.2.3 Important Species and Habitats ................................................... 4-40 28 4.3.2.4 Aquatic Monitoring ....................................................................... 4-40 29 4.3.2.5 Mitigation ..................................................................................... 4-40 30 4.3.2.6 Summary ..................................................................................... 4-41 31 4.4 Socioeconomic Impacts ......................................................................................... 4-41 32 4.4.1 Physical Impacts......................................................................................... 4-42 33 4.4.1.1 Workers and the Local Public ...................................................... 4-42 34 4.4.1.2 Structures .................................................................................... 4-43 35 4.4.1.3 Transportation .............................................................................. 4-44 36 4.4.1.4 Aesthetics .................................................................................... 4-45 37 4.4.1.5 Summary of Physical Impacts...................................................... 4-45 38 4.4.2 Demography ............................................................................................... 4-46 39 4.4.3 Economic Impacts on the Community ........................................................ 4-49 40 4.4.3.1 Economy ...................................................................................... 4-49 41 4.4.3.2 Taxes ........................................................................................... 4-51 42 4.4.3.3 Summary of Economic Impacts on the Community ..................... 4-52 43 4.4.4 Infrastructure and Community Service Impacts .......................................... 4-52 44 4.4.4.1 Traffic ........................................................................................... 4-52 45 4.4.4.2 Recreation ................................................................................... 4-56 46 4.4.4.3 Housing ........................................................................................ 4-56 ix

TABLE OF CONTENTS (CONTINUED) 1 4.4.4.4 Public Services ............................................................................ 4-57 2 4.4.4.5 Education ..................................................................................... 4-60 3 4.4.4.6 Summary of Community Service and Infrastructure Impacts....... 4-60 4 4.4.5 Summary of Socioeconomic Impacts ......................................................... 4-61 5 4.5 Environmental Justice Impacts............................................................................... 4-62 6 4.5.1 Health Impacts............................................................................................ 4-62 7 4.5.2 Physical and Environmental Impacts .......................................................... 4-62 8 4.5.2.1 Soil ............................................................................................... 4-63 9 4.5.2.2 Water ........................................................................................... 4-63 10 4.5.2.3 Air ................................................................................................ 4-63 11 4.5.2.4 Noise ............................................................................................ 4-63 12 4.5.2.5 Summary of Physical and Environmental Impacts....................... 4-64 13 4.5.3 Socioeconomic Impacts.............................................................................. 4-64 14 4.5.4 Subsistence and Special Conditions .......................................................... 4-64 15 4.5.4.1 Subsistence ................................................................................. 4-64 16 4.5.4.2 High-Density Communities .......................................................... 4-64 17 4.5.5 Migrant Labor ............................................................................................. 4-65 18 4.5.6 Summary of Environmental Justice Impacts .............................................. 4-65 19 4.6 Historic and Cultural Resources ............................................................................. 4-65 20 4.6.1 Onsite Impacts on Historic and Cultural Resources ................................... 4-66 21 4.6.2 Offsite Impacts on Historic and Cultural Resources ................................... 4-67 22 4.6.3 Summary .................................................................................................... 4-68 23 4.7 Meteorological and Air-Quality Impacts .................................................................. 4-68 24 4.7.1 Construction and Preconstruction Activities ............................................... 4-69 25 4.7.2 Traffic (Emissions) ...................................................................................... 4-70 26 4.7.3 Summary .................................................................................................... 4-71 27 4.8 Nonradiological Health Impacts.............................................................................. 4-71 28 4.8.1 Public and Occupational Health ................................................................. 4-72 29 4.8.1.1 Public Health ................................................................................ 4-72 30 4.8.1.2 Construction Worker Health ......................................................... 4-72 31 4.8.2 Noise Impacts ............................................................................................. 4-73 32 4.8.3 Transportation Impacts ............................................................................... 4-75 33 4.8.4 Summary of Nonradiological Health Impacts ............................................. 4-76 34 4.9 Radiological Health Impacts ................................................................................... 4-77 35 4.9.1 Direct Radiation Exposures ........................................................................ 4-78 36 4.9.2 Radiation Exposures from Gaseous Effluents ............................................ 4-78 37 4.9.3 Radiation Exposures from Liquid Effluents ................................................. 4-79 38 4.9.4 Total Dose to Construction Workers ........................................................... 4-79 39 4.9.5 Summary of Radiological Health Impacts ................................................... 4-79 40 4.10 Nonradioactive Waste Impacts............................................................................... 4-80 41 4.10.1 Impacts on Land ......................................................................................... 4-80 42 4.10.2 Impacts on Water ....................................................................................... 4-80 43 4.10.3 Impacts on Air............................................................................................. 4-81 44 4.10.4 Summary of Impacts................................................................................... 4-81 45 4.11 Measures and Controls to Limit Adverse Impacts during Construction Activities .. 4-82 46 4.12 Summary of Construction and Preconstruction Impacts ........................................ 4-85 x

TABLE OF CONTENTS (CONTINUED) 1 5.0 OPERATIONAL IMPACTS AT THE PROPOSED SITE .................................................. 5-1 2 5.1 Land-Use Impacts .................................................................................................... 5-1 3 5.1.1 The Site and Vicinity ..................................................................................... 5-1 4 5.1.2 Offsite Areas ................................................................................................. 5-2 5 5.1.3 Summary of Land-Use Impacts .................................................................... 5-3 6 5.2 Water-Related Impacts............................................................................................. 5-3 7 5.2.1 Hydrologic Alterations................................................................................... 5-4 8 5.2.2 Water-Use Impacts ....................................................................................... 5-6 9 5.2.2.1 Surface-Water-Use Impacts........................................................... 5-6 10 5.2.2.2 Groundwater-Use Impacts ............................................................. 5-7 11 5.2.3 Water-Quality Impacts .................................................................................. 5-7 12 5.2.3.1 Surface-Water-Quality Impacts ...................................................... 5-8 13 5.2.3.2 Groundwater-Quality Impacts ...................................................... 5-11 14 5.2.4 Water Monitoring ........................................................................................ 5-12 15 5.2.4.1 Surface-Water Monitoring ............................................................ 5-12 16 5.2.4.2 Groundwater Monitoring .............................................................. 5-12 17 5.3 Ecology................................................................................................................... 5-13 18 5.3.1 Terrestrial and Wetland Impacts Related to Operation .............................. 5-13 19 5.3.1.1 Site and Vicinity ........................................................................... 5-13 20 5.3.1.2 Offsite Areas ................................................................................ 5-18 21 5.3.1.3 Important Terrestrial Species and Habitats.................................. 5-18 22 5.3.1.4 Monitoring .................................................................................... 5-20 23 5.3.1.5 Mitigation ..................................................................................... 5-20 24 5.3.1.6 Summary ..................................................................................... 5-20 25 5.3.2 Aquatic Impacts .......................................................................................... 5-21 26 5.3.2.1 Site and Vicinity ........................................................................... 5-21 27 5.3.2.2 Offsite Areas ................................................................................ 5-24 28 5.3.2.3 Important Aquatic Species and Habitats - Site and Vicinity 29 and Offsite Areas ......................................................................... 5-25 30 5.3.2.4 Summary and Conclusions .......................................................... 5-25 31 5.4 Socioeconomic Impacts ......................................................................................... 5-25 32 5.4.1 Physical Impacts......................................................................................... 5-26 33 5.4.1.1 Workers and the Local Public ...................................................... 5-26 34 5.4.1.2 Noise ............................................................................................ 5-27 35 5.4.1.3 Air Quality .................................................................................... 5-27 36 5.4.1.4 Structures .................................................................................... 5-27 37 5.4.1.5 Transportation .............................................................................. 5-27 38 5.4.1.6 Aesthetics .................................................................................... 5-28 39 5.4.1.7 Summary of Physical Impacts...................................................... 5-30 40 5.4.2 Demography ............................................................................................... 5-30 41 5.4.3 Economic Impacts on the Community ........................................................ 5-31 42 5.4.3.1 Economy ...................................................................................... 5-31 43 5.4.3.2 Taxes ........................................................................................... 5-32 44 5.4.3.3 Summary of Economic Impacts on the Community ..................... 5-33 45 5.4.4 Infrastructure and Community Service Impacts .......................................... 5-33 46 5.4.4.1 Traffic ........................................................................................... 5-33 xi

TABLE OF CONTENTS (CONTINUED) 1 5.4.4.2 Recreation ................................................................................... 5-34 2 5.4.4.3 Housing ........................................................................................ 5-35 3 5.4.4.4 Public Services ............................................................................ 5-35 4 5.4.4.5 Education ..................................................................................... 5-36 5 5.4.4.6 Summary of Community Service and Infrastructure Impacts....... 5-37 6 5.4.5 Summary of Socioeconomic Impacts ......................................................... 5-37 7 5.5 Environmental Justice ............................................................................................ 5-37 8 5.5.1 Health Impacts............................................................................................ 5-38 9 5.5.2 Physical and Environmental Impacts .......................................................... 5-38 10 5.5.2.1 Soil ............................................................................................... 5-39 11 5.5.2.2 Water ........................................................................................... 5-39 12 5.5.2.3 Air ................................................................................................ 5-39 13 5.5.2.4 Noise ............................................................................................ 5-39 14 5.5.2.5 Summary of Physical and Environmental Impacts....................... 5-40 15 5.5.3 Socioeconomic Impacts.............................................................................. 5-40 16 5.5.4 Subsistence and Special Conditions .......................................................... 5-40 17 5.5.4.1 Subsistence ................................................................................. 5-40 18 5.5.4.2 High-Density Communities .......................................................... 5-41 19 5.5.5 Migrant Labor ............................................................................................. 5-41 20 5.5.6 Summary of Environmental Justice Impacts .............................................. 5-41 21 5.6 Historic and Cultural Resources ............................................................................. 5-41 22 5.6.1 Onsite Impacts on Historic and Cultural Resources ................................... 5-42 23 5.6.2 Offsite Impacts on Historic and Cultural Resources ................................... 5-43 24 5.6.3 Summary .................................................................................................... 5-43 25 5.7 Meteorology and Air Quality Impacts ..................................................................... 5-43 26 5.7.1 Air-Quality Impacts ..................................................................................... 5-43 27 5.7.1.1 Criteria Pollutants......................................................................... 5-44 28 5.7.1.2 Greenhouse Gases ...................................................................... 5-45 29 5.7.2 Cooling-System Impacts ............................................................................. 5-46 30 5.7.2.1 Visible Plumes ............................................................................. 5-46 31 5.7.2.2 Ground Fogging and Icing ........................................................... 5-47 32 5.7.2.3 Plume Shadowing ........................................................................ 5-47 33 5.7.2.4 Salt Deposition ............................................................................. 5-47 34 5.7.2.5 Interaction with Other Pollutant Sources...................................... 5-48 35 5.7.3 Transmission Line Impacts ......................................................................... 5-48 36 5.7.4 Summary .................................................................................................... 5-49 37 5.8 Nonradiological Health Impacts.............................................................................. 5-49 38 5.8.1 Etiological (Disease-Causing) Agents ........................................................ 5-49 39 5.8.2 Noise Impacts ............................................................................................. 5-50 40 5.8.3 Acute Effects of Electromagnetic Fields ..................................................... 5-50 41 5.8.4 Chronic Effects of Electromagnetic Fields .................................................. 5-51 42 5.8.5 Occupational Health ................................................................................... 5-51 43 5.8.6 Transportation Impacts ............................................................................... 5-52 44 5.8.7 Summary of Nonradiological Health Impacts ............................................. 5-53 45 5.9 Radiological Impacts of Normal Operations ........................................................... 5-54 46 5.9.1 Exposure Pathways .................................................................................... 5-54 xii

TABLE OF CONTENTS (CONTINUED) 1 5.9.2 Radiation Doses to Members of the Public ................................................ 5-56 2 5.9.2.1 Liquid Effluent Pathway ............................................................... 5-56 3 5.9.2.2 Gaseous Effluent Pathway .......................................................... 5-58 4 5.9.3 Impacts on Members of the Public ............................................................. 5-59 5 5.9.3.1 Maximally Exposed Individual ...................................................... 5-59 6 5.9.3.2 Population Dose .......................................................................... 5-60 7 5.9.3.3 Summary of Radiological Impacts on Members of the Public...... 5-62 8 5.9.4 Occupational Doses to Workers ................................................................. 5-62 9 5.9.5 Impacts on Biota Other than Humans ........................................................ 5-62 10 5.9.5.1 Liquid Effluent Pathway ............................................................... 5-63 11 5.9.5.2 Gaseous Effluent Pathway .......................................................... 5-63 12 5.9.5.3 Impact of Estimated Nonhuman Biota Doses .............................. 5-63 13 5.9.6 Radiological Monitoring .............................................................................. 5-64 14 5.10 Nonradioactive Waste Impacts............................................................................... 5-65 15 5.10.1 Impacts on Land ......................................................................................... 5-65 16 5.10.2 Impacts on Water ....................................................................................... 5-66 17 5.10.3 Impacts on Air............................................................................................. 5-66 18 5.10.4 Mixed-Waste Impacts ................................................................................. 5-66 19 5.10.5 Summary of Nonradioactive Waste Impacts .............................................. 5-67 20 5.11 Environmental Impacts of Postulated Accidents .................................................... 5-68 21 5.11.1 Design Basis Accidents .............................................................................. 5-71 22 5.11.2 Severe Accidents ........................................................................................ 5-74 23 5.11.2.1 Air Pathway .................................................................................. 5-76 24 5.11.2.2 Surface-Water Pathways ............................................................. 5-83 25 5.11.2.3 Groundwater Pathway ................................................................. 5-84 26 5.11.2.4 Externally Initiated Events ........................................................... 5-84 27 5.11.2.5 Spent Fuel Pool Accidents ........................................................... 5-85 28 5.11.2.6 Summary of Severe Accident Impacts ......................................... 5-87 29 5.11.3 Severe Accident Mitigation Alternatives ..................................................... 5-87 30 5.11.4 Summary of Postulated Accident Impacts .................................................. 5-88 31 5.12 Measures and Controls to Limit Adverse Impacts during Operation ...................... 5-88 32 5.13 Summary of Operational Impacts ........................................................................... 5-93 33 6.0 FUEL CYCLE, TRANSPORTATION, AND DECOMMISSIONING .................................. 6-1 34 6.1 Fuel-Cycle Impacts and Solid-Waste Management ................................................. 6-1 35 6.1.1 Land Use ...................................................................................................... 6-8 36 6.1.2 Water Use..................................................................................................... 6-8 37 6.1.3 Fossil Fuel Impacts....................................................................................... 6-9 38 6.1.4 Chemical Effluents ...................................................................................... 6-10 39 6.1.5 Radiological Effluents ................................................................................. 6-10 40 6.1.6 Radiological Wastes ................................................................................... 6-12 41 6.1.7 Occupational Dose ..................................................................................... 6-16 42 6.1.8 Transportation ............................................................................................ 6-16 43 6.1.9 Summary .................................................................................................... 6-16 44 6.2 Transportation Impacts........................................................................................... 6-17 45 6.2.1 Transportation of Unirradiated Fuel ............................................................ 6-19 xiii

TABLE OF CONTENTS (CONTINUED) 1 6.2.1.1 Normal Conditions ....................................................................... 6-19 2 6.2.1.2 Radiological Impacts of Transportation Accidents ....................... 6-24 3 6.2.1.3 Nonradiological Impacts of Transportation Accidents .................. 6-25 4 6.2.2 Transportation of Spent Fuel ...................................................................... 6-26 5 6.2.2.1 Normal Conditions ....................................................................... 6-27 6 6.2.2.2 Radiological Impacts of Accidents ............................................... 6-32 7 6.2.2.3 Nonradiological Impact of Spent Fuel Shipments ........................ 6-35 8 6.2.3 Transportation of Radioactive Waste ......................................................... 6-35 9 6.2.4 Conclusions for Transportation................................................................... 6-37 10 6.3 Decommissioning Impacts ..................................................................................... 6-38 11 7.0 CUMULATIVE IMPACTS ................................................................................................. 7-1 12 7.1 Land Use ................................................................................................................ 7-10 13 7.2 Water Use and Quality ........................................................................................... 7-13 14 7.2.1 Water-Use Impacts ..................................................................................... 7-13 15 7.2.1.1 Surface-Water-Use Impacts......................................................... 7-13 16 7.2.1.2 Groundwater-Use Impacts ........................................................... 7-15 17 7.2.2 Water-Quality Impacts ................................................................................ 7-16 18 7.2.2.1 Surface-Water-Quality Impacts .................................................... 7-16 19 7.2.2.2 Groundwater-Quality Impacts ...................................................... 7-18 20 7.3 Ecology................................................................................................................... 7-19 21 7.3.1 Terrestrial and Wetland Resources ............................................................ 7-19 22 7.3.1.1 Terrestrial Habitats....................................................................... 7-20 23 7.3.1.2 Wetlands ...................................................................................... 7-21 24 7.3.1.3 Wildlife ......................................................................................... 7-22 25 7.3.1.4 Important Species and Habitats ................................................... 7-23 26 7.3.1.5 Summary ..................................................................................... 7-24 27 7.3.2 Aquatic Ecosystem ..................................................................................... 7-25 28 7.3.2.1 CRN Site and Vicinity .................................................................. 7-25 29 7.3.2.2 69-kV Underground Transmission Line ....................................... 7-28 30 7.3.2.3 Offsite Transmission Lines .......................................................... 7-28 31 7.3.2.4 Conclusion ................................................................................... 7-29 32 7.4 Socioeconomics and Environmental Justice .......................................................... 7-29 33 7.4.1 Socioeconomics ......................................................................................... 7-29 34 7.4.2 Environmental Justice ................................................................................ 7-31 35 7.5 Historic and Cultural Resources ............................................................................. 7-32 36 7.6 Air Quality ............................................................................................................... 7-34 37 7.6.1 Criteria Pollutants ....................................................................................... 7-34 38 7.6.2 Greenhouse Gas Emissions ....................................................................... 7-35 39 7.6.3 Summary .................................................................................................... 7-37 40 7.7 Nonradiological Health ........................................................................................... 7-37 41 7.8 Radiological Impacts of Normal Operation ............................................................. 7-38 42 7.9 Nonradiological Waste Systems............................................................................. 7-40 43 7.10 Postulated Accidents .............................................................................................. 7-41 44 7.11 Fuel Cycle, Transportation, and Decommissioning ................................................ 7-42 45 7.11.1 Fuel Cycle................................................................................................... 7-42 xiv

TABLE OF CONTENTS (CONTINUED) 1 7.11.2 Transportation of Radioactive Material ....................................................... 7-43 2 7.11.3 Decommissioning ....................................................................................... 7-44 3 7.11.4 Summary of Cumulative Fuel Cycle, Transportation, and 4 Decommissioning Impacts .......................................................................... 7-44 5 7.12 Conclusions ............................................................................................................ 7-44 6 8.0 NEED FOR POWER ........................................................................................................ 8-1 7 9.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES ...................................................... 9-1 8 9.1 No-Action Alternative................................................................................................ 9-1 9 9.2 Energy Alternatives .................................................................................................. 9-2 10 9.3 Alternative Sites ....................................................................................................... 9-2 11 9.3.1 Alternative Site Selection Process ................................................................ 9-3 12 9.3.1.1 Selection of the Region of Interest ................................................. 9-4 13 9.3.1.2 Selection of Candidate Areas ........................................................ 9-4 14 9.3.1.3 Selection of Potential Sites ............................................................ 9-5 15 9.3.1.4 Selection of Candidate Sites and Proposed Site ........................... 9-6 16 9.3.1.5 Review Team Evaluation of the TVA Site Selection Process ........ 9-6 17 9.3.2 Review Team Evaluation of Alternative Sites ORR 2, ORR 8, and 18 Redstone 12 ............................................................................................... 9-12 19 9.3.2.1 Land Use ..................................................................................... 9-19 20 9.3.2.2 Water Use and Quality ................................................................. 9-23 21 9.3.2.3 Terrestrial and Wetland Resources ............................................. 9-33 22 9.3.2.4 Aquatic Resources ....................................................................... 9-42 23 9.3.2.5 Socioeconomics ........................................................................... 9-47 24 9.3.2.6 Environmental Justice .................................................................. 9-57 25 9.3.2.7 Historic and Cultural Resources .................................................. 9-60 26 9.3.2.8 Air Quality .................................................................................... 9-64 27 9.3.2.9 Nonradiological Health ................................................................. 9-66 28 9.3.2.10 Radiological Impacts of Normal Operations................................. 9-68 29 9.3.2.11 Accidents ..................................................................................... 9-69 30 9.3.3 Comparison of the Impacts of the Proposed Action at Alternative Sites .... 9-71 31 9.3.3.1 Comparison of Cumulative Impacts Associated with CRN Site 32 and Alternative Sites .................................................................... 9-72 33 9.3.3.2 Environmentally Preferable Sites ................................................. 9-73 34 9.3.3.3 Obviously Superior Sites.............................................................. 9-74 35 9.4 System Design Alternatives ................................................................................... 9-74 36 9.4.1 Heat-Dissipation System Alternatives ........................................................ 9-75 37 9.4.1.1 Once-Through Cooling ................................................................ 9-75 38 9.4.1.2 Closed-Cycle Cooling .................................................................. 9-75 39 9.4.2 Circulating-Water System Alternatives ....................................................... 9-79 40 9.4.2.1 Intake Alternatives ....................................................................... 9-79 41 9.4.2.2 Discharge Alternatives ................................................................. 9-81 42 9.4.2.3 Water Supply Alternatives ........................................................... 9-82 43 9.4.3 Summary .................................................................................................... 9-83 44

10.0 CONCLUSION

S AND RECOMMENDATIONS .............................................................. 10-1 xv

TABLE OF CONTENTS (CONTINUED) 1 10.1 Impacts of the Proposed Action ............................................................................. 10-3 2 10.1.1 Unavoidable Adverse Environmental Impacts ............................................ 10-3 3 10.1.1.1 Unavoidable Adverse Impacts during Construction and 4 Preconstruction ............................................................................ 10-3 5 10.1.2 Unavoidable Adverse Impacts during Operation ...................................... 10-12 6 10.2 Relationship between Short-Term Uses and Long-Term Productivity of the 7 Human Environment............................................................................................. 10-19 8 10.3 Irreversible and Irretrievable Commitments of Resources ................................... 10-19 9 10.3.1 Irreversible Commitments of Resources .................................................. 10-20 10 10.3.1.1 Land Use ................................................................................... 10-20 11 10.3.1.2 Water Use and Quality ............................................................... 10-20 12 10.3.1.3 Terrestrial and Aquatic Biota...................................................... 10-20 13 10.3.1.4 Socioeconomic Resources ........................................................ 10-21 14 10.3.1.5 Historic and Cultural Resources ................................................ 10-21 15 10.3.1.6 Air Quality .................................................................................. 10-21 16 10.3.2 Irretrievable Commitments of Resources ................................................. 10-21 17 10.4 Alternatives to the Proposed Action ..................................................................... 10-22 18 10.5 Benefit-Cost Balance............................................................................................ 10-22 19 10.6 Staff Conclusions and Recommendations ........................................................... 10-22 20

11.0 REFERENCES

............................................................................................................... 11-1 21 12.0 INDEX............................................................................................................................. 12-1 22 APPENDIX A - CONTRIBUTORS TO THE ENVIRONMENTAL IMPACT STATEMENT ...... A-1 23 APPENDIX B - ORGANIZATIONS CONTACTED .................................................................. B-1 24 APPENDIX C - CHRONOLOGY OF NRC AND USACE STAFF ENVIRONMENTAL 25 REVIEW CORRESPONDENCE RELATED TO THE TVA APPLICATION 26 FOR AN EARLY SITE PERMIT (ESP) AT THE CRN SITE ........................... C-1 27 APPENDIX D - SCOPING COMMENTS AND RESPONSES ................................................. D-1 28 APPENDIX E - DRAFT ENVIRONMENTAL IMPACT STATEMENT COMMENTS AND 29 RESPONSES ................................................................................................. E-1 30 APPENDIX F - KEY CONSULTATION CORRESPONDENCE ...............................................F-1 31 APPENDIX G - SUPPORTING INFORMATION FOR RADIOLOGICAL 32 DOSE ASSESSMENTS OF ROUTINE OPERATIONS (G.1) AND 33 POSTULATED SEVERE ACCIDENTS (G.2) ................................................ G-1 34 APPENDIX H - LIST OF AUTHORIZATIONS, PERMITS, AND CERTIFICATIONS .............. H-1 35 APPENDIX I - CLINCH RIVER NUCLEAR SITE CHARACTERISTICS AND PLANT 36 PARAMETER ENVELOPE VALUES............................................................... I-1 xvi

TABLE OF CONTENTS (CONTINUED) 1 APPENDIX J - REPRESENTATIONS AND ASSUMPTIONS ................................................. J-1 2 APPENDIX K - GREENHOUSE GAS FOOTPRINT ESTIMATES FOR A REFERENCE 3 1,000-MW(E) LIGHT WATER REACTOR (LWR) .......................................... K-1 4 APPENDIX L - THE EFFECT OF CLIMATE CHANGE ON THE EVALUATION OF 5 ENVIRONMENTAL IMPACTS ........................................................................L-1 6 APPENDIX M - BIOLOGICAL ASSESSMENT FOR THE U.S. FISH AND WILDLIFE 7 SERVICE REGARDING THE CLINCH RIVER SMALL MODULAR 8 REACTOR EARLY SITE PERMIT APPLICATION ........................................ M-1 xvii

1 LIST OF FIGURES 2 Figure ES-1 The CRN Site and Vicinity .............................................................................. xxxi 3 Figure ES-2 CRN Site and Alternative Sites 2 and 8 at Oak Ridge Reservation ............. xxxiv 4 Figure ES-3 Alternative Site at Redstone Arsenal Site 12 ................................................ xxxv 5 Figure 2-1 Clinch River Nuclear Site and Vicinity ............................................................ 2-2 6 Figure 2-2 Clinch River Nuclear Site Utilization Plan ........................................................ 2-3 7 Figure 2-3 Aerial View of the Existing CRN Site and Barge/Traffic Area .......................... 2-4 8 Figure 2-4 Land Use and Land Cover within the CRN Site and BTA .............................. 2-6 9 Figure 2-5 Affected Floodplains on the CRN Site ............................................................ 2-7 10 Figure 2-6 Farmland Resources in the Vicinity of the CRN Site ...................................... 2-9 11 Figure 2-7 Land Use within the Vicinity of the CRN Site ............................................... 2-11 12 Figure 2-8 Affected TVA Transmission Corridors ........................................................... 2-13 13 Figure 2-9 Borrow Pits Currently Used by TVA ............................................................. 2-14 14 Figure 2-10 Land Use in the CRN Site Region ................................................................ 2-16 15 Figure 2-11 Major Transportation Features in the CRN Site Region ............................... 2-17 16 Figure 2-12 Streams and Rivers near the CRN Site ......................................................... 2-20 17 Figure 2-13 Locations of Dams that Influence Flows at the CRN Site ............................. 2-21 18 Figure 2-14 Watts Bar Reservoir Elevation at the Dam: Maximum, Minimum, and 19 Average of Daily Midnight Readings for 2004-2013 ..................................... 2-22 20 Figure 2-15 Annual Discharge of the Clinch River Upstream of Norris Reservoir, 21 1920-2016 ................................................................................................... 2-24 22 Figure 2-16 Frequency of Hourly Discharge from the Melton Hill Dam for 2004-2013 ... 2-25 23 Figure 2-17 Bathymetry of the Clinch River at the CRN Site Intake Location ................. 2-26 24 Figure 2-18 Bathymetry of the Clinch River at the CRN Site Discharge Location ........... 2-27 25 Figure 2-19 Streams, Ponds, and Wetlands on and near the CRN Site ........................... 2-29 26 Figure 2-20 Road Cut in Valley and Ridge Physiographic Province Illustrating 27 Secondary Porosity Features: Fractures, Bedding Planes, and 28 Dissolution ..................................................................................................... 2-30 29 Figure 2-21 Mapped Karst Features in the CRN Site Area ............................................. 2-32 30 Figure 2-22 CRN Site Topography and Observation Well Locations .............................. 2-35 31 Figure 2-23 Continuous and Manual Groundwater Heads Measured at Well Cluster 32 OW-423 ........................................................................................................ 2-36 33 Figure 2-24 Wells Located within 1.5 Mi of the CRN Site ................................................ 2-40 34 Figure 2-25 Results of Hourly Temperature Monitoring in the Tailwater below Melton 35 Hill Dam, in 2004 and 2008-2013 ................................................................ 2-45 36 Figure 2-26 Average and Range of Hourly Water Temperature in the Tailwater below 37 Melton Hill Dam by Date ............................................................................... 2-45 38 Figure 2-27 Plant Communities and Habitat Types across the CRN Site and BTA.......... 2-53 39 Figure 2-28 Important Terrestrial Habitats on and within 2 Mi of the CRN Site and 40 BTA ............................................................................................................... 2-77 41 Figure 2-29 Aggregate Minority Block Groups within 50 Mi of the CRN Site .................. 2-134 42 Figure 2-30 Low-Income Block Groups within 50 Mi of the CRN Site ............................ 2-135 xix

LIST OF FIGURES (CONTINUED) 1 Figure 2-31 Onsite Direct- and Indirect-Effects APEs at the CRN Site .......................... 2-140 2 Figure 2-32 Offsite Direct- and Indirect-Effects APEs at the Melton Hill Dam ................ 2-141 3 Figure 2-33 Simplified Geologic Map of the CRN Site and Vicinity ............................... 2-159 4 Figure 2-34 Geologic Cross Section near the CRN Site and Vicinity ............................ 2-160 5 Figure 2-35 Stratigraphic Section for the CRN Site and Vicinity .................................... 2-161 6 Figure 2-36 Geotechnical Cross Section through the CRN Site Power-Block Area ...... 2-162 7 Figure 2-37 Site Layout at the Meteorological Tower .................................................... 2-171 8 Figure 2-38 CRN Site Aerial Map .................................................................................. 2-178 9 Figure 2-39 Traffic Study Intersections Potentially Affected by the Proposed Project ... 2-180 10 Figure 3-1 Project Layout ................................................................................................. 3-3 11 Figure 3-2 Architectural Rendering of Two SMR Units Superimposed on the CRN 12 Site ................................................................................................................. 3-4 13 Figure 3-3 Conceptual Plan View of the Cooling-Water Intake Structure ........................ 3-6 14 Figure 3-4 Conceptual Side View of the Cooling-Water Intake Structure ........................ 3-6 15 Figure 3-5 Conceptual Plan View of the Cooling-Water Discharge Structure .................. 3-7 16 Figure 3-6 Existing 161-kV and 500-kV Transmission Lines and Proposed New 17 Underground 69-kV Transmission Line in the Vicinity of the CRN Site ......... 3-10 18 Figure 3-7 Plant Water-Use Diagram ............................................................................ 3-20 19 Figure 4-1 Construction and Preconstruction Impacts on Land Use/Land Cover at 20 the CRN Site .................................................................................................. 4-6 21 Figure 4-2 Aerial Overview of Expected Land-Use Impacts of Construction and 22 Preconstruction at the CRN Site .................................................................... 4-7 23 Figure 4-3 CRN Site and BTA Development Footprint Overlaid on Terrestrial 24 Habitats and Wetlands .................................................................................. 4-20 25 Figure 4-4 Pre- and Post-Construction Forest Interior Parcels on the CRN Site and 26 near the BTA ................................................................................................. 4-22 27 Figure 4-5 Conceptual Traffic Flow and Mitigation Design for 2024 Access to the 28 CRN Site ...................................................................................................... 4-55 29 Figure 5-1 TVA Simulation Results of Thermal Discharge Effects under Bounding 30 Winter Conditions at 13 Hours and 24 Hours from the Start of the 31 Simulation Period ......................................................................................... 5-10 32 Figure 5-2 Salt Deposition Rates that Exceed the 1,000 kg/km2/mo Threshold 33 Overlaid on Terrestrial Vegetation on the CRN Site ...................................... 5-15 34 Figure 5-3 Visual Simulation of the Operating Facilities at the CRN Site Showing the 35 Annual Average Cooling-Tower Plume ......................................................... 5-29 36 Figure 5-4 Visual Simulation of the Operating Facilities at the CRN Site Showing the 37 Annual Average Cooling-Tower Plume ......................................................... 5-29 38 Figure 5-5 Example Exposure Pathways to Humans .................................................... 5-55 39 Figure 5-6 Example Exposure Pathways to Biota Other than Humans ......................... 5-57 40 Figure 6-1 The Uranium Fuel Cycle: No-Recycle Option ................................................ 6-6 41 Figure 6-2 Illustration of the Truck Stop Model ............................................................... 6-29 42 Figure 9-1 TVA Site Selection Process ........................................................................... 9-3 43 Figure 9-2 The Region of Interest and Candidate Areas ................................................. 9-4 44 Figure 9-3 ORR Candidate Sites ..................................................................................... 9-7 xx

LIST OF FIGURES (CONTINUED) 1 Figure 9-4 Redstone Arsenal Candidate Sites ................................................................ 9-8 2 Figure 9-5 Location of ORR Alternative Sites Relative to the CRN Site ........................ 9-13 3 Figure 9-6 Aerial Overview of the Redstone Alternative Site ......................................... 9-14 4 Figure 9-7 Minority Populations within 50 Mi of the Redstone Arsenal .......................... 9-58 5 Figure 9-8 Low-Income Populations within 50 Mi of the Redstone Arsenal ................... 9-59 xxi

1 LIST OF TABLES 2 Table ES-1 Environmental Impact Levels at the CRN Site .............................................. xxxii 3 Table ES-2 Cumulative Impacts on Environmental Resources, Including the Impacts 4 of Proposed Action ....................................................................................... xxxiii 5 Table ES-3 Comparison of Cumulative Impacts at the CRN Site and Alternative Sites.. xxxvi 6 Table 2-1 Land Use and Land Cover within the CRN Site and Surrounding Areas ...... 2-10 7 Table 2-2 Mileage and Acreage of Affected Transmission Line Corridors .................... 2-12 8 Table 2-3 Reservoirs that Influence Flows at the CRN Site .......................................... 2-22 9 Table 2-4 Monthly Mean Statistics for Melton Hill Dam Releases ................................. 2-24 10 Table 2-5 Saturated Hydraulic Conductivity Results from CRN Site Tests ................... 2-37 11 Table 2-6 Maximum Values for Water-Quality Parameters Measured by TVA in the 12 Clinch River Arm of Watts Bar Reservoir ...................................................... 2-42 13 Table 2-7 Minimum and Maximum Values for Groundwater-Quality Parameters at 14 the CRN Site ................................................................................................. 2-47 15 Table 2-8 ORR Legacy Contaminants Detected in CRN Site Groundwater Samples .. 2-48 16 Table 2-9 Extent of Habitat Types on the CRN Site and in the BTA ............................. 2-51 17 Table 2-10 Type, Condition, and Size of Wetlands on the CRN Site and in the BTA...... 2-56 18 Table 2-11 Terrestrial Resources within Transmission Line Segments that May Be 19 Uprated, Reconductored, or Rebuilt .............................................................. 2-62 20 Table 2-12 Important Species within 2 mi of the CRN Site and within 2 mi of the BTA .. 2-73 21 Table 2-13 Important Terrestrial Habitats within 2 mi of the CRN Site or BTA ............... 2-75 22 Table 2-14 Important Species Known to Occur within 0.125 mi of the Offsite 23 Transmission Lines that May Be Uprated, Reconductored, or Rebuilt .......... 2-80 24 Table 2-15 Federally Listed Species Occurring in the Counties with the Proposed 25 Transmission Lines that Would Be Uprated, Reconductored, and Rebuilt ... 2-86 26 Table 2-16 Local Invasive Plant Species ........................................................................ 2-91 27 Table 2-17 Abundance of Native Mussels in Clinch River, CRM 15.0 to 19.0 ................ 2-98 28 Table 2-18 Recreationally Valuable Fish in the Clinch River Arm of the Watts Bar 29 Reservoir in the Vicinity of the CRN Site .................................................... 2-101 30 Table 2-19 Federally Listed Aquatic Species in the Vicinity of the CRN Site ................ 2-102 31 Table 2-20 State-Listed Aquatic Species in Roane County, Tennessee ....................... 2-103 32 Table 2-21 Federally Listed Aquatic Species that May Occur in Proximity to the 33 Transmission Lines Proposed for Upgrade in: Franklin, Warren, White, 34 Van Buren, Bledsoe, Rhea, Putnam, Cumberland, Roane, Anderson, 35 Scott, Knox, Campbell, Grainger, Hawkins, Greene, Jefferson, Hamblen, 36 Claiborne, Grundy, Hamilton, Sequatchie, Sevier, and Cocke Counties, 37 Tennessee; Bell and Whitely counties Kentucky, and Catoosa County 38 Georgia........................................................................................................ 2-107 39 Table 2-22 Recent Population and Growth Rates of Counties in the Economic 40 Region ......................................................................................................... 2-110 41 Table 2-23 Population of Municipalities within 10 mi of the CRN Site ........................... 2-111 xxiii

LIST OF TABLES (CONTINUED) 1 Table 2-24 Historical and Projected County Populations in the Economic Region, 2 1970-2040 .................................................................................................. 2-112 3 Table 2-25 2015 Percentage Age and Gender Distribution in the Economic Region 4 and State ..................................................................................................... 2-113 5 Table 2-26 Household Income Distribution within the Economic Region in 2015 6 Inflation-Adjusted Dollars ............................................................................ 2-114 7 Table 2-27 2015 Racial and Ethnic Percentage Distribution within the Economic 8 Region ......................................................................................................... 2-114 9 Table 2-28 2016 Annual Average Labor Force, Employment, and Unemployment in 10 Counties of the Region and Tennessee ...................................................... 2-115 11 Table 2-29 Annual Unemployment Rates for Counties of the Economic Region and 12 Tennessee, 2005 to 2016 ............................................................................ 2-116 13 Table 2-30 Total Employment by Industry in the Economic Region ............................. 2-117 14 Table 2-31 TVA Tax-Equivalent Payments to State of Tennessee and Local Counties 15 FY 2011 through FY 2016 .......................................................................... 2-119 16 Table 2-32 Current Applicable Tax Rates by County and Principal Tax Type............... 2-119 17 Table 2-33 2016 Summarized Revenue and Expenses by County Governments ....... 2-120 18 Table 2-34 Peak-Hour Traffic Volume and Level of Service at Key Intersections ........ 2-123 19 Table 2-35 Housing Data for Counties in the Economic Region .................................. 2-126 20 Table 2-36 Major Water Supply Systems in the Economic Region ............................... 2-127 21 Table 2-37 Public Wastewater-Treatment Systems in the Economic Region .............. 2-128 22 Table 2-38 Local Law Enforcement Personnel in Counties of the Economic Region .. 2-129 23 Table 2-39 Public School Enrollment, Teachers, and Student-to-Teacher Ratios in 24 the Economic Region and State .................................................................. 2-130 25 Table 2-40 Statewide Percent Minority Populations and Associated 20 Percentage 26 Point Threshold Criteria for the 50-Mi Demographic Region ....................... 2-133 27 Table 2-41 Distribution of Census Block Groups Exceeding Environmental Justice 28 Thresholds within a 50-Mi Radius of the CRN Site and the Counties of 29 the Economic Region .................................................................................. 2-136 30 Table 2-42 Historic and Cultural Resources Located within the Onsite and Offsite 31 Direct- and Indirect-Effects APEs ................................................................ 2-144 32 Table 2-43 Summary of TVAs Historic and Cultural Resource Investigations 33 Completed of the Onsite Direct-Effects APE at the CRN Site for NHPA 34 Section 106 Compliance Purposes ............................................................. 2-151 35 Table 2-44 Mean Seasonal and Annual Morning and Afternoon Mixing Heights near 36 the CRN Site ............................................................................................... 2-169 37 Table 2-45 Atmospheric Dispersion Factors for Design Basis Accident Calculations ... 2-169 38 Table 2-46 Maximum Annual Average Atmospheric Dispersion and Deposition 39 Factors for Evaluation of Normal Effluents for Receptors of Interest .......... 2-170 40 Table 2-47 Meteorological Tower Instrumentation Performance Specifications............ 2-173 41 Table 2-48 Sound Levels Measured during the Baseline Survey .................................. 2-179 42 Table 3-1 Definitions and Examples of Activities Associated with the Proposed 43 Project ........................................................................................................... 3-13 xxiv

LIST OF TABLES (CONTINUED) 1 Table 3-2 Summary of Parameters and Resource Commitments Associated with 2 Construction and Preconstruction of the Proposed Project ........................... 3-17 3 Table 3-3 Projected Blowdown Constituents and Concentrations ................................. 3-23 4 Table 3-4 Projected Maximum Annual Emissions from Auxiliary Boilers, Standby 5 Diesel Generators, and Gas Turbines ........................................................... 3-24 6 Table 3-5 Resource Parameters Associated with Operation of the Proposed Project .. 3-25 7 Table 4-1 Land-Use Changes as a Result of Construction and Preconstruction 8 Activities on the CRN Site ............................................................................... 4-5 9 Table 4-2 Habitat and Land-Cover Types that Would Be Disturbed by Developing 10 the CRN Site and BTA .................................................................................. 4-21 11 Table 4-3 Affected Wetlands on the CRN Site .............................................................. 4-23 12 Table 4-4 Estimated Construction Workforce Requirements by Construction Month.... 4-46 13 Table 4-5 Projected Peak Construction Onsite Labor Requirements ............................ 4-48 14 Table 4-6 Estimated Population Increase and Employment in the Economic Impact 15 Region during the Peak Construction Period ................................................ 4-49 16 Table 4-7 Impacts on Roadways around the CRN Site during Peak Building ............... 4-54 17 Table 4-8 Estimated Housing Impacts in the Economic Regional at Peak 18 Employment .................................................................................................. 4-57 19 Table 4-9 Estimated Water Supply Impacts in the Economic Region ........................... 4-58 20 Table 4-10 Estimated Wastewater Supply Impacts in the Economic Region .................. 4-58 21 Table 4-11 Estimated Number of School-Aged Children Associated with In-Migrating 22 Workforce Associated with Building at the CRN Site .................................... 4-60 23 Table 4-12 Annual Nonradiological Impacts of Transporting Workers and Materials to 24 and from the Proposed CRN Site .................................................................. 4-76 25 Table 4-13 Measures and Controls to Limit Adverse Impacts when Building a New 26 SMR at the CRN Site .................................................................................... 4-83 27 Table 4-14 Summary of Impacts from Building a New Nuclear Power Plant at the 28 CRN Site ....................................................................................................... 4-86 29 Table 5-1 Clinch River Arm of Watts Bar Reservoir Flow Reduction from CRN Site 30 Withdrawal and Consumptive Use ................................................................. 5-6 31 Table 5-2 Estimated Population Increase in the Economic Region during 32 Operations, Not Including Outage Workers ................................................... 5-30 33 Table 5-3 Annual Estimated Emissions from Cooling Towers, Auxiliary Boilers, 34 Diesel Generators, and Gas Turbines at the CRN Site ................................. 5-44 35 Table 5-4 Nonradiological Impacts of Transporting Workers to and from the 36 Proposed CRN Site for SMRs ....................................................................... 5-53 37 Table 5-5 Doses to the MEI for Liquid Effluent Releases from the CRN Site ................ 5-58 38 Table 5-6 Doses to the MEI from the Gaseous Effluent Pathway for the CRN Site ...... 5-59 39 Table 5-7 Comparison of MEI Dose Estimates from Liquid and Gaseous Effluents 40 of the CRN Site to 10 CFR Part 50 Appendix I, Design Objectives .............. 5-60 41 Table 5-8 Comparison of MEI Doses from All Units for the CRN Site to 40 CFR Part 42 190 ................................................................................................................ 5-60 43 Table 5-9 Calculated Doses to the Population within 50 Mi of the CRN Site from 44 Gaseous and Liquid Pathways ...................................................................... 5-61 xxv

LIST OF TABLES (CONTINUED) 1 Table 5-10 Nonhuman Biota Dose Rates from All SMR Units at the CRN Site............... 5-63 2 Table 5-11 Comparison of Nonhuman Biota Dose Rates from All SMR Units at the 3 CRN Site to Relevant Guidelines for Nonhuman Biota Protection ................ 5-64 4 Table 5-12 Atmospheric Dispersion Factors for CRN Site Design Basis Accident 5 Calculations ................................................................................................... 5-73 6 Table 5-13 Doses for the Surrogate Plant LOCA ............................................................ 5-73 7 Table 5-14 Environmental Risks from a Severe Accident at the CRN Site Assuming a 8 Site Boundary EPZ ........................................................................................ 5-77 9 Table 5-15 Environmental Risks from a Severe Accident at the CRN Site Assuming a 10 2-Mi EPZ ....................................................................................................... 5-78 11 Table 5-16 Environmental Risks from a Severe Accident at the CRN Site Assuming a 12 10-Mi EPZ ..................................................................................................... 5-79 13 Table 5-17 Comparison of Environmental Risks for a Small Modular Reactor at the 14 CRN Site with Risks for Current-Generation Reactors .................................. 5-81 15 Table 5-18 Comparison of Environmental Risks from Severe Accidents for a Small 16 Modular Reactor at the CRN Site with Risks for Current Plants from 17 Operating License Renewal Reviews ............................................................ 5-82 18 Table 5-19 Measures and Controls to Limit Adverse Impacts during Operation of a 19 New Nuclear Power Plant at the CRN Site ................................................... 5-89 20 Table 5-20 Summary of Operational Impacts for a New SMR at the CRN Site .............. 5-94 21 Table 6-1 Uranium Fuel-Cycle Environmental Data as Provided in Table S-3 of 10 22 CFR 51.51(b) .................................................................................................. 6-2 23 Table 6-2 Comparison of Annual Average Dose Received by an Individual from All 24 Sources ......................................................................................................... 6-13 25 Table 6-3 2006-2015 Summary of Disposal of LLW Generated in the State of 26 Tennessee..................................................................................................... 6-13 27 Table 6-4 Number of Truck Shipments of Unirradiated Fuel for the Reference LWR 28 and the Surrogate SMR at the CRN Site, Normalized to the Reference 29 LWR (880 MW(e) net) ................................................................................... 6-20 30 Table 6-5 RADTRAN 6 Input Parameters for Reference LWR Fresh Fuel Shipments.. 6-21 31 Table 6-6 Radiological Impacts under Normal Conditions of Transporting 32 Unirradiated Fuel to the CRN Site or Alternative Sites, Normalized to 33 Reference LWR (880 MW(e) net) .................................................................. 6-22 34 Table 6-7 Nonradiological Impacts of Transporting Unirradiated Fuel to the CRN 35 Site and Alternative Sites, Normalized to Reference LWR (880 MW(e) 36 net) ................................................................................................................ 6-26 37 Table 6-8 Transportation Route Information for Shipments from the CRN Site and 38 Alternative Sites to the Yucca Mountain Spent Fuel Disposal Facility .......... 6-28 39 Table 6-9 RADTRAN 6 Normal Exposure Parameters .................................................. 6-28 40 Table 6-10 Normal Radiation Doses to Transport Workers and the Public from 41 Shipping Spent Fuel from the CRN Site and Alternative Sites to the 42 Proposed HLW Repository at Yucca Mountain, Normalized to Reference 43 LWR (880 MW(e) net) ................................................................................... 6-30 44 Table 6-11 PPE Radionuclide Inventory Used in Transportation Accident Risk 45 Calculations for the Surrogate SMR .............................................................. 6-33 xxvi

LIST OF TABLES (CONTINUED) 1 Table 6-12 Annual Spent Fuel Transportation Accident Impacts for Transporting 2 Spent Fuel from the CRN Site and Alternative Sites, Normalized to 3 Reference LWR Reactor (880 MW(e) net) .................................................... 6-34 4 Table 6-13 Nonradiological Impacts of Transporting Spent Fuel from the CRN Site 5 and Alternative Sites to Yucca Mountain, Normalized to Reference LWR 6 (880 MW(e) net) ............................................................................................ 6-35 7 Table 6-14 Summary of Radioactive Waste Shipments from the CRN Site and 8 Alternative Sites, Normalized to Reference LWR (880 MW(e) net) .............. 6-36 9 Table 6-15 Nonradiological Impacts of Radioactive Waste Shipments from the CRN 10 Site and Alternative Sites, Normalized to the Reference LWR (880 MW(e) 11 net) ................................................................................................................ 6-37 12 Table 7-1 Projects and Other Actions Considered in the Cumulative Impacts 13 Analysis for the CRN Site ................................................................................ 7-2 14 Table 7-2 Comparison of Annual Carbon Dioxide Equivalent Emissions ...................... 7-36 15 Table 7-3 Cumulative Impacts on Environmental Resources, Including the Impacts 16 of Two or More SMRs at the CRN Site ......................................................... 7-45 17 Table 9-1 Rankings of the Candidate Sites Based on Total Numerical Scores............... 9-6 18 Table 9-2 Projects and Other Actions Considered in the Cumulative Impacts 19 Analysis for Redstone Arsenal Site 12 .......................................................... 9-15 20 Table 9-3 2016 Land Cover by Alternative Site ............................................................. 9-20 21 Table 9-4 Important Species within 2 Mi of ORR Site 2 and ORR Site 8 ..................... 9-35 22 Table 9-5 2016 Land Cover in the 6-Mi GAI of the Alternative Sites ............................. 9-40 23 Table 9-6 Federally and State-Listed Aquatic Species in the Vicinity of CRN at ORR 24 Site 2 and Site 8 in Tennessee ..................................................................... 9-44 25 Table 9-7 Federally and State-Listed Aquatic Species in the Vicinity of Redstone 26 Arsenal Site 12 in Alabama ........................................................................... 9-44 27 Table 9-8 Construction Impacts Estimated Population Increase for the ORR Site 2 28 and ORR Site 8 ............................................................................................. 9-48 29 Table 9-9 Operations Impacts Estimated Population Increase for the ORR Site 2 30 and ORR Site 8 ............................................................................................. 9-48 31 Table 9-10 Construction Impacts Estimated Population Increase for Redstone 32 Arsenal Site 12 .............................................................................................. 9-49 33 Table 9-11 Operations Impacts Estimated Population Increase for Redstone Arsenal 34 Site 12 ........................................................................................................... 9-49 35 Table 9-12 TVA Tax-Equivalent Payments to the State of Alabama and Local 36 Counties from FY 2011 through FY 2016 ...................................................... 9-51 37 Table 9-13 Estimated Housing Impacts in the Redstone Site 12 Economic Region at 38 Peak Employment ......................................................................................... 9-54 39 Table 9-14 Comparison of Cumulative Impacts at the Proposed CRN Site and Three 40 Alternative Sites ............................................................................................ 9-73 41 Table 9-15 Estimated Land Use and Consumptive Water Use of Alternative Closed-42 Cycle Cooling Systems for an 800-MW(e) Nuclear Power Plant .................. 9-76 43 Table 10-1 Unavoidable Adverse Environmental Impacts during Construction and 44 Preconstruction ............................................................................................. 10-4 45 Table 10-2 Unavoidable Adverse Environmental Impacts from Operations .................. 10-13 xxvii

1 EXECUTIVE

SUMMARY

2 This draft environmental impact statement (EIS) presents the results of a U.S. Nuclear 3 Regulatory Commission (NRC) environmental review of an application by the Tennessee Valley 4 Authority (TVA) for an early site permit (ESP) at the Clinch River Nuclear (CRN) Site in Oak 5 Ridge, Roane County, Tennessee, for a new nuclear power plant demonstrating small modular 6 reactor (SMR) technology. The Nashville District, Regulatory Division, U.S. Army Corps of 7 Engineers (USACE) is a cooperating agency with the NRC to verify that the information 8 presented in this draft EIS is adequate to support a Department of the Army permit application if 9 TVA submits a Department of the Army permit application at a future date. The USACE is 10 cooperating in the preparation of this draft EIS to streamline regulatory review processes, avoid 11 unnecessary duplication of effort, and ensure issues and concerns related to impacts on waters 12 of the United States and navigable waters of the United States are identified and addressed early 13 in the NRCs review process. The NRC, its contractors, and USACE make up the review team.

14 Background

15 On May 16, 2016, TVA submitted an application to the NRC for an ESP at the CRN Site. TVA 16 subsequently provided supplemental information in support of the application. The staff 17 determined that the application (with the subsequent submittals) was sufficient for docketing and 18 issued a Federal Register (82 FR 3812) notice notifying the public of the NRCs acceptance of 19 the CRN Site ESP application on January 12, 2017. On December 15, 2017, 2017, TVA 20 submitted Revision 1 of its application, including the Environmental Report (ER) to the NRC.

21 Upon acceptance of TVAs application, the NRC review team began the environmental review 22 process as described in Title 10 of the Code of Federal Regulations Part 52 (10 CFR Part 52) 23 by publishing a Notice of Intent to prepare an EIS and conduct scoping in the Federal Register 24 on April 13, 2017 (82 FR 17885). As part of this environmental review, the review team did the 25 following:

26 considered comments received during a 60-day scoping process that began on April 13, 27 2017 and ended on June 12, 2017, and conducted related public scoping meetings on May 28 15, 2017 in Oak Ridge, Tennessee 29 reviewed TVAs ER, as supplemented by TVA, and conducted a full scope environmental 30 audit in May 2017 31 conducted visits to the proposed CRN Site and alternative sites in May 2017 32 consulted with Tribal Nations and other agencies such as the U.S. Fish and Wildlife Service, 33 Advisory Council on Historic Preservation, Tennessee Historical Commission, Tennessee 34 Department of Environment and Conservation, Tennessee Wildlife Resource Agency, and 35 Alabama Department of Conservation and Natural Resources.

36 Proposed Action 37 The proposed action related to the TVA application is the issuance of an ESP for the CRN Site 38 approving the site as suitable for the future demonstration of the construction and operation of 39 two or more SMRs with characteristics presented in the application.

xxix

1 Purpose and Need for Action 2 The purpose of the proposed NRC action, issuance of the ESP, is to provide for early resolution 3 of site safety and environmental issues, which provides stability in the licensing process. The 4 NRCs purpose and need is further informed by the applicants purpose and need. TVAs 5 application provides TVAs analyses of the environmental impacts that could result from building 6 and operating two or more SMRs with a maximum total electrical output of 800 MW(e) to 7 demonstrate the capability of SMR technology.

8 The objective of the USACE review is to streamline its regulatory review process, avoid 9 unnecessary duplication of effort, and ensure issues and concerns related to impacts on waters 10 of the United States and navigable waters of the United States are identified and addressed 11 early in the NRCs review process.

12 Public Involvement 13 A 60-day scoping period was held from April 13, 2017 to June 12, 2017. On May 15, 2017, the 14 NRC held public scoping meetings in Oak Ridge, Tennessee. The review team received oral 15 comments during the public meetings and a total of 74 pieces of scoping correspondence about 16 topics such as surface-water hydrology, ecology, socioeconomics, and historic and cultural 17 resources. The review teams responses to the in-scope public comments can be found in 18 Appendix D of this draft EIS. The Scoping Summary Report (Agencywide Documents Access 19 and Management System Accession Package No. ML17242A061) contains all of the comments 20 and responses, including those considered out-of-scope.

21 Affected Environment 22 The CRN Site is located in Oak Ridge, Roane County, Tennessee (Figure ES-1). The CRN Site 23 is located on the Clinch River arm of the Watts Bar Reservoir, adjacent to the existing U.S.

24 Department of Energys Oak Ridge Reservation. The CRN Site is situated in the southwestern 25 part of the city limits of Oak Ridge approximately 10 mi south of the Oak Ridge urban center; 16 26 mi west of Knoxville, Tennessee; and 7 mi east of Kingston, Tennessee. The primary source of 27 cooling water would be the Clinch River. The ultimate heat sink for the CRN SMRs would be 28 the atmosphere, using mechanical draft cooling towers.

29 Evaluation of Environmental Impacts 30 This draft EIS evaluates the potential environmental impacts of the construction and operation 31 of two or more SMRs at the CRN Site related to the following resource areas:

land use human health (radiological and nonradiological) air quality socioeconomics aquatic ecology environmental justice terrestrial ecology cultural resources surface water and groundwater fuel cycle, decommissioning, and transportation.

waste 32 The impacts are designated as SMALL, MODERATE, or LARGE. The incremental impacts 33 related to the construction and operations activities requiring NRC authorization are described xxx

1 2 Figure ES-1. The CRN Site and Vicinity xxxi

1 and characterized, as are the cumulative 2 impacts resulting from the proposed action SMALL: Environmental effects are not detectable or are so minor that they will 3 when the effects are added to, or interact with, neither destabilize nor noticeably alter any 4 other past, present, and reasonably important attribute of the resource.

5 foreseeable future effects on the same MODERATE: Environmental effects are 6 resources. The construction and operation sufficient to alter noticeably, but not to 7 impacts are outlined in Table ES-1. Table ES-2 destabilize, important attributes of the 8 summarizes the review teams assessment of resource.

9 cumulative impacts. The review teams LARGE: Environmental effects are clearly 10 detailed analysis, which supports the impact noticeable and are sufficient to destabilize 11 assessment of the proposed new units, can be important attributes of the resource.

12 found in Chapters 4, 5, 6, and 7.

13 Table ES-1. Environmental Impact Levels at the CRN Site Construction and Resource Category Preconstruction Operation Land Use Site and Vicinity MODERATE SMALL Water-Related Water Use - Surface Water SMALL SMALL Water Use - Groundwater Use SMALL SMALL Water Quality - Surface Water SMALL SMALL Water Quality - Groundwater SMALL SMALL Ecology Terrestrial Ecosystems MODERATE SMALL Aquatic Ecosystems SMALL SMALL Socioeconomic Physical Impacts SMALL to MODERATE SMALL to MODERATE (aesthetics)

Demography SMALL SMALL Economic Impacts on the Community SMALL (beneficial to the SMALL (beneficial to the region) region)

Infrastructure and Community SMALL (for all categories SMALL to MODERATE Services except traffic) and MODERATE (recreation) to LARGE (for traffic)

Environmental Justice NONE(a) NONE(a)

Historic and Cultural Resources Onsite Direct and Indirect Effects MODERATE to LARGE SMALL Area of Potential Affect Air Quality SMALL SMALL Nonradiological Health SMALL to MODERATE SMALL to MODERATE Radiological Health SMALL SMALL Nonradioactive Waste SMALL SMALL Postulated Accidents NA SMALL Fuel Cycle, Transportation, and NA SMALL Decommissioning (a) 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.

xxxii

1 Table ES-2. Cumulative Impacts on Environmental Resources, Including the Impacts of 2 Proposed Action Resource Category Impact Level Land Use MODERATE Water-Related Water Use - Surface Water MODERATE Water Use - Groundwater Use SMALL Water Quality - Surface Water MODERATE Water Quality - Groundwater MODERATE Ecology Terrestrial Ecosystems MODERATE Aquatic Ecosystems LARGE Socioeconomic Physical Impacts SMALL to MODERATE Demography SMALL Taxes and Economy SMALL Infrastructure and Community Services MODERATE to LARGE Environmental Justice NONE(a)

Historic and Cultural Resources MODERATE to LARGE Air Quality SMALL for criteria pollutants and MODERATE for GHGs Nonradiological Health SMALL to MODERATE Nonradioactive Waste SMALL Radiological Health SMALL Postulated Accidents SMALL Fuel Cycle, Transportation, and SMALL Decommissioning (a) 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.

3 Alternatives 4 The review team considered the environmental impacts associated with alternatives to issuing 5 an ESP for the CRN Site. These alternatives included a no-action alternative (i.e., not issuing 6 the ESP), siting locations, and system designs. The applicants ER is not required to include a 7 discussion of the alternative energy sources for an ESP (10 CFR 51.50(b)(2)).

8 The no-action alternative would result if NRC does not grant the ESP. If an ESP is not granted, 9 construction and operation of new units at the CRN Site in accordance with the 10 CFR Part 52 10 (TN251) process referencing an approved ESP would not occur, nor would any benefits 11 intended by an approved ESP be realized.

12 After comparing the cumulative effects of building and operating two or more SMRs at the 13 proposed site against those at the alternative sites, the NRC staff concluded that none of the 14 alternative sites would be environmentally preferable to the proposed site for building and 15 operating two or more SMRs (Table ES-3). The alternatives sites selected were as follows 16 (Figure ES-2 and ES-3):

17 Oak Ridge Reservation (ORR) Site 2, in Oak Ridge, Tennessee 18 ORR Site 8, in Oak Ridge, Tennessee 19 Redstone Arsenal Site 12, in Huntsville, Alabama.

xxxiii

1 2 Figure ES-2. CRN Site (Site 3) and Alternative Sites 2 and 8 at Oak Ridge Reservation xxxiv

1 2 Figure ES-3. Alternative Site at Redstone Arsenal Site 12 xxxv

1 Table ES-3. Comparison of Cumulative Impacts at the CRN Site and Alternative Sites CRN Site Redstone Resource Category (Site 3)(a) ORR Site 2(a) ORR Site 8(b) Arsenal Site 12(b)

Land Use MODERATE MODERATE MODERATE MODERATE Water-Related 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 Ecology Terrestrial ecosystems MODERATE LARGE LARGE MODERATE Aquatic ecosystems 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 MODERATE to MODERATE to MODERATE to MODERTE to community services LARGE LARGE LARGE LARGE Environmental Justice None(c) None(c) None(c) None(c)

Historic and Cultural MODERATE to MODERATE to MODERATE to MODERATE to Resources LARGE LARGE LARGE LARGE Air Quality Criteria pollutants SMALL SMALL SMALL SMALL Greenhouse gas MODERATE MODERATE MODERATE MODERATE emissions Nonradiological Health SMALL to SMALL to SMALL to SMALL to MODERATE MODERATE MODERATE MODERATE Nonradioactive Waste SMALL SMALL SMALL SMALL Radiological Health SMALL SMALL SMALL SMALL Postulated Accidents SMALL SMALL SMALL SMALL (a) Impact levels for all alternatives are for construction and operation but do not reflect cumulative impacts. Thus, the nuclear impacts identified here may differ from those used to compare the proposed site to the alternative sites, which reflect cumulative impacts.

(b) Impacts are from draft EIS Table 9-14. These conclusions for energy alternatives should be compared to NRC-authorized activities reflected in Chapters 4 and 5 and Sections 6.1 and 6.2.

(c) 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.

2 Table ES-3 provides a summary of the cumulative impacts for the proposed and alternative 3 sites. The NRC staff concluded that all of the sites were generally comparable, and it would be 4 difficult to state that one site is preferable to another from an environmental perspective. In 5 such a case, the proposed site prevails because none of the alternatives is environmentally 6 preferable to the proposed site.

xxxvi

1 The NRC staff considered various alternative system designs, including alternative heat-2 dissipation systems and multiple alternative intake, discharge, and water-supply systems. The 3 review team identified no alternatives that were environmentally preferable to the proposed 4 CRN SMR system design.

5 Benefits and Costs 6 TVA did not address the balance of benefits and costs in its ESP application for the CRN Site, 7 because such an assessment is not required for an ESP application per 10 CFR 51.50, Section 8 (b)(2) (TN250). Should the NRC ultimately determine to issue an ESP for the CRN site, and a 9 CP or COL application that references such an ESP is docketed, these matters will be 10 considered in the EIS prepared in connection with the review of that CP or COL application.

11 Recommendation 12 The NRC staffs preliminary recommendation to the Commission related to the environmental 13 aspects of the proposed action is that the ESP should be issued.

14 This recommendation is based on the following:

15 the application, including the ER and supplemental information submitted by TVA 16 consultation with Federal, State, Tribes, and local agencies 17 information gathered during the environmental audit and visits to the site and alternative 18 sites 19 consideration of public comments received during the environmental review 20 the review teams independent review and assessment summarized in this draft EIS.

21 xxxvii

1 ABBREVIATIONS AND ACRONYMS 2

3 °C degree(s) Celsius 4 °F degree(s) Fahrenheit 5 µg microgram(s) 6 g/L micrograms per liter 7 µm micrometer(s) 8 Sv/cm microsievert(s) per centimeter 9 /Q atmospheric dispersion factor(s) 10 7Q10 7-day, 10-year low flow (i.e., the lowest flow for 7 consecutive days, 11 expected to occur once per decade) 12 235 U uranium-235 13 ac acre(s) 14 AC alternating current 15 ac-ft acre-feet 16 ACHP Advisory Council on Historic Preservation 17 ACS American Community Survey 18 AD Anno Domini 19 ADAMS Agencywide Documents Access and Management System 20 AECOM AECOM Technical Services Inc.

21 ALARA as low as is reasonably achievable 22 APE area of potential effect 23 ARPA Archaeological Resources Protection Act 24 BA biological assessment 25 BC Before Christ 26 BEIR Biological Effects of Ionizing Radiation 27 bgs below ground surface 28 BMP best management practice 29 BSR biodiversity significance rank 30 BTA barge/traffic area 31 Btu British thermal unit(s) 32 CDC Centers for Disease Control and Prevention 33 CDF core damage frequency 34 CEQ Council on Environmental Quality 35 CERCLA Comprehensive Environmental Response, Compensation, and Liability 36 Act (Superfund) 37 CFR Code of Federal Regulations 38 cfs cubic feet per second 39 CH4 methane 40 Ci curie(s) 41 cm centimeter(s) xxxix

1 CO carbon monoxide 2 CO2 carbon dioxide 3 CO2e CO2 equivalent 4 COL combined construction permit and operating license or combined license 5 COLA combined license application 6 CP construction permit 7 CR Clinch River 8 CRBR Clinch River Breeder Reactor 9 CRBRP Clinch River Breeder Reactor Project 10 CRM Clinch River mile 11 CRN Clinch River Nuclear 12 CWA Clean Water Act (aka Federal Water Pollution Control Act) 13 CWS circulating water system 14 d day 15 D/Q deposition factor(s) 16 DASU data acquisition switch unit 17 dB decibel(s) 18 dBA decibel(s) on the A-weighted scale 19 DBA design basis accident 20 DCD Design Control Document 21 DCG derived concentration guide 22 DNL day-night average sound level 23 DoD U.S. Department of Defense 24 DOE U.S. Department of Energy 25 DOT U.S. Department of Transportation 26 EAB exclusion area boundary 27 EIS environmental impact statement 28 ELF extremely low frequency 29 EMF electromagnetic field 30 EO Executive Order 31 EPA U.S. Environmental Protection Agency 32 EPRI Electric Power Research Institute 33 EPZ Emergency Planning Zone 34 ER Environmental Report 35 ESA Endangered Species Act of 1973, as amended 36 ESP early site permit 37 ESPA early site permit application 38 ESRP Environmental Standard Review Plan (NUREG-1555) 39 ETTP East Tennessee Technology Park 40 FE Federally Endangered 41 fps feet per second xl

1 FR Federal Register 2 ft foot or feet 3 FT Federally Threatened 4 ft2 square foot or feet 5 ft3 cubic foot or feet 6 FTE full-time equivalent employee 7 FWS U.S. Fish and Wildlife Service 8 g gram(s) 9 GAI geographic area of interest 10 gal gallon(s) 11 GBq gigabecquerel 12 GCRP U.S. Global Change Research Program 13 GDNR Georgia Department of Natural Resources 14 GEIS Generic Environmental Impact Statement for License Renewal of Nuclear 15 Plants (NUREG-1437) 16 GEIS-DECOM GEIS-Decommissioning of Nuclear Facilities (NUREG-0586) 17 GHG greenhouse gas 18 GI-LLI gastrointestinal lining of lower intestine 19 gpd gallon(s) per day 20 gpm gallon(s) per minute 21 GWD gigawatt day(s) 22 Gy gray(s) 23 ha hectare(s) 24 HLW high-level waste 25 hr hour(s) 26 Hz hertz 27 IAEA International Atomic Energy Agency 28 IBA Important Bird Area 29 ICRP International Commission on Radiological Protection 30 in. inch(es) 31 IPPP Integrated Pollution Prevention Plan 32 ISFSI independent spent fuel storage installation 33 kg kilogram(s) 34 kHz kilohertz 35 km kilometer(s) 36 km/hr kilometer(s) per hour 37 km2 square kilometer(s) 38 KSNPC Kentucky State Nature Preserves Commission 39 kV kilovolt(s) 40 kW kilowatt(s) 41 kW(e) kilowatt(s) (electrical) xli

1 kWh kilowatt-hour(s) 2 kWp kilowatt peak 3 L liter(s) 4 lb pound(s) 5 Ldn day-night average sound level 6 Leq equivalent continuous sound level 7 LLC Limited Liability Company 8 LLW low-level waste 9 LOCA loss of coolant accident 10 LOI letter of interpretation 11 LOS level of service 12 LPZ low-population zone 13 LULC land use and land cover 14 LWA Limited Work Authorization 15 LWCF Land and Water Conservation Fund 16 LWR light water reactor 17 m meter(s) 18 m/s meter(s) per second 19 m2 square meter(s) 20 m3 cubic meter(s) 21 m3/s cubic meter(s) per second 22 MACCS2 Melcor Accident Consequence Code System Version 1.12 23 MEI maximally exposed individual 24 mg milligram(s) 25 Mgd million gallon(s) per day 26 mGy milligray(s) 27 mi mile(s) 28 mi2 square mile(s) 29 MIMS Manifest Information Management System 30 min minute(s) 31 MKAA Metropolitan Knoxville Airport Authority 32 mL milliliter(s) 33 mm millimeter(s) 34 M million 35 mo month(s) 36 mph mile(s) per hour 37 mrad millirad(s) 38 mrem millirem(s) 39 Mscf thousand standard cubic feet 40 MSL mean sea level 41 mSv millisievert(s) xlii

1 MT metric ton(nes) 2 MTU metric ton(nes) uranium 3 MW megawatt(s) 4 MW(e) megawatt(s) (electrical) 5 MW(t) megawatt(s) (thermal) 6 MWd megawatt-day(s) 7 MWd/MTU megawatt-day(s) per metric ton of uranium 8 MWh megawatt-hour(s) 9 N2O nitrous oxide 10 NA not applicable 11 NAGPRA Native American Graves Protection and Repatriation Act 12 NAVD North American Vertical Datum (sea level reference point used in 13 surveying) 14 NAVD88 North American Vertical Datum of 1988 15 NCRP National Council on Radiation Protection and Measurements 16 NEI Nuclear Electric Institute 17 NEPA National Environmental Policy Act of 1969, as amended 18 NERP National Environmental Research Park 19 NESC National Electric Safety Code 20 NGVD29 National Geodetic Vertical Datum of 1929 21 NHPA National Historic Preservation Act 22 NIEHS National Institute of Environmental Health Sciences 23 NLEB northern long-eared bat 24 NMFS National Marine Fisheries Service 25 NO2 nitrogen dioxide 26 NOx oxides of nitrogen 27 NPDES National Pollutant Discharge Elimination System 28 NRC U.S. Nuclear Regulatory Commission 29 NRHP National Register of Historic Places 30 NSA Naval Support Activity 31 NTU nephelometric turbidity unit(s) 32 NUREG U.S. Nuclear Regulatory Commission technical document 33 NWS National Weather Service 34 O3 ozone 35 OL operating license 36 ORNL Oak Ridge National Laboratory 37 ORR Oak Ridge Reservation 38 OSCS oriented spray cooling system 39 OSHA Occupational Safety and Health Administration 40 PA Programmatic Agreement 41 PAM primary amebic meningoencephalitis xliii

1 Pb lead 2 PCB polychlorinated biphenyl 3 pc/L picocuries per liter 4 PEP Plume Exposure Pathway 5 pH measure of acidity or basicity in solution 6 PIR public interest review 7 PIRF public interest review factor 8 PM particulate matter 9 PM10 particulate matter with a mean aerodynamic diameter of 10 m or less 10 PM2.5 particulate matter with a mean aerodynamic diameter of 2.5 m or less 11 PNNL Pacific Northwest National Laboratory 12 ppb part(s) per billion 13 PPE plant parameter envelope 14 ppm part(s) per million 15 ppt part(s) per thousand 16 PRA probabilistic risk assessment 17 psi pound(s) per square inch 18 rad radiation absorbed dose 19 RCRA Resource Conservation and Recovery Act of 1976, as amended 20 rem Roentgen equivalent man (a unit of radiation dose) 21 REMP radiological environmental monitoring program 22 RG Regulatory Guide 23 RHA Rivers and Harbors Appropriation Act 24 ROI region of interest 25 ROS River Operations Study 26 Ryr reactor-year(s) 27 s or sec second(s) 28 SACTI Seasonal and Annual Cooling Tower Impact (prediction code) 29 SAFSTOR Safe Storage 30 scf standard cubic feet 31 SER safety evaluation report 32 SHPO State Historic Preservation Office 33 SMR small modular reactor 34 SMZ streamside management zone 35 SO2 sulfur dioxide 36 SOARCA State-of-the-Art Reactor Consequence Analysis 37 SOx oxides of sulfur 38 SSAR Site Safety Analysis Report 39 Sv sievert 40 SWPPP stormwater pollution prevention plan 41 SWS service water system xliv

1 T ton(s) 2 TDEC Tennessee Department of Environment and Conservation 3 TDHS Tennessee Department of Human Resources 4 TDS total dissolved solids 5 TEDE total effective dose equivalent 6 THC Tennessee Historical Commission 7 TIA traffic impact analysis 8 TNHP Tennessee Natural Heritage Program 9 TRAGIS Transportation Routing Analysis Geographic Information System 10 TRM Tennessee River Mile 11 TVA Tennessee Valley Authority 12 TWh terawatt-hour(s) 13 TWRA Tennessee Wildlife Resources Agency 14 UPF Uranium Processing Facility 15 U.S. United States 16 UMTRI University of Michigan Transportation Research Institute 17 USACE U.S. Army Corps of Engineers 18 U.S.C. United States Code 19 USCB U.S. Census Bureau 20 USGS U.S. Geological Survey 21 V volt 22 VOC volatile organic compound 23 WBN Watts Bar Nuclear 24 WNS white-nose syndrome 25 Y-12 Y-12 National Security Complex 26 yd yard(s) 27 yd3 cubic yard(s) 28 yr year(s) 29 yr-1 per year 30 xlv

1 APPENDIX A 2 CONTRIBUTORS TO THE ENVIRONMENTAL IMPACT STATEMENT 3 The overall responsibility for the preparation of this environmental impact statement was 4 assigned to the Office of New Reactors, U.S. Nuclear Regulatory Commission. The U.S. Army 5 Corps of Engineers is participating as a cooperating agency. This environmental impact 6 statement was prepared by members of the Office of New Reactors with assistance from other 7 U.S. Nuclear Regulatory Commission organizations, the U.S. Army Corps of Engineers, and 8 Pacific Northwest National Laboratory.

9 Name Affiliation Function or Expertise Nuclear Regulatory Commission Tamsen Dozier Office of New Reactors Environmental Project Manager Patricia Vokoun Office of New Reactors Environmental Project Manager Jack Cushing Office of New Reactors Plant Description; Cumulative Impacts Jennifer Davis Office of New Reactors Historic and Cultural Resources Mohammad Haque Office of New Reactors Hydrology Daniel Barnhurst Office of New Reactors Hydrology Andrew Kugler Office of New Reactors Alternative Sites; Alternative Systems Daniel Mussatti Office of New Reactors Socioeconomics; Environmental Justice; Nonradiological Health; Nonradiological Waste Management Laura Willingham Office of New Reactors Meteorology and Air Quality: Climate Change Kevin Quinlan Office of New Reactors Meteorology and Air Quality Peyton Doub Office of New Reactors Terrestrial Ecology; Aquatic Ecology; Land Use Eva Eckert Hickey Office of New Reactors Radiological Health; Uranium Fuel Cycle; Decommissioning; Donald Palmrose Office of New Reactors Postulated Accidents; Transportation of Radioactive Material Michelle Hart Office of New Reactors Design Basis Accidents U.S. Army Corps of Engineers Mark McIntosh Nashville District Regulatory Specialist, Regulatory Division Casey H. Ehorn Nashville District Chief, East Branch, Regulatory Division Tammy R. Turley Nashville District Chief, Regulatory Division (a)

Pacific Northwest National Laboratory Bruce McDowell Team Lead; Cumulative Impacts Kim Leigh Deputy Team Lead Michael Smith Radiological Health; Uranium Fuel Cycle; Decommissioning Eva Mart Radiological Health; Uranium Fuel Cycle; Postulated Accidents Katie Cort Alternative Sites A-1

Name Affiliation Function or Expertise Dave Anderson Socioeconomics; Environmental Justice; Land Use Rebekah Krieg Aquatic Ecology Ellen Kennedy Historic and Cultural Resources Stephanie Liss Aquatic Ecology Bruce Napier Postulated Accidents Jeremy Rishel Severe Accidents Steven Maheras Transportation Philip Meyer Hydrology; Alternative Systems Marshall Richmond Hydrology Julia Flaherty Meteorology and Air Quality Lance Vail Climate Change Lara Aston Nonradiological Health; Nonradioactive Waste Jim Becker Terrestrial Ecology Nancy Kohn Plant Description Joanne Duncan Cumulative Impacts; References Kris Hand GIS Mapping Susan Loper GIS Mapping Sadie Montgomery GIS Mapping Mike Parker Editor Susan Ennor Editor (a) Pacific Northwest National Laboratory is managed for the U.S. Department of Energy by Battelle Memorial Institute.

A-2

1 APPENDIX B 2 ORGANIZATIONS CONTACTED 3 The following Federal, State, Tribal, regional, and local organizations were contacted during the 4 review of potential environmental impacts from the building and operation of two or more small 5 modular reactors (within the plant parameter envelope described in this environmental impact 6 statement) at the Clinch River Nuclear Site in Roane County, Tennessee:

7 Advisory Council on Historic Preservation, Office of Federal Agency Programs, Washington, 8 D.C.

9 Absentee Shawnee Tribe, Shawnee, Oklahoma 10 Alabama-Coushatta Tribe of Texas, Livingston, Texas 11 Alabama-Quassarte Tribal Town, Wetumka, Oklahoma 12 Alabama Department of Conservation and Natural Resources 13 Auburn University, Auburn, Alabama 14 Anderson County Chamber of Commerce, Clinton, Tennessee 15 Anderson County Economic Development Association, Clinton, Tennessee 16 Anderson County Sheriffs Department, Clinton, Tennessee 17 Cherokee Nation of Oklahoma, Tahlequah, Oklahoma 18 City of Knoxville, Knoxville, Tennessee 19 City of Oak Ridge, Oak Ridge, Tennessee 20 The Chickasaw Nation, Ada, Oklahoma 21 Choctaw Nation of Oklahoma, Durant, Oklahoma 22 Coushatta Tribe of Louisiana, Elton, Louisiana 23 Eastern Band of the Cherokee Indians, Cherokee, North Carolina 24 Eastern Shawnee Tribe of Oklahoma, Wyandotte, Oklahoma 25 Georgia Department of Natural Resources, Social Circle, Georgia 26 Governor of Tennessee, Nashville, Tennessee 27 Huntsville Utilities, Huntsville, Alabama 28 Jena Band of the Choctaw Indians, Jena, Louisiana 29 Kialegee Tribal Town, Wetumka, Oklahoma 30 Kentucky State Nature Preserves Commission, Frankfort, Kentucky 31 Knox County Government, Knoxville, Tennessee 32 Loudon County Economic Development Agency, Loudon, Tennessee 33 Loudon County Government, Loudon, Tennessee 34 Morgan County Government, Wartburg, Tennessee 35 Mississippi Band of Choctaw Indians, Choctaw, Mississippi B-1

1 Muscogee (Creek) Nation of Oklahoma, Okmulgee, Oklahoma 2 Oak Ridge National Laboratory, Oak Ridge, Tennessee 3 Poarch Band of Creek Indians, Atmore, Alabama 4 Quapaw Tribe of Oklahoma, Quapaw, Oklahoma 5 Roane Alliance, Kingston, Tennessee 6 Roane County Government, Kingston, Tennessee 7 Roane County Sherriffs Office, Kingston, Tennessee 8 Seminole Tribe of Florida, Hollywood, Florida 9 Seminole Nation of Oklahoma, Wewoka, Oklahoma 10 Shawnee Tribe of Oklahoma, Miami, Oklahoma 11 Tennessee Department of Environment and Conservation, Nashville, Tennessee 12 Tennessee Department of Environment and Conservation, Knoxville Field Office, Tennessee 13 Tennessee Department of Transportation, Region 1, Knoxville, Tennessee 14 Tennessee Emergency Management Agency, Nashville, Tennessee 15 Tennessee Historical Commission, Nashville, Tennessee 16 Tennessee Housing Development Agency, Knoxville, Tennessee 17 Tennessee Wildlife Resource Agency, Crossville, Tennessee 18 Tennessee Wildlife Resource Agency, Nashville, Tennessee 19 Thlopthlocco Tribal Town, Okemah, Oklahoma 20 Trinity Outreach, Oak Ridge, Tennessee 21 United Keetoowah Band of Cherokee Indians, Tahlequah, Oklahoma 22 United Way of Anderson County, Oak Ridge, Tennessee 23 United Way of Loudon County, Lenoir City, Tennessee 24 United Way of Roane County, Harriman, Tennessee 25 U.S. Department of Energy, Oak Ridge Office of Environmental Management, Oak Ridge, 26 Tennessee 27 U.S. Environmental Protection Agency, Region 4, Atlanta, Georgia 28 U.S. Federal Emergency Management Agency, Atlanta, Georgia 29 U.S. Fish and Wildlife Service, Tennessee Ecological Services Field Office, Cookeville, 30 Tennessee 31 U.S. Fish and Wildlife Service, Alabama Ecological Services Field Office, Daphne, Alabama 32 U.S. House of Representatives, 2nd District, Knoxville Office, Knoxville, Tennessee 33 U.S. House of Representatives, 3rd District, Oak Ridge, Tennessee 34 U.S. Senate, District 15, Oak Ridge, Tennessee B-2

1 University of Tennessee Baker Center for Public Policy, Knoxville, Tennessee 2 Watts Bar Utility District, Harriman, Tennessee B-3

1 APPENDIX C 2 CHRONOLOGY OF NRC AND USACE STAFF ENVIRONMENTAL 3 REVIEW CORRESPONDENCE RELATED TO THE TVA APPLICATION 4 FOR AN EARLY SITE PERMIT (ESP) AT THE CRN SITE 5 This appendix contains a chronological list of correspondence between the U.S. Nuclear 6 Regulatory Commission (NRC) and Tennessee Valley Authority (TVA), and other 7 correspondence related to the NRC staffs environmental review, under Title 10 of the Code of 8 Federal Regulations Part 51, for TVAs application for an early site permit at the Clinch River 9 Nuclear Site. All documents, with the exception of those containing proprietary information, 10 have been placed in the Commissions Public Document Room, at One White Flint North, 11555 11 Rockville Pike (first floor), Rockville, Maryland, and are available electronically from the Public 12 Electronic Reading Room found on the Internet at the following web address:

13 http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRCs 14 Agencywide Document Access and Management Systems (ADAMS), which provides text and 15 image files of the NRCs public documents in the Publicly Available Records component of 16 ADAMS. The ADAMS accession numbers for each document are included below.

17 October 23, 2013 NRC Memorandum: Trip Report Pre-Application Visit to Clinch River 18 Small Modular Reactor Site, Oak Ridge, Tennessee, and Meeting with 19 U.S. Army Corps of Engineers, Nashville District, Eastern Section, in 20 Lenoir City, Tennessee. (Accession No. ML13296A087) 21 March 20, 2015 NRC Memorandum: Summary of Trip to TVAs Clinch River Site on 22 October 7-8, 2014, for a Site Tour and a Review of the Current Status of 23 the Environmental Report for TVAs Early Site Permit Application 24 Submittal. (Package Accession No. ML14329A151).

25 April 30, 2015 Letter to NRC from J.W. Shea, Tennessee Valley Authority (TVA),

26 Regarding Onsite Reference Portal. (Accession No. ML15124A655) 27 July 15, 2015 Letter from the NRC to J.W. Shea, Tennessee Valley Authority (TVA),

28 Regarding the Clinch River Small Modular Reactor Project ESP 29 Application Online Reference Portal. (Accession No. ML15149A397) 30 July 17, 2015 Letter from the NRC to Daniel Stout, TVA, Regarding the Clinch River 31 Early Site Permit Pre-Application Readiness Assessment. (Accession 32 No. ML15190A225) 33 October 26, 2015 NRC Memorandum: Observations from the Environmental Readiness 34 Assessment Activities for a Future Early Site Permit Application for the 35 Clinch River Nuclear Site. (Package Accession No. ML15251A697) 36 May 12, 2016 Letter to NRC from J.W. Shea, TVA, Submitting Application for Early Site 37 Permit for Clinch River Nuclear Site (Rev 0). (Accession No.

38 ML16139A752) 39 May 12, 2016 Early Site Permit Application (Rev 0) for Clinch River Nuclear Site at 40 https://www.nrc.gov/reactors/new-reactors/esp/clinch-41 river.html#application C-1

1 June 10, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 2 Meteorological Data in Support of Early Site Permit Application for 3 Clinch River Nuclear Site. (Accession No. ML16168A212) 4 June 17, 2016 Letter from NRC to J.W. Shea, TVA, Acknowledging Receipt of the Early 5 Site Permit Application For the Clinch River Nuclear Site and Associated 6 Federal Register Notice. (Accession No. ML16153A282) 7 June 23, 2016 Federal Register Notice - NRC Receipt of TVA Early Site Permit 8 Application. (81 FR 40929) 9 June 23, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Calculation Input and 10 Output Files in Support of the Clinch River Nuclear Site Early Site Permit 11 Application. (Accession No. ML16180A307) 12 July 6, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Siting Study in Support 13 of the Clinch River Nuclear Site Early Site Permit Application. (Accession 14 No. ML16188A075) 15 July 28, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Atmospheric Dispersion 16 Calculation Input and Output Files in Support of the Clinch River Nuclear 17 Site Early Site Permit Application. (Accession No. ML16216A109) 18 August 11, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Schedule for Submittals 19 of Supplemental Information. (Accession No. ML16224B143) 20 August 19, 2016 Letter from NRC to J.W. Shea, TVA, Regarding Tennessee Valley 21 Authority Request and Schedule for Submittal of Supplemental 22 Information in Support of Early Site Permit Application for Clinch River 23 Nuclear Site. (Accession No. ML16225A667) 24 August 31, 2016 Notice of Forthcoming Public Meeting with Tennessee Valley Authority to 25 Discuss Various Topics Related to Supplemental Information for the 26 Early Site Permit (ESP) Application for the Clinch River Nuclear Site.

27 (Accession No. ML16252A375) 28 September 15, 2016 Handouts from Public Meeting of Sep 15, 2016: Environmental 29 Alternatives Supplemental Items. (Accession No. ML16252A182) 30 October 27, 2016 Letter from NRC to Daniel Stout Regarding Plan for Document Audit of 31 Tennessee Valley Authoritys Supplemental Information to Support the 32 Early Site Permit Environmental Report. (Accession No. ML16285A388) 33 December 2, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Information on 34 Cumulative Radiological Health Impacts in Support of the Clinch River 35 Nuclear Site Early Site Permit Application. (Accession No.

36 ML16340A259) 37 December 2, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Meteorological 38 Information in Support of the Clinch River Nuclear Site Early Site Permit 39 Application. (Accession No. ML16340A256)

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1 December 8, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Information on Alternate 2 Cooling Water Systems in Support of the Clinch River Nuclear Site Early 3 Site Permit Application. (Accession No. ML16344A061) 4 December 12, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of Cultural 5 Reports and Programmatic Agreement in Support of Early Site Permit 6 Application for Clinch River Nuclear Site. (Package Accession No.

7 ML17284A306) 8 December 13, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Information on 9 Terrestrial Ecology in Support of the Clinch River Nuclear Site Early Site 10 Permit Application. (Accession No. ML16348A552) 11 December 15, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Site Selection 12 Information in Support of the Clinch River Nuclear Site Early Site Permit 13 Application. (Accession No. ML16350A429) 14 December 16, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Aquatic Ecology 15 Information in Support of the Clinch River Nuclear Site Early Site Permit 16 Application. (Accession No. ML16356A485) 17 December 27, 2016 Letter to NRC from J.W. Shea, TVA, Regarding Environmental 18 Protection Plan Information in Support of the Clinch River Nuclear Site 19 Early Site Permit Application. (Accession No. ML16363A378) 20 January 5, 2017 Letter from NRC to J.W. Shea, TVA, Regarding the Acceptance Review 21 Results for an Early Site Permit Application for Clinch River Nuclear Site.

22 (Package Accession No. ML16356A226) 23 January 9, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of Cultural 24 Resource Reports in Support of Early Site Permit Application for Clinch 25 River Nuclear Site. (Package Accession No. ML17298A058) 26 January 12, 2017 Federal Register Notice - Early Site Permit Application; Acceptance for 27 Docketing. (82 FR 3812) 28 February 11, 2017 NRC Memorandum: Summary Report for the Audit Related to the 29 Tennessee Valley Authority's Supplemental Information to Support the 30 Early Site Permit Environmental Report. (Accession No. ML17011A193) 31 February 13, 2017 Email from Allen Fetter to Ray Schiele: Clinch River ESP - Saf.

32 Additional topics for Monday (2/13/17) public meeting. (Accession No.

33 ML17044A265) 34 February 25, 2017 NRC Memorandum: Summary of Meeting Between the US. NRC and 35 TVA to discuss topics associated with Section 2.1, 2.2 and 2.3 in Part 2 36 of the Site Safety Analysis Report of the Tennessee Valley Authority's 37 Early Site Permit Application for the Clinch River Nuclear Site.

38 (Accession No. ML17054D545)

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1 March 1, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of Calculation 2 Input and Output Files in Support of Early Site Permit Application for 3 Clinch River Nuclear Site. (Accession No. ML17065A269) 4 March 10, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of Tribal 5 Consultation Letter in Support of Early Site Permit Application.

6 (Accession No. ML17072A224) 7 March 17, 2017 Letter from NRC to J.W. Shea, TVA, Regarding the Clinch River Nuclear 8 Site Early Site Permit Application Review Schedule. (Accession No.

9 ML17069A104) 10 March 30, 2017 Letter from NRC to Emily Steele, Kingston Public Library, Regarding 11 Maintenance of Reference Materials at the Kingston Public Library 12 Related to the Environmental Review of the Tennessee Valley Authority 13 Early Site Permit Application at the Clinch River Nuclear Site. (Accession 14 No. ML17061A426) 15 March 30, 2017 Letter from NRC to Kathy McNeilly, Oak Ridge Public Library, Regarding 16 Maintenance of Reference Materials at the Oak Ridge Public Library 17 Related to the Environmental Review of the Tennessee Valley Authority 18 Early Site Permit Application at the Clinch River Nuclear Site. (Accession 19 No. ML17061A427) 20 April 4, 2017 Letter from NRC to J.W. Shea, TVA, Regarding Tennessee Valley 21 Authority - Application for an Early Site Permit for the Clinch River 22 Nuclear Site; the Notice of Hearing, Opportunity to Petition for Leave to 23 Intervene, and Associated Federal Register Notice. (Package Accession 24 No. ML17061A396) 25 April 4, 2017 Federal Register Notice - Notice of Hearing and Opportunity to Petition 26 for Leave to Intervene; Order Imposing Procedures. (82 FR 16436) 27 April 7, 2017 Letter from NRC to J.W. Shea, TVA, Regarding Notice of Intent to 28 Prepare an Environmental Impact Statement and Conduct Scoping 29 Related to an Early Site Permit for the Clinch River Nuclear Site.

30 (Package Accession No. ML17068A241) 31 April 12, 2017 Letter from NRC to Tammy Turley, USACE Nashville District, Regarding 32 Invitation to Participate as a Cooperating Agency in Preparation of an 33 Environmental Impact Statement for the Tennessee Valley Authority 34 Early Site Permit Application at the Clinch River Nuclear Site, Roane 35 County, Tennessee. (Accession No. ML17065A237) 36 April 13, 2017 Federal Register Notice - Intent to Prepare Environmental Impact 37 Statement and Conduct Scoping Process; Public Meeting and Request 38 for Comment. (82 FR 17885)

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1 April 17, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 2 Supplemental Information Related to the Exclusion Area Boundary and 3 Population Distribution Around the Clinch River Nuclear Site in Support 4 of the Early Site Permit Application. (Accession No. ML17107A080) 5 April 20, 2017 Letter from NRC to Edwina Butler-Wolfe, Absentee Shawnee Tribe, 6 Regarding Initiation of Section 106 and Scoping Process for the 7 Environmental Review of the Early Site Permit Application for the Clinch 8 River Nuclear Site in Roane County, Tennessee. (Accession No.

9 ML17041A081) 10 April 20, 2017 Letter from NRC to Ryan Morrow, Thlopthlocco Tribal Town, Regarding 11 Initiation of Section 106 and Scoping Process for the Environmental 12 Review of the Early Site Permit Application for the Clinch River Nuclear 13 Site in Roane County, Tennessee. (Accession No. ML17047A682) 14 April 20, 2017 Letter from NRC to Gary Batton, Choctaw Nation of Oklahoma, 15 Regarding Initiation of Section 106 and Scoping Process for the 16 Environmental Review of the Early Site Permit Application for the Clinch 17 River Nuclear Site in Roane County, Tennessee. (Accession No.

18 ML17041A086) 19 April 20, 2017 Letter from NRC to Stephanie A. Bryan, Poarch Band of Creek Indians, 20 Regarding Initiation of Section 106 and Scoping Process for the 21 Environmental Review of the Early Site Permit Application for the Clinch 22 River Nuclear Site in Roane County, Tennessee. (Accession No.

23 ML17047A676) 24 April 20, 2017 Letter from NRC to Jo Ann Battise, Alabama-Coushatta Tribe of Texas, 25 Regarding Initiation of Section 106 and Scoping Process for the 26 Environmental Review of the Early Site Permit Application for the Clinch 27 River Nuclear Site in Roane County, Tennessee. (Accession No.

28 ML17041A082) 29 April 20, 2017 Letter from NRC to Patrick Lambert, Eastern Band of Cherokee Indians 30 of North Carolina, Regarding Initiation of Section 106 and Scoping 31 Process for the Environmental Review of the Early Site Permit 32 Application for the Clinch River Nuclear Site in Roane County, 33 Tennessee. (Accession No. ML17017A123) 34 April 20, 2017 Letter from NRC to Bill John Baker, Cherokee Nation of Oklahoma, 35 Regarding Initiation of Section 106 and Scoping Process for the 36 Environmental Review of the Early Site Permit Application for the Clinch 37 River Nuclear Site in Roane County, Tennessee. (Accession No.

38 ML17041A085) 39 April 20, 2017 Letter from NRC to Tarpie Yargee, Alabama-Quassarte Tribal Town, 40 Regarding Initiation of Section 106 and Scoping Process for the 41 Environmental Review of the Early Site Permit Application for the Clinch 42 River Nuclear Site in Roane County, Tennessee. (Accession No.

43 ML17041A084)

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1 April 20, 2017 Letter from NRC to B. Cheryl Smith, Jena Band of the Choctaw Indians, 2 Regarding Initiation of Section 106 and Scoping Process for the 3 Environmental Review of the Early Site Permit Application for the Clinch 4 River Nuclear Site in Roane County, Tennessee . (Accession No.

5 ML17047A407) 6 April 20, 2017 Letter from NRC to Bill Anoatubby, The Chickasaw Nation, Regarding 7 Initiation of Section 106 and Scoping Process for the Environmental 8 Review of the Early Site Permit Application for the Clinch River Nuclear 9 Site in Roane County, Tennessee. (Accession No. ML17047A681) 10 April 20, 2017 Letter from NRC to John Berrey, Quapaw Tribe of Oklahoma, Regarding 11 Initiation of Section 106 and Scoping Process for the Environmental 12 Review of the Early Site Permit Application for the Clinch River Nuclear 13 Site in Roane County, Tennessee. (Accession No. ML17047A677) 14 April 20, 2017 Letter from NRC to Marcellus W. Osceola, Jr., Seminole Tribe of Florida, 15 Regarding Initiation of Section 106 and Scoping Process for the 16 Environmental Review of the Early Site Permit Application for the Clinch 17 River Nuclear Site in Roane County, Tennessee. (Accession No.

18 ML17047A679) 19 April 20, 2017 Letter from NRC to Joe Bunch, United Keetoowah Band of Cherokee 20 Indians, Regarding Initiation of Section 106 and Scoping Process for the 21 Environmental Review of the Early Site Permit Application for the Clinch 22 River Nuclear Site in Roane County, Tennessee. (Accession No.

23 ML17047A683) 24 April 20, 2017 Letter from NRC to Lovelin Poncho, Coushatta Tribe of Louisiana, 25 Regarding Initiation of Section 106 and Scoping Process for the 26 Environmental Review of the Early Site Permit Application for the Clinch 27 River Nuclear Site in Roane County, Tennessee. (Accession No.

28 ML17047A405) 29 April 20, 2017 Letter from NRC to E. Patrick McIntyre, Jr., Tennessee Historical 30 Commission, Regarding Initiation of Section 106 and Scoping Process 31 for the Environmental Review of the Early Site Permit Application for the 32 Clinch River Nuclear Site in Roane County, Tennessee. (Accession No.

33 ML17061A428) 34 April 20, 2017 Letter from NRC to Phyliss J. Anderson, Mississippi Band Of Choctaw 35 Indians, Regarding Initiation of Section 106 and Scoping Process for the 36 Environmental Review of the Early Site Permit Application for the Clinch 37 River Nuclear Site in Roane County, Tennessee. (Accession No.

38 ML17047A409) 39 April 20, 2017 Letter from NRC to Mary Jennings, U.S. Fish and Wildlife Service, 40 Regarding Request For Participation In The Environmental Scoping 41 Process And A List Of Protected Species Within The Area Under 42 Evaluation For The Proposed Clinch River Nuclear Site Early Site Permit 43 Application. (Accession No. ML17069A249)

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1 April 20, 2017 Letter from NRC to James Floyd, Muscogee (Creek) Nation of 2 Oklahoma, Regarding Initiation of Section 106 and Scoping Process for 3 the Environmental Review of the Early Site Permit Application for the 4 Clinch River Nuclear Site in Roane County, Tennessee. (Accession No.

5 ML17047A675) 6 April 20, 2017 Letter from NRC to Leonard M. Harjo, Seminole Nation of Oklahoma, 7 Regarding Initiation of Section 106 and Scoping Process for the 8 Environmental Review of the Early Site Permit Application for the Clinch 9 River Nuclear Site in Roane County, Tennessee . (Accession No.

10 ML17047A678) 11 April 20, 2017 Letter from NRC to Glenna J. Wallace, Eastern Shawnee Tribe of 12 Oklahoma, Regarding Initiation of Section 106 and Scoping Process for 13 the Environmental Review of the Early Site Permit Application for the 14 Clinch River Nuclear Site in Roane County, Tennessee. (Accession No.

15 ML17047A406) 16 April 20, 2017 Letter from NRC to Ron Sparkman, Shawnee Tribe of Oklahoma, 17 Regarding Initiation of Section 106 and Scoping Process for the 18 Environmental Review of the Early Site Permit Application for the Clinch 19 River Nuclear Site in Roane County, Tennessee. (Accession No.

20 ML17047A680) 21 April 20, 2017 Letter from NRC to Bill Pearson, U.S. Fish and Wildlife Service, 22 Regarding Request For Participation In The Environmental Scoping 23 Process And A List Of Protected Species Within The Area Under 24 Evaluation For The Proposed Clinch River Early Site Permit Application 25 Review. (Accession No. ML17088A264) 26 April 20, 2017 Letter from NRC to Reid Nelson, Advisory Council on Historic 27 Preservation, Regarding Initiation of Section 106 and Scoping Process 28 for the Environmental Review of the Early Site Permit Application for the 29 Clinch River Nuclear Site in Roane County, Tennessee. (Accession No.

30 ML17065A239) 31 April 20, 2017 Letter from NRC to Jeremiah Hobia, Kialegee Tribal Town, Regarding 32 Initiation of Section 106 and Scoping Process for the Environmental 33 Review of the Early Site Permit Application for the Clinch River Nuclear 34 Site in Roane County, Tennessee. (Accession No. ML17047A408) 35 April 21, 2017 Letter to NRC from Mary Jennings, U.S. Fish and Wildlife Service, 36 Regarding FWS#2017-CPA-0711. Notice of Intent for the Nuclear 37 Regulatory Commission to Prepare an Environmental Impact Statement 38 and Conduct a Scoping Process for the Clinch River Nuclear Site 39 Located in Roane County, Tennessee. (Accession No. ML17145A505) 40 April 28, 2017 Notice of Public Meeting to Discuss the Environmental Scoping Process 41 for the Clinch River Nuclear Site Early Site Permit Application.

42 (Accession No. ML17118A330)

C-7

1 May 2, 2017 Letter from Tammy Turley, USACE Nashville District, to NRC, regarding 2 Invitation to Participate as a Cooperating Agency in Preparation of an 3 Environmental Impact Statement for the Tennessee Valley Authority 4 Early Site Permit Application at the Clinch River Nuclear Site, Roane 5 County, Tennessee. (Accession No. ML17205A413) 6 May 5, 2017 Letter to NRC from Mary Jennings, U.S. Fish and Wildlife Service, 7 Regarding FWS# 2017-I-0473. U.S. Nuclear Regulatory Commission -

8 Requests for Participation in the Environmental Scoping Process and 9 List of Federally Protected Species Within the Area Under Evaluation for 10 the Proposed Clinch River Nuclear Site Located in Oak Ridge, Roane 11 County, Tennessee. (Accession No. ML17205A341) 12 May 7, 2017 Plan for Environmental Audit Related to the Clinch River Nuclear Site 13 Early Site Permit Application. (Accession No. ML17088A728) 14 May 12, 2017 Letter to NRC from Elizabeth Toombs, Cherokee Nation, Regarding 15 Clinch River Nuclear Site, Roane County, TN - Cherokee Nation Section 16 106. (Accession No. ML17145A580) 17 May 30, 2017 Letter to NRC from Larry Long, U.S. Environmental Protection Agency, 18 Regarding Informal Pre-permit Clinch River Nuclear Site. (Accession 19 No. ML17157B742) 20 June 5, 2017 Letter to NRC from Daniel Rangle, Choctaw Nation of Oklahoma, 21 Regarding Initiation of Section 106 and Scoping Process for the 22 Environmental Review of the Early Site Permit Application for Clinch 23 River Nuclear Site in Roane County, Tennessee. (Accession No.

24 ML17157B749) 25 June 7, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 26 Supplemental Information Related to the Hydrologic Engineering in 27 Support of the Clinch River Nuclear Site Early Site Permit Application -

28 Groundwater. (Accession No. ML17158B342) 29 June 12, 2017 Letter to NRC from Kendra Abkowitz, Tennessee Department of 30 Environment and Conservation, Regarding TDEC NEPA 31 Review/Comments Complete. (Accession No. ML17170A310) 32 June 15, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 33 Supplemental Information Regarding the Impacts of Non-Radiological 34 Traffic Accidents in Support of the Early Site Permit Application for 35 Clinch River Nuclear Site. (Accession No. ML17167A155) 36 June 28, 2017 Letter to NRC from Karen Pritchett, United Keetoowah Band of 37 Cherokee Indians, Regarding Clinch River Nuclear Site, Roane County, 38 Tennessee. (Accession No. ML17206A450) 39 June 20, 2017 NRC Memorandum: Summary of Public Scoping Meeting Related To 40 The Early Site Permit Application Review Of The Clinch River Nuclear 41 Site. (Package Accession No. ML17163A352)

C-8

1 June 26, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 2 Supplemental Information Related to Plant Parameter Envelope Source 3 Terms in Support of Early Site Permit Application for Clinch River 4 Nuclear Site. (Accession No. ML17178A330) 5 July 7, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 6 Supplemental Information Related to the Environmental Audit in Support 7 of Early Site Permit Application for Clinch River Nuclear Site. (Accession 8 No. ML17206A091) 9 July 18, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 10 Supplemental Information Related to the Environmental Audit in Support 11 of Early Site Permit Application for Clinch River Nuclear Site. (Accession 12 No. ML17200C887) 13 July 20, 2017 Letter from NRC to Mary Jennings, U.S. Fish and Wildlife Service, 14 Regarding FWS# 2017-I-0473. U.S. Nuclear Regulatory Commission 15 (NRC) - Updated List of Federally Threatened and Endangered Species 16 that Potentially Occur near the Proposed Clinch River Small Modular 17 Nuclear Reactor Facility in Oak Ridge, Roane County, Tennessee.

18 (Accession No. ML17205A342) 19 August 1, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 20 Supplemental Information Related to the Environmental Audit in Support 21 of Early Site Permit Application for Clinch River Nuclear Site. (Package 22 Accession No. ML17234A002) 23 August 14, 2017 NRC Memorandum: Meeting between the U.S. Nuclear Regulatory 24 Commission and Tennessee Valley Authority to Discuss Topics 25 Associated With TVA's Early Site Permit Application for the Clinch River 26 Nuclear Site [Application Figures and Graphic Information System files].

27 (Accession No. ML18010A258) 28 August 21, 2017 Email from Mike Barbour, Auburn University, to James Becker, PNNL, 29 Regarding Map Package for AL NHP. (Package Accession No.

30 ML18022A463).

31 August 21, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 32 Supplemental Information Related to the Environmental Audit in Support 33 of Early Site Permit Application for Clinch River Nuclear Site. (Accession 34 No. ML17233A298) 35 August 25, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Supplemental 36 Information Related to Groundwater Hydrology in Support of Early Site 37 Permit Application for Clinch River Nuclear Site. (Accession No.

38 ML17237C084) 39 August 30, 2017 Meeting between the U.S. Nuclear Regulatory Commission (NRC) and 40 Tennessee Valley Authority (TVA) to Discuss Topics Associated With 41 TVA's Early Site Permit Application for the Clinch River Nuclear Site 42 [Cultural Resources and Transportation]. (Accession No. ML17352A028)

C-9

1 September 5, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Supplemental 2 Information Related to Environmental Report Figures in Support of Early 3 Site Permit Application for Clinch River Nuclear Site. (Accession No.

4 ML18010A067) 5 September 6, 2017 Email from Pat Black, Tennessee Wildlife Resource Agency, to James 6 Becker, PNNL, Regarding Watts Bar Reservoir Creel Survey Report.

7 (Package Accession No. ML18022A346).

8 September 6, 2017 Email from Gerry Middleton, Tennessee Department of Environment and 9 Conservation, to James Becker, PNNL, Regarding Bat Data Report 10 2013, 2014, and 2015. (Package Accession No. ML18019A036) 11 September 11, 2017 Email from Stephanie Williams, Tennessee Department of Environment 12 and Conservation, to James Becker, PNNL, Regarding Map Package for 13 TN NHP. (Package Accession No. ML18026A552) 14 September 13, 2017 Email from James Becker, PNNL, to Ian Horn, Kentucky State Nature 15 Preserves Commission, Regarding KY NHP Review of Transmission 16 Line Segment for Clinch River SMR ESP Project in Tennessee.

17 (Accession No. ML18059A130) 18 September 15, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Response to Request for 19 Additional Information Related to the Evacuation Time Estimates in 20 Support of Early Site Permit Application for Clinch River Nuclear Site.

21 (Accession No. ML17261A066) 22 September 18, 2017 Email from Kitty McCracken, Oak Ridge National Laboratory, to James 23 Becker, PNNL, Regarding Fish Data for Ish Creek, Oak Ridge, 24 Tennessee. (Package Accession No. ML18016A334) 25 September 24, 2017 Email from Anna Yellin, Georgia Department of Natural Resources, to 26 James Becker, PNNL, Regarding the Environmental Review. (Package 27 Accession No. ML18012A447) 28 October 2, 2017 Email from Ian Horn, Kentucky State Nature Preserves Commission, to 29 James Becker, PNNL, Regarding KY NHP Review of Transmission Line 30 Segment for Clinch River SMR ESP Project in Tennessee. (Package 31 Accession No. ML18012A656) 32 October 10, 2017 Letter to NRC, from J.W. Shea, TVA, Regarding Submittal of 33 Supplemental Information Related to Groundwater Hydrology in Support 34 of Early Site Permit Application for Clinch River Nuclear Site. (Accession 35 No. ML17286A615) 36 October 26, 2017 Environmental Impact Statement Scoping Process Summary Report 37 Clinch River Nuclear Site Early Site Permit Application. (Package 38 Accession No. ML17242A061)

C-10

1 November 3, 2017 Email from Brian Flock, Tennessee Wildlife Resource Agency, to James 2 Becker, PNNL, Regarding Clinch River Small Modular Reactor Project- 2 3 Figures. (Accession No. ML18064A895) 4 November 8, 2017 Email from Neil Giffen, Oak Ridge National Laboratory, to James Becker, 5 PNNL, Regarding Questions About a Former Area of Very High 6 Biological Significance on the Clinch River Site. (Package Accession 7 No. ML18022A742) 8 November 13, 2017 Meeting between the U.S. Nuclear Regulatory Commission (NRC) and 9 Tennessee Valley Authority (TVA) to Discuss Topics Associated With 10 TVA's Early Site Permit Application for the Clinch River Nuclear Site [ER 11 References and Site Safety Hydrology]. (Accession No. ML18010A322) 12 November 17, 2017 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 13 Environmental Report References in Support of Early Site Permit 14 Application for Clinch River Nuclear Site. (Accession No. ML17334A038) 15 December 7, 2017 Email from Neil Giffen, Oak Ridge National Laboratory, to James Becker, 16 PNNL, Regarding Question About a Former Area of "Very High 17 Biological Significance" on the Clinch River Site. (Accession No.

18 ML18010A883).

19 December 15, 2017 Letter to NRC from J.W. Shea, TVA, Submitting Application for Early Site 20 Permit for Clinch River Nuclear Site (Rev 1). (Accession No.

21 ML18005A067) 22 December 15, 2017 Early Site Permit Application for Clinch River Nuclear Site at 23 https://www.nrc.gov/reactors/new-reactors/esp/clinch-24 river.html#application 25 January 11, 2018 NRC Memorandum: Summary Report for the Full Scope Environmental 26 Audit for the Clinch River Nuclear Site Early Site Permit Application.

27 (Package Accession No. ML17226A020) 28 January 19, 2018 Email from NRC, to Theodore Isham, Seminole Nation of Oklahoma, 29 Regarding Early Site Permit Application for the Clinch River Nuclear Site 30 in Roane County, Tennessee. (Package Accession No. ML18031A950) 31 January 19, 2018 Email from NRC, to Samantha Robison, Alabama-Quassarte Tribal 32 Town, Regarding Early Site Permit Application for the Clinch River 33 Nuclear Site in Roane County, Tennessee. (Accession No.

34 ML18046A410) 35 January 19, 2018 Email from NRC, to Bryant Celestine, Alabama-Coushatta Tribe of 36 Texas, Regarding Early Site Permit Application for the Clinch River 37 Nuclear Site in Roane County, Tennessee. (Package Accession No.

38 ML18058B560)

C-11

1 January 20, 2018 Email from Theodore Isham, Seminole Nation of Oklahoma, to NRC, 2 Regarding Early Site Permit Application for the Clinch River Nuclear Site 3 in Roane County, Tennessee. (Accession No. ML18046A412) 4 January 22, 2018 Email from Karen Brunso, The Chickasaw Nation, to NRC, Regarding 5 Early Site Permit Application for the Clinch River Nuclear Site in Roane 6 County, Tennessee. (Accession No. ML18031A976) 7 January 22, 2018 Email from NRC, to Victoria Menchaca, Seminole Tribe of Florida, 8 Regarding Early Site Permit Application for the Clinch River Nuclear Site 9 in Roane County, Tennessee. (Accession No. ML18059A157) 10 January 22, 2018 Letter to NRC from J.W. Shea, TVA, Submitting Responses to Request 11 for Additional Information Related to Emergency Planning Exemption 12 Requests in Support of Early Site Permit Application for Clinch River 13 Nuclear Site. (Accession No. ML18022A917) 14 January 25, 2018 Letter to NRC from J.W. Shea, TVA, Regarding Submittal of 15 Environmental Report References in Support of Early Site Permit 16 Application for Clinch River Nuclear Site. (Accession No. ML18036A346) 17 January 29, 2018 Email from NRC, to Terry Clouthier, Thlopthlocco Tribal Town, 18 Regarding Early Site Permit Application for the Clinch River Nuclear Site 19 in Roane County, Tennessee. (Accession No. ML18040A439) 20 February 9, 2018 Email from NRC, to Daniel Ragle, Choctaw Nation of Oklahoma, 21 Regarding Clinch River Nuclear Site, Early Site Permit Application, 22 Environmental Audit Summary Report. (Accession No. ML18044A843) 23 February 16, 2018 Email from NRC, to Carolyn White, Poarch Band of Creek Indians, 24 Regarding Early Site Permit Application for the Clinch River Nuclear Site 25 in Roane County, Tennessee. (Accession No. ML18051A746) 26 February 19, 2018 Letter to NRC, from Terry Clothier, Thlopthlocco Tribal Town, Regarding 27 Early Site Permit Application for the Clinch River Nuclear Site in Roane 28 County, Tennessee. (Accession No. ML18051A738) 29 March 5, 2018 Email from NRC, to Theodore Isham, Seminole Nation of Oklahoma, 30 Regarding Early Site Permit Application for the Clinch River Nuclear Site 31 in Roane County, Tennessee. (Accession No. ML18064A222)

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1 APPENDIX D 2 SCOPING COMMENTS AND RESPONSES 3 On April 13, 2017, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of Intent 4 to Prepare an Environmental Impact Statement and Conduct Scoping Process in the Federal 5 Register (82 FR 17885 2017-TN4910). The Notice of Intent notified the public of the staffs 6 intent to prepare an environmental impact statement (EIS) and conduct scoping for an 7 application received from Tennessee Valley Authority (TVA) for an Early Site Permit (ESP) for 8 the Clinch River Nuclear (CRN) Site. The CRN Site is located in Roane County in eastern 9 Tennessee.

10 This EIS has been prepared in accordance with provisions of the National Environmental Policy 11 Act of 1969 (NEPA) (42 U.S.C. § 4321 et seq.-TN661), Council on Environmental Quality 12 guidelines, and Title 10 of the Code of Federal Regulations (CFR) Parts 51 and 52 (TN250 and 13 TN251, respectively). As outlined by NEPA, the NRC initiated the scoping process with the 14 issuance of the Federal Register Notice. The NRC invited the applicant; Federal, Tribal, State, 15 and local government agencies; local organizations; and individuals to participate in the scoping 16 process by providing oral comments at the scheduled public meeting and/or by submitting 17 written suggestions and comments no later than June 12, 2017.

18 D.1 Overview of the Scoping Process 19 The scoping process provides an opportunity for public participation to identify issues to be 20 addressed in the EIS and to highlight public concerns and issues. The Notice of Intent identified 21 the following objectives of the scoping process.

22 Define the proposed action that is to be the subject of the EIS.

23 Determine the scope of the EIS and identify significant issues to be analyzed in depth.

24 Identify and eliminate from detailed study those issues that are peripheral or that are not 25 significant.

26 Identify any environmental assessments and other EISs that are being prepared or will be 27 prepared that are related to, but not part of, the scope of the EIS being considered.

28 Identify other environmental review and consultation requirements related to the proposed 29 action.

30 Identify parties consulting with the NRC under the National Historic Preservation Act 31 (NHPA), as set forth in 36 CFR 800.8(c)(1)(i) (TN513).

32 Indicate the relationship between the timing of the preparation of the environmental 33 analyses and the NRCs tentative planning and decision-making schedule.

34 Identify any cooperating agencies and, as appropriate, allocate assignments for preparation 35 and schedules for completing the EIS to the NRC and any cooperating agencies.

36 Describe how the EIS will be prepared and identify any contractor assistance to be used.

37 Two public scoping meetings were held at the Pollard Technology Conference Center 38 Auditorium, at 210 Badger Avenue, in Oak Ridge, Tennessee, on May 15, 2017; meetings 39 took place at 1:00 p.m. and 6:00 p.m. The NRC announced the meetings in local and regional 40 newspapers (The Oak Ridger, Roane County News, Knoxville Sentinel, and The 41 Roane Reader) and issued press releases locally. Each scoping meeting began with prepared 42 statements from NRC staff members providing a brief overview of the ESP application D-1

1 review process and the NEPA process. After the NRCs prepared statements, the meetings 2 were opened for public comments.

3 Twelve afternoon scoping meeting attendees and seven evening scoping meeting attendees 4 provided oral comments that were recorded and transcribed by a certified court reporter. Two 5 written statements were received during the meeting. In addition to the oral and written 6 statements provided at the public scoping meeting, a total of 74 pieces of correspondence were 7 received during the scoping period. The scoping period ran from April 13, 2017 to June 12, 2017.

8 Transcripts for both afternoon and evening scoping meetings can be found in the NRCs 9 Agencywide Documents Access and Management System (ADAMS) under accession numbers 10 ML17151A407 and ML17151A408, respectively. A scoping meeting summary memorandum 11 (ML17157B585) was issued on June 20, 2017.

12 At the conclusion of the scoping period, the NRC staff and its contractor, Pacific Northwest 13 National Laboratory, reviewed the scoping meeting transcripts, as well as all written material 14 received, and identified individual comments. These comments were organized according to 15 topic within the proposed EIS or according to the general topic if outside the scope of the EIS.

16 After comments were grouped according to subject area, the NRC staff prepared responses to 17 the comments, identifying which were within the scope of the EIS.

18 Table D-1 identifies in alphabetical order the individuals who provided comments during the 19 scoping period, their affiliations (if given), and the ADAMS accession number that can be used 20 to locate their correspondence. Table D-2 lists the comment categories in alphabetical order 21 and the commenter names and numbers for comments for each category. The balance of this 22 appendix presents the comments and NRC staff responses organized by topic category.

23 Table D-1. Individuals Providing Comments during the Comment Period Comment Source and Correspondence Commenter Affiliation (if stated) Document ID ID Abkowitz, Tennessee Department of Email (ML17170A310) 0043 Kendra Environment and Conservation Almond, Jake Meeting Transcript 0001-8 (ML17151A407)

Anderson, KC Email (ML17163A439) 0039 Anonymous Letter (ML17145A549) 0035 Anonymous Letter (ML17158B348) 0036 Anonymous Letter (ML17180A317) 0059 Anonymous reg.gov (ML17163A077) 0047 Anthony, Kate reg.gov (ML17164A179) 0051 Bates, Renee Letter (ML17157B347) 0034 Beach, Tom Meeting Transcript 0002-1 (ML17151A408)

Boles, Dustin U.S. Fish and Wildlife Service Email (ML17145A505) 0003 Bothwell, Cecil Email (ML17145A542) 0008 Bryant, Harry Email (ML17206A449) 0060 Burger, Carol reg.gov (ML17163A081) 0050 24 D-2

Table D-1. (contd)

Comment Source and Correspondence Commenter Affiliation (if stated) Document ID ID Campbell, Jim East Tennessee Economic Council reg.gov (ML17166A207) 0053 Carter, Pat Email (ML17157B743) 0027 Carter, Rick Email (ML17157B745) 0028 Chinn, Jr., Rick City of Oak Ridge Email (ML17163A440) 0040 Chinn, Jr., Rick City of Oak Ridge Email (ML17180A318) 0040 Colclasure, Doug Email (ML17163A442) 0042 Colton, Kara Energy Communities Alliance Email (ML17163A441) 0041 Cremer, Claudine reg.gov (ML17163A080) 0049 Cumberland, Meeting Transcript 0002-3 Margaret (ML17151A408)

Curran, Diane Southern Alliance for Clean Energy Email (ML17166A206) 0052 DiMaria, Pamela Email (ML17163A438) 0038 Ellis, Daniel Email (ML17145A551) 0010 Emert, Steven Anderson County Board of Letter (ML17177A090) 0058 Commissioners Flagg, Tom Email (ML17145A554) 0011 Frank, Terry Anderson County Mayor Letter (ML17151A788) 0062 Franklin, Doug Hands On, Carpentry and Solar reg.gov (ML17132A171) 0017 Gilmartin, Gary Meeting Transcript 0001-2 (ML17151A407)

Goins, Joe reg.gov (ML17163A086) 0056 Goss, Sandra Tennessee Citizens for Wilderness reg.gov (ML17166A208) 0054 Planning Griffin, Tim Energy, Technology and Meeting Transcript 0001-9 Environmental Business (ML17151A407)

Association Grimes, Patricia Email (ML1715B722) 0023 Hardy, Parker Oak Ridge Chamber of Commerce Meeting Transcript 0001-3 (ML17151A407)

Harland, Donald reg.gov (ML17142A302) 0021 Hickman, Beth City of Oak Ridge Email (ML17163A440) 0040 Hickman, Beth City of Oak Ridge Email (ML17180A318) 0040 Holt, Cathy Email (ML17145A565) 0014 Humphries, Oak Ridge Chamber of Commerce Email (ML17158C137) 0037 Leigha Hyche, Kenneth reg.gov (ML17163A078) 0048 Jennings, Mary U.S. Fish and Wildlife Service Letter (ML17205A341) 0063 Johnston, Susan reg.gov (ML17163A076) 0046 D-3

Table D-1. (contd)

Comment Source and Correspondence Commenter Affiliation (if stated) Document ID ID Jones, Sid Email (ML17157B748) 0031 Jordan, Ben Meeting Transcript 0001-1 (ML17151A407)

Kirkman, Arden Email (ML17157B741) 0025 Kohlhorst, Darrel Meeting Transcript 0001-7 (ML17151A407)

Krushenski, City of Oak Ridge Email (ML17163A440) 0040 Kenneth Krushenski, City of Oak Ridge Email (ML17180A318) 0040 Kenneth Kurtz, Sandy Meeting Transcript 0002-2 (ML17151A408)

LeQuire, Alan reg.gov (ML17163A085) 0044 Lloyd, AA Email (ML17138A296) 0020 Long, Larry EPA Region 4 Email (ML17157B742) 0026 Lyle, Marcia Email (ML17157B750) 0033 Martin, Rodger Meeting Transcript 0002-6 (ML17151A408)

McBride, Geoff Email (ML17145A560) 0005 McBride, Linda Email (ML17145A557) 0005 McClendon, Linda Email (ML17145A507) 0004 McClendon, Linda Email (ML17157B746) 0029 McCoy, Lawrence Email (ML17164A178) 0038 McFadden, Nancy Email (ML17145A539) 0007 Michlink, Doug Container Technologies Meeting Transcript 0001-6 (ML17151A407)

Mortenson, Julia reg.gov (ML17163A074) 0045 Naegeli, Wolf Foundation for Global Meeting Transcript 0001-11 Sustainability (ML17151A407)

Oehler, Susan Email (ML17145A549) 0009 Packan, Nicolas Email (ML17057B740) 0024 Paddock, Brian Meeting Transcript 0002-4 (ML17151A408)

Pittillo, Dan Email (ML17145A567) 0015 Powell, Michelle Southern Alliance for Clean Energy Meeting Transcript 0001-4 (ML17151A407)

Prins, Claire reg.gov (ML17142A304) 0022 D-4

Table D-1. (contd)

Comment Source and Correspondence Commenter Affiliation (if stated) Document ID ID Pritchett, Karen United Keetoowah Band of Email (ML17206A450) 0061 Cherokee Indians Pusey, Caleb reg.gov (ML17163A073) 0044 Rangle, Daniel Choctaw Nation of Oklahoma Email (ML17157B749) 0032 Robertson, Grace reg.gov (ML17136A204) 0018 Safer, Don Tennessee Environmental Council Meeting Transcript 0001-5 (ML17151A407)

Salzman, Alicia Letter (ML17157B750) 0057 Sauer, Robert Email (ML17145A559) 0012 Skutnik, Steve Meeting Transcript 0001-10 (ML17151A407)

Skutnik, Steve Meeting Transcript 0002-5 (ML17151A408)

Smith, Brian reg.gov (ML17138A295) 0019 Spencer, Martha reg.gov (ML17163A084) 0044 Sprignoli, Damon Email (ML17145A545) 0005 Sutlock, Dot Email (ML17145A537) 0006 Sweeton, Beverly Email (ML17157B747) 0030 Toombs, Cherokee Nation Email (ML17145A580) 0016 Elizabeth Turk, Lawrence Email (ML17145A535) 0005 "Butch" Turk, Lawrence reg.gov (ML17163A082) 0044 "Butch" Wallace, Beth Email (ML17163A075) 0038 Wunderlich, Walt Email (ML17145A564) 0013 Zeller, Lou Blue Ridge Environmental Defense Meeting Transcript 0001-12 League (ML17151A407)

Zeller, Lou Blue Ridge Environmental Defense Meeting Transcript 0002-7 League (ML17151A408)

Zeller, Lou Blue Ridge Environmental Defense reg.gov (ML17151A409) 0055 League Zeller, Lou Blue Ridge Environmental Defense reg.gov (ML17166A379) 0055 League D-5

1 Table D-2. Comment Categories with Associated Commenters and Comment IDs Comment Category Commenter (Comment ID)

Accidents - Severe Curran, Diane (0052-1) (0052-3) (0052-4) (0052-5) (0052-7)

(0052-8) (0052-9)

Martin, Rodger (0002-6-5)

Safer, Don (0001-5-7)

Alternatives - Energy Bates, Renee (0034-1)

Curran, Diane (0052-2) (0052-6) (0052-10) (0052-13) (0052-14)

(0052-15) (0052-16) (0052-17) (0052-18)

Ellis, Daniel (0010-2)

Goins, Joe (0056-2)

Harland, Donald (0021-2)

Johnston, Susan (0046-1)

Kirkman, Arden (0025-4)

McBride, Geoff (0005-2) (0005-6)

McBride, Linda (0005-2) (0005-6)

McFadden, Nancy (0007-2) (0007-4)

Mortenson, Julia (0045-1)

Naegeli, Wolf (0001-11-1)

Powell, Michelle (0001-4-5)

Safer, Don (0001-5-3)

Sprignoli, Damon (0005-2) (0005-6)

Sweeton, Beverly (0030-1)

Turk, Lawrence "Butch" (0005-2) (0005-6)

Wunderlich, Walt (0013-4) (0013-5)

Zeller, Lou (0001-12-2) (0055-1)

Alternatives - No-Action Curran, Diane (0052-19)

Kurtz, Sandy (0002-2-14)

Skutnik, Steve (0001-10-5) (0002-5-4)

Alternatives - Sites Colclasure, Doug (0042-1)

Wunderlich, Walt (0013-1) (0013-2)

Benefit - Cost Balance Anonymous, Anonymous (0059-4)

Anthony, Kate (0051-3) (0051-9)

Powell, Michelle (0001-4-2)

Safer, Don (0001-5-2) (0001-5-4)

Ecology - Aquatic Kurtz, Sandy (0002-2-3)

Naegeli, Wolf (0001-11-3)

Safer, Don (0001-5-11)

Ecology - Terrestrial Boles, Dustin (0003-1) (0003-2) (0003-3) (0003-4) (0003-5) (0003-6)

(0003-7)

Cumberland, Margaret (0002-3-1)

Jennings, Mary (0063-1)

Kurtz, Sandy (0002-2-5) (0002-2-6)

Naegeli, Wolf (0001-11-2)

Geology Safer, Don (0001-5-8)

Health - Nonradiological Abkowitz, Kendra (0043-9)

Almond, Jake (0001-8-1) 2 D-6

Table D-2. (contd)

Comment Category Commenter (Comment ID)

Health - Radiological Holt, Cathy (0014-3)

Kurtz, Sandy (0002-2-12) (0002-2-13)

Martin, Rodger (0002-6-1)

Paddock, Brian (0002-4-8)

Pittillo, Dan (0015-1)

Skutnik, Steve (0001-10-3)

Historic and Cultural Abkowitz, Kendra (0043-11)

Resources Pritchett, Karen (0061-1)

Rangle, Daniel (0032-1)

Toombs, Elizabeth (0016-1)

Hydrology - Groundwater Abkowitz, Kendra (0043-4)

Jones, Sid (0031-2)

Kurtz, Sandy (0002-2-2)

Paddock, Brian (0002-4-9)

Skutnik, Steve (0002-5-1)

Hydrology - Surface Water Abkowitz, Kendra (0043-2) (0043-3)

Anonymous, Anonymous (0059-3)

Anthony, Kate (0051-5) (0051-11)

Goss, Sandra (0054-2)

Grimes, Patricia (0023-2)

Kirkman, Arden (0025-3)

Kurtz, Sandy (0002-2-4) (0002-2-7) (0002-2-9)

Martin, Rodger (0002-6-2)

Skutnik, Steve (0001-10-2) (0002-5-2)

Land Use - Site and Vicinity Goss, Sandra (0054-1)

Meteorology and Air Quality Abkowitz, Kendra (0043-7) (0043-8) (0043-10)

Kurtz, Sandy (0002-2-8)

Need for Power Anthony, Kate (0051-6) (0051-12)

Powell, Michelle (0001-4-3)

Safer, Don (0001-5-6)

Nonradiological Waste Abkowitz, Kendra (0043-5) (0043-6)

Process - ESP Kohlhorst, Darrel (0001-7-1)

Safer, Don (0001-5-5)

Zeller, Lou (0055-2)

Process - NEPA Abkowitz, Kendra (0043-1) (0043-12)

Curran, Diane (0052-11) (0052-12)

Long, Larry (0026-1) (0026-2) (0026-4)

Paddock, Brian (0002-4-6)

Skutnik, Steve (0002-5-3)

Site Layout and Design Anonymous, Anonymous (0059-2)

Kurtz, Sandy (0002-2-10)

Paddock, Brian (0002-4-1) (0002-4-3) (0002-4-4) (0002-4-5)

Powell, Michelle (0001-4-4)

Wunderlich, Walt (0013-3)

Socioeconomics Almond, Jake (0001-8-2)

Kohlhorst, Darrel (0001-7-2)

Naegeli, Wolf (0001-11-4)

Uranium Fuel Cycle Harland, Donald (0021-4)

D-7

Table D-2. (contd)

Comment Category Commenter (Comment ID)

Holt, Cathy (0014-2)

Hyche, Kenneth (0048-1)

Jones, Sid (0031-1)

Kirkman, Arden (0025-2)

Long, Larry (0026-3)

McBride, Geoff (0005-3) (0005-7)

McBride, Linda (0005-3) (0005-7)

McFadden, Nancy (0007-3)

Safer, Don (0001-5-10)

Sprignoli, Damon (0005-3) (0005-7)

Sutlock, Dot (0006-2)

Turk, Lawrence "Butch" (0005-3) (0005-7) 1 D.2 In-Scope Comments and Responses 2 The in-scope comment categories are listed alphabetically in Table D-3 in the order that they 3 are presented in this EIS. In-scope comments and responses are included below the table.

4 Parenthetical numbers shown after each comment refer to the Comment Identification (ID) 5 number (document number-comment number) and the commenter name.

6 Table D-3. Comment Categories in Order as Presented in this Report D.2.1 Comments Concerning Process - ESP D.2.2 Comments Concerning Process - NEPA D.2.3 Comments Concerning Site Layout and Design D.2.4 Comments Concerning Land Use - Site and Vicinity D.2.5 Comments Concerning Geology D.2.6 Comments Concerning Hydrology - Surface Water D.2.7 Comments Concerning Hydrology - Groundwater D.2.8 Comments Concerning Ecology - Terrestrial D.2.9 Comments Concerning Ecology - Aquatic D.2.10 Comments Concerning Socioeconomics D.2.11 Comments Concerning Historic and Cultural Resources D.2.12 Comments Concerning Meteorology and Air Quality D.2.13 Comments Concerning Health - Nonradiological D.2.14 Comments Concerning Health - Radiological D.2.15 Comments Concerning Nonradiological Waste D.2.16 Comments Concerning Accidents - Severe D.2.17 Comments Concerning the Uranium Fuel Cycle D.2.18 Comments Concerning the Need for Power D.2.19 Comments Concerning Alternatives - No-Action D.2.20 Comments Concerning Alternatives - Energy D.2.21 Comments Concerning Alternatives - Sites D.2.22 Comments Concerning Benefit-Cost Balance D-8

1 D.2.1 Comments Concerning Process - ESP 2 Comment: On to the scoping comments. The ESP process at this stage of the game is highly 3 speculative without knowing what the reactor design is going to be and without even having a 4 certified reactor design. In the ESP application they talk about four possible reactors -- designs 5 that could be considered -- well, three of the companies have -- have removed themselves from 6 the business. That's an indication of their judgment of the market conditions that are highly 7 unfavorable to small modular reactors. (0001-5-5 [Safer, Don])

8 Comment: I know you're doing a lessons-learned study right now, and I know the NRC has 9 long had a lesson from the program. Looking at the EIS statements you've done in the past, I 10 hope you will also look at the timing factor. Taking long amounts of time to get through these 11 things does not necessarily mean a complete review. So I would hope that you would look at 12 that because I think anything we can do to push the process forward and still make it a complete 13 and thorough process would help the industry. (0001-7-1 [Kohlhorst, Darrel])

14 Comment:

15 Critical Infrastructure 16 Executive Order 13636, "Improving Critical Infrastructure Cybersecurity," was issued 17 February 12, 2013.6 The order cites "cyber intrusions into critical infrastructure" which 18 "demonstrate the need for improved cybersecurity." The order states:

19 Sec. 9. Identification of Critical Infrastructure at Greatest Risk. (a) Within 150 days of the date 20 of this order, the Secretary shall use a risk-based approach to identify critical infrastructure 21 where a cybersecurity incident could reasonably result in catastrophic regional or national 22 effects on public health or safety, economic security, or national security.

23 TVA's application states that "SMR deployment will demonstrate that the technology is capable 24 of incrementally supplying ... power that is less vulnerable to disruption to facilities owned by 25 federal agencies."7 The NRC cannot take lightly the prospect of another experimental nuclear 26 reactor design's impact on electric power infrastructure in light of the evolving threats and the 27 energy economics of the 21st Century. SMR passive cooling systems do not have active 28 backup systems. The weaker containment of SMRs has a greater chance of damage from 29 hydrogen explosions. Underground siting increases risk during flooding. And multiple SMRs 30 present higher risk from reduced support staff or safety equipment. The risks from these 31 reactors are precisely the catastrophic regional or national effects on public health or safety and 32 economic security which EO 13636 seeks to prevent.

33 In conclusion, the Commission should reject TVA's proposal for modular nukes.

34 [footnotes:]

35 6 Federal Register, Vol. 78, No. 33, February 19, 2013 36 7 Clinch River Nuclear Site Early Site Permit Application, Part 3, Environmental Report, page 37 1-1 (0055-2 [Zeller, Lou])

38 Response: The action before the NRC is the issuance of an early site permit (ESP) to 39 determine whether the Clinch River Nuclear (CRN) Site is suitable for placement of one or more 40 small modular nuclear reactors with a maximum electrical output not to exceed 800 MWe. An 41 ESP, if granted, does not authorize construction of any reactors; the applicant must obtain a 42 construction permit (CP) or combined construction permit and operating license (combined D-9

1 license or COL) from the NRC and the CP or COL application would be the subject of an NRC 2 review when the application for the CP or COL is submitted. An applicant is not required to 3 specify a reactor design for an ESP; however, in the absence of a specified design, the 4 applicant is expected to provide a plant parameter envelope (PPE), which TVA has done 5 here. A PPE is a set of values of plant design parameters that an ESP applicant expects will 6 bound the design characteristics of the reactor or reactors that might be constructed at a given 7 site. The PPE values are a bounding surrogate for actual reactor design information, and 8 should provide sufficient information about the reactor(s) and associated facilities, so that an 9 assessment of site suitability can be made.

10 The NRC is conducting its environmental review of TVAs ESP application and preparing an 11 Environmental Impact Statement (EIS) in accordance with 10 CFR Part 51 (TN250) and 10 CFR 12 52.18 (TN251). The environmental review will focus on the effects of construction and operation 13 of a nuclear power plant that is bounded by the PPE provided by the applicant. Accidents will 14 be addressed in Section 5.11 of the EIS, but reactor safety systems and flooding risk are 15 reviewed in the NRCs separate but parallel safety review. The outcome of the ESP safety 16 review will be published in a Safety Evaluation Report.

17 D.2.2 Comments Concerning Process - NEPA 18 Comment: One of the things, the fundamental things, about an EIS is that it identifies what the 19 project is and why it is needed. Because every project under an EIS has to have a no-action 20 alternative. The law requires that.

21 So, the no-action alternative is we don't approve anything. And for this, obviously, it's we build 22 these SMRs, whatever they may be at this site, but there has to be a reason. And that reason 23 needs to be in the Environmental Impact Statement.

24 I know that TVA has asserted to the NRC that it doesn't need to talk about the need for power.

25 And I know the TVA officials have said, "We're not buying any power, folks. Sorry. You know, 26 go away. We haven't even made a contract for 3-cent-a-kilowatt-hour wind, like the west end of 27 the State."

28 But, as we get closer to this, it seems to me that the EIS is going to be challenged and 29 challengeable if it does not state the need, the projected need for power, and why that is going 30 to be compared to the other sources that are already going and available, both from all the 31 existing generation, particularly since TVA says it's not going to phase out its coal plants, and 32 with things like free mining wind at the west end of the State. (0002-4-6 [Paddock, Brian])

33 Comment: But, then, I think there are issues that are involved that in one place there are other 34 issues, such as flooding and seismology risks that have not even been brought up that I think 35 we all agree are valid.

36 Again, I think we should establish here the purpose of an early site permit should be to establish 37 the viability of a site and to characterize, if a site is chosen for action, what a root cause is of 38 potential risk factors would be. So, in other words, what is our baseline flooding risk? What is 39 our baseline subsidence risk? What is our baseline seismological risk? These are valid.

40 Things I think, though, that should be not they're irrelevant to the scope and they are beyond the 41 NRC's safety mandate include the following factors. I believe this is entirely the NRC is not an 42 energy policy agency, nor should they be.

D-10

1 I believe it is valid if you want to take this to the TVA Rate Payers Board. Be my guest. You 2 should. The same goes for electricity. These are ancillary to the site's suitability. I think the site 3 suitability presentation should focus on the environmental suitability and environmental impacts.

4 A lot of talkers have brought up the absence of a specified design, which is somewhat puzzling 5 since we're not at the construction licensing, construction/operating licensing phase.

6 What we question more here with this Environmental Impact Assessment is whether or not this 7 site could suitably host a numeric nuclear facility. In this sense, then, I think discussions should 8 be suitably restricted towards the issues which have the most pertinent influence on actual 9 radiological safety issues of the plant. And these include the geology, hydrology, and 10 seismology. Other issues that are more policy-oriented and such I think are not as germane.

11 (0002-5-3 [Skutnik, Steve])

12 Response: Chapter 1 of the EIS will address the purpose of and need for the proposed action, 13 and will present the range of alternatives considered in the EIS, including the no-action 14 alternative. The ESP determination is primarily a siting decision; in accordance with 10 CFR 15 51.75 (TN250), the EIS will not include an assessment of the need for power or an evaluation of 16 alternative energy sources because these matters were not addressed in the applicants 17 environmental report (ER; TVA 2016-TN4637). Site safety, seismicity, and flooding risk are 18 reviewed in the NRCs separate but parallel safety review; the outcome of the ESP safety 19 review will be published in a Safety Evaluation Report.

20 Comment: NRC and TVA may want to consider the advantages of early consultation with 21 federal, state and tribal agencies for the purpose of streamlining the permitting process during 22 the NEPA analysis. One advantage of an early consultation process could be TVA obtaining 23 their environmental permits shortly after the NEPA Record of Decision (ROD) issuance. The 24 inclusion of NRC's systematic approach (10 CFR Part 51) along with state and federal 25 permitting issues into the NRC's pre-permitting process can provide a streamline NEPA analysis 26 that helps to eliminate duplications in the permitting analysis. This will help to provide a more 27 productive analytical process overall. (0026-1 [Long, Larry])

28 Comment: NRC and TVA may also want to consider incorporating the Army Corps of 29 Engineers into the early consultation process to include Clean Water Act (CWA) 404 permitting 30 requirements, such as avoidance and minimization, along with mitigation requirements, if any.

31 (0026-2 [Long, Larry])

32 Comment: Please provide us [EPA Region 4, NEPA, Resource Conservation & Restoration 33 Division] with a copy (electronic, CD with two hardcopies) of future NEPA documents when they 34 become available. (0026-4 [Long, Larry])

35 Comment: The Tennessee Department of Environment and Conservation (TDEC) appreciates 36 the opportunity to provide comments on the Nuclear Regulatory Commission (NRC) Notice of 37 Intent (NOI) to prepare an Environmental Impact Statement (EIS) related to the Tennessee 38 Valley Authority (TVA) early site permit (ESP) for the Clinch River Nuclear (CRN) Site near Oak 39 Ridge, Tennessee.1 TDEC understands that the ESP application by TVA is an initial 40 determination process for resolving safety and environmental siting issues for a potential future 41 Small Modular Reactor (SMR) at the CRN Site, but does not authorize construction and 42 operation of a nuclear power plant. Additionally, as a Federal agency, TVA is required to 43 comply with the National Environmental Policy Act (NEPA) and the National Historic 44 Preservation Act (NHPA) independently of NRC requirements. The NRC expects to publish a D-11

1 draft EIS in June 2018. The proposed CRN Site, is located in Roane County, Tennessee, along 2 the Clinch River, approximately 25 miles west-southwest of downtown Knoxville, Tennessee.

3 (0043-1 [Abkowitz, Kendra])

4 [footnote:]

5 1 For more information on the TVA CRN proposal, including the ESP Application 6 (ML16144A086) please visit https://www.nrc.gov/reactors/new-reactors/esp/clinch-river.html.

7 Specific information regarding the TVA CRN proposal as is discussed in TDECs consolidated 8 response is taken from the Part 3 - Environmental Report submitted as part of TVAs ESP to 9 NRC. The Part 3 - Environmental Report can be found at 10 https://www.nrc.gov/docs/ML1614/ML16144A145.html.

11 Comment: TDEC appreciates the opportunity to comment on this NOI from NRC to prepare an 12 EIS for the TVA CRN Site. Please note that these comments are not indicative of approval or 13 disapproval of the proposed action or its alternatives, nor should they be interpreted as an 14 indication regarding future permitting decisions by TDEC. (0043-12 [Abkowitz, Kendra])

15 Response: The NRC is conducting its environmental review of TVAs ESP application and 16 preparing an EIS in accordance with 10 CFR Part 51 (TN250) and 10 CFR 52.18 (TN251). The 17 U.S. Army Corps of Engineers (USACE) is a cooperating agency on the environmental review 18 and will be providing input relevant to Clean Water Act Section 404 permitting and mitigation 19 requirements. The NRC has initiated consultation with Federal, State, and Tribal entities; a 20 chronology of correspondence will be provided in Appendix C of the EIS, and key formal 21 consultations (e.g., Section 7 of the Endangered Species Act) will be in Appendix F of the EIS.

22 Comment:

23 2. Brief Summary of Basis for the Contention:

24 a. Requirements of NEPA 25 NEPA implements a "broad national commitment to protecting and promoting environmental 26 quality." Louisiana Energy Services, L.P. (Claiborne Enrichment Center), CLI-98-3, 47 NRC 77, 27 87 (1998) (quoting Robertson, 490 U.S. at 348 and citing 42 U.S.C. § 4331). NEPA has two key 28 purposes: to ensure that the agency "will have available, and will carefully consider, detailed 29 information concerning significant environmental impacts" before it makes a decision; and to 30 guarantee that "the relevant information will be made available to the larger audience that may 31 also play a role in the decision-making process and implementation of that decision." Robertson, 32 490 U.S. at 349.

33 In fulfilling NEPA's first purpose of evaluating the environmental impacts of its decisions, 34 requires a federal agency to take a "hard look" at potential environmental consequences by 35 preparing an EIS prior to any "major Federal action[] significantly affecting the quality of the 36 human environment." Robertson, 490 U.S. at 349; 42 U.S.C. § 4332(c). The "hallmarks of a 37 'hard look' are thorough investigation into environmental impacts and forthright acknowledgment 38 of potential environmental harms." National Audubon Society, 422 F.3d at 185. In addition, the 39 agency must "rigorously explore and objectively evaluate the projected environmental impacts 40 of all reasonable alternatives for completing the proposed action." Van Ee v. EPA, 202 F.3d 41 296, 309 (D.C. Cir. 2000). In considering alternatives, the agency must examine the "alternative 42 of no action." 40 C.F .R. § 1502.14.

D-12

1 In fulfilling NEPA's second purpose of public participation, the agency's environmental analysis 2 must be published for public comment "to permit the public a role in the agency's decision-3 making process." Robertson, 490 U.S. at 349-50; Hughes River Watershed Conservancy v.

4 Glickman, 81F.3d437, 443 (4th Cir. 1996). NRC's Part 51 regulations also allow interested 5 members of the public to participate in the environmental decision-making process through the 6 NRC's hearing process. 10 C.F.R. §51.104(a). (0052-11 [Curran, Diane])

7 Comment:

8 b. Regulatory requirements for NEPA compliance in ESP proceedings 9 Because an ESP approves only the banking of a site and not construction or operation of any 10 nuclear facility, the NRC limits the scope of an EIS to issues related to the siting of the facility.

11 As explained in the preamble to the rule, the NRC intended to focus the environmental analysis 12 for ESP applications on issues related to site suitability, such as environmental impacts of 13 construction and operation and alternative sites:

14 The environmental report and EIS for an early site permit must address the benefits associated 15 with issuance of the early site permit (e.g., early resolution of siting issues, early resolution of 16 issues on the environmental impacts of construction and operation of a reactor(s) that fall within 17 the site characteristics, and ability of potential nuclear power plant licensees to "bank" sites on 18 which nuclear power plants could be located without obtaining a full construction permit or 19 combined license). The benefits (and impacts) of issuing an early site permit must always be 20 addressed in the environmental report and EIS for an early site permit, regardless of whether 21 the early site permit applicant chooses to defer consideration of the benefits associated with the 22 construction and operation of a nuclear power plant that may be located at the early site permit 23 site. This is because the benefits * *

of the proposed action for which the discussion may be 24 deferred are the benefits associated with the construction and operation of a nuclear power 25 plant that may be located at the early site permit site; the benefits which may be deferred are 26 entirely separate from the benefits of issuing an early site permit. The proposed action of 27 issuing an early site permit is not the same as the proposed action of constructing and 28 operating a nuclear power plant for which the discussion of benefits (including need for power) 29 may be deferred under § 51.50(b).

30 Final Rule: Licenses, Certifications, and Approvals for Nuclear Power Plants, 72 Fed. Reg.

31 49,352, 49,430 (Aug. 28, 2007) (emphasis added). Accordingly, NRC regulation 10 C.F.R.

32 §51.50(b)(2) provides that an environmental report for an ESP application "need not include an 33 assessment of the economic, technical, or other benefits (for example, need for power) and 34 costs of the proposed action or an evaluation of alternative energy sources." As explained in the 35 preamble, the choice is up to the applicant:

36 Environmental reports must focus on the environmental effects of construction and operation of 37 a nuclear reactor, or reactors, which have characteristics that fall within the design parameters 38 postulated in the early site permit. Environmental reports must also include an evaluation of 39 alternative sites to determine whether there is any obviously superior alternative to the site 40 proposed. Environmental reports submitted in an early site permit application are not required 41 to but may include an assessment of the economic, technical, and other benefits and costs of 42 the proposed action or an analysis of other energy alternatives.

43 Id. at 49,434 (emphasis added). Thus, the NRC does not consider the energy alternative issue 44 to be material to the issuance of an ESP, unless the applicant chooses to address the issue.

D-13

1 In a proceeding where the applicant decides not to address energy alternatives at the ESP 2 stage, the NRC prohibits members of the public from raising contentions regarding those issues, 3 because the NRC does not require those issues to be addressed in its ESP licensing decisions.

4 See, e.g., Dominion Nuclear North Anna, L.L.C. (Early Site Permit for North Anna ESP Site),

5 LBP-04-18, 60 NRC 253, 264 (2004) (citing Florida Power & Light Co. (Turkey Point Nuclear 6 Generating Plant, Units 3 and 4), LBP-01-06, 53 NRC 138, 159 (2001); Pacific Gas & Electric 7 Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), LBP-93-01, 37 NRC 5, 29-30 (2001);

8 Public Service Co. of New Hampshire (Seabrook Station, Units 1 and 2), LBP-82-106, 26 NRC 9 1649, 1656 (1982); Yankee Atomic Electric Co. (Yankee Nuclear Power Station), CLI-96-7, 43 10 NRC 235, 251 (1996); Arizona Public Service Co. (Palo Verde Nuclear Generating Station, 11 Units 1, 2, and 3), LBP-91-19, 33 NRC 397, 410, aff'd in part and rev'd in part on other grounds, 12 CLI-91-12, 34 NRC 149 (1991) (holding that a contention advocating stricter requirements than 13 agency rules impose or that otherwise seek to litigate a generic NRC determination are 14 inadmissible)). Accordingly, with the exception of the issue of site alternatives, NRC prohibits 15 members of the public from seeking consideration of alternatives in an Environmental Report or 16 EIS for an ESP, including comparisons of the proposed operational technology to other 17 technologies for production of electricity.

18 In hearings on NEPA issues, the NRC also requires fairness to all parties. Hydro Resources, 19 Inc. (P.O. Box 15910, Rio Rancho, NM 87174), CLI-01-04, 53 NRC 31, 38 (2001). As the 20 Commission held in Hydro Resources, Inc., the NRC may not issue a license based on an EIS 21 whose contents it has shielded from challenge in a hearing. (0052-12 [Curran, Diane])

22 Response: The commenter's scoping comments were submitted to the NRC as part of a 23 separate hearing process. Please refer to ML17188A445 for the NRC staff's response to the 24 comments. These comments describe the NEPA process as it relates to an ESP 25 proceeding. The comments do not provide information relevant to the environmental effects of 26 the proposed action and will not be evaluated in the EIS.

27 D.2.3 Comments Concerning Site Layout and Design 28 Comment: In fact, SMRs don't even exist yet. There isn't a certified reactor design, therefore it 29 is impossible to state now that SMRs can provide reliable energy for extended operation as TVA 30 misleadingly stated in their ESP application. (0001-4-4 [Powell, Michelle])

31 Comment: The design for the SMR is not there yet. And it seems to me that we can't really 32 make a final determination that this site is even suitable when you don't know what you want to 33 construct. So, I'm not quite sure why there's a scoping session ahead of even knowing about 34 are we clear that the site would be applicable before you know that you want to build on it.

35 (0002-2-10 [Kurtz, Sandy])

36 Comment: It looks like to me that the proposal is that there's going to be 12 SMRs. It is the 37 NuScale SMR design, which is still in discussion with the people at the NRC as well because, 38 eventually, if it ever becomes the only approved SMR design.

39 I recently spent an entire afternoon listening to staff testimony to the Advisory Committee on 40 Reactor Safeguards --and this was the other piece that the introductions mentioned --where the 41 safety of an SMR is reviewed. It went from about one o'clock to five o'clock. It was quite 42 extensive.

D-14

1 These are mostly academics and other nuclear engineers, specialists. One of the members, in 2 fact, has been on the Advisory Committee so long that he sat on the discussion of the safety of 3 the Clinch River breeder reactor, and he is about my age.

4 That Committee raised a number of questions which I think go to the point about how you 5 decide the suitability of the site when you do not yet have an approved design. The last time 6 the NRC approved another site approval several years ago --and this was called to our attention 7 at a couple of earlier public meetings as this was beginning to gel. And we were told, "Go back 8 and look at the most recent approval of the other site."

9 Well, I looked at it. It took about 10 years to approve the site. And that was based on the idea 10 that they would build one of several existing designs that had already been designed and built 11 and approved, and so forth. So, the envelope primarily for that was quite clear as to what kind 12 of a nuclear reactor generation system might be built at a site. It seems to me that that makes 13 the environmental assessment much, much easier. (0002-4-1 [Paddock, Brian])

14 Comment: Another member of the Committee, the Advisory Committee on Reactor 15 Safeguards, questioned, he said, "I am very uncomfortable with the assumption that, because 16 these reactors are going to be underground, they're safe." There are a lot, tons of things we 17 worry about with the above-ground full-scale reactors that simply can't happen. And there was 18 not a lot of discussion about that assumption, but there was a certain amount of discomfort 19 among several members of the Advisory Committee about the assumption that this somehow, 20 putting small reactors underground, as is proposed here, wiped away a lot of the questions and 21 problems that you might ordinarily think more about it. (0002-4-3 [Paddock, Brian])

22 Comment: And the staff also brought up in their testimony to the Committee a very interesting 23 question. They said, "Well, we're having quite a difficult time because there are no applicable, 24 advanced reactor standards applicable to SMRs that are still working advanced reactors."

25 And by the way, there were handouts at the table there, new reactor plant designs, and referred 26 to a 1988 Policy Statement and referred to several designs, only one of which I think, the 27 AP1000, has seen tentative, partial construction in the United States. And this was called a 28 "backgrounder," and it was from June 2008.

29 If we are still thinking, if we are still able to describe what our understanding is of advanced 30 nuclear plant designs on a piece of paper that was put out in 2008, we obviously are not ready 31 for new plant designs.

32 The same thing is true of the next-generation reactors. The factsheet talks about as of January 33 2004. It talks about the AP1000. And the radioactive waste sheet is dated April of 2007.

34 If we are where we were a decade ago on all of those issues --and I don't believe we are --in 35 terms of both the challenges and our responses, then we're getting way ahead of ourselves.

36 Now, if you go back to the staff comments, one of the things they say is, "We don't have a place 37 to go." It doesn't fit in with the advanced reactor design approval process or standards that are 38 being worked on there. It doesn't fit in with the existing standards for full-scale reactors. These 39 are supposed to be lightwater reactors.

D-15

1 But, for example, the chemical engineers have a huge, a large set of standards, very detailed 2 standards for what goes into the kind of equipment and how it's installed, and so forth, for a full-3 scale reactor. And the staff said: we can't really use those. They don't apply. What we have to 4 do with respect to every standard engineering function is to go back and figure out why that's in 5 there. Why did we say the pipe should be this big? Why did we say it has to be done this way?

6 And we have to figure out what that was to accomplish in terms of safety and reliability. And we 7 have to do that with every one of the existing standards, and that is just for mechanical 8 engineering, which was the example used, but it would clearly apply for control, instrumentation, 9 and a number of other factors.

10 Likewise, at other places, they simply say, "We cannot use, without reinventing to some extent 11 all of the existing standards for reactor safety and for reactor standards." And that brought about 12 a very interesting conversation at the end among the members of the Advisory Committee on 13 Reactor Safeguard because one of them said, "Why don't we go back to basics? Why don't we 14 just look at the things where you might release radiation to affect the public and skip all the rest 15 of this?" All this stuff that we developed over the years that says what kind of stainless steel has 16 to be used in what kind of a situation, and what the reliability is of pumps and switches and 17 instruments, and so forth. And that led to a fairly interesting discussion about whether we were 18 trying to be too detailed in developing these standards. (0002-4-4 [Paddock, Brian])

19 Comment: But, to tell the people that are working on the EIS that they have some kind of a 20 grasp on what the proper envelope is --and I think that is the word that is used in the application, 21 the proper envelope to be examined of what the possible design for our numbers, and so forth, 22 are. Are these SMRs, and particularly the multiple system of them --it seems to me we have 23 gotten way ahead of ourselves. (0002-4-5 [Paddock, Brian])

24 Comment: If it is an experimental design of national importance the TVA rate payers should 25 not be used as test rabbits for footing the bill if they already shoulder the risks of possible 26 failure. Given the unreliability of renewable energy at least as long as we don't have the 27 necessary bridging capabilities, SMRs could fill a very necessary role in stabilizing electricity 28 supply, especially near locations where electrical supply reliability is paramount. Hopefully 29 these reactors can be made safe enough that they can be also located near these locations, 30 i.e., by self-contained cooling as well as by self-contained emergency systems. Until this 31 happens TVA should direct its attention to the urgently needed revamping of the legal 32 environment that prevents it from continuing its role as a valley-wide resource development 33 agency, as addressed in 4. (0013-3 [Wunderlich, Walt])

34 Comment: No actual approved design (0059-2 [Anonymous, Anonymous])

35 Response: Most of these comments concern the lack of an approved Small Modular Reactor 36 (SMR) design or the timeframe for the SMR design review process. An applicant is not required 37 to specify a reactor design for an ESP; however, in the absence of a specified design, the 38 applicant is expected to provide a plant parameter envelope (PPE) that provides sufficient 39 information about a surrogate reactor(s) and associated facilities so that an assessment of site 40 suitability can be made. SMR design development and certification are outside the scope of the 41 ESP environmental review; information about NRCs SMR design certification status can be 42 found on the NRCs website at https://www.nrc.gov/reactors/new-reactors/smr.html.

43 An ESP, if granted, does not authorize construction of any reactors. The applicant must obtain 44 a construction permit (CP) or combined construction permit and operating license (combined 45 license or COL) from NRC, and an application for CP or COL is required to reference a specific D-16

1 reactor design. In its review of a CP or COL application referencing an ESP, the NRC would 2 carefully consider any parameters that are outside the PPE that was evaluated for the ESP, any 3 new and significant information that could change the impact determined for the ESP, and any 4 information relevant to resolving any issues left unresolved for the ESP.

5 D.2.4 Comments Concerning Land Use - Site and Vicinity 6 Comment: We recommend environmental zoning for the former Clinch River Breeder Reactor 7 Site. We believe it is appropriate that all of the upland area on the northern half of this 8 peninsula be designated as Zone 4 [Natural Resource Conservation]. Further, portions of the 9 disturbed and level area at the southern end of the peninsula should be designated for Zone 5 10 [Industrial]. The portion of the site designated for small modular reactor installation would best 11 be limited to the area previously disturbed by prior construction and the relatively level land 12 immediately surrounding it to the north and away from the reservoir. Further, we ask that a strip 13 between 75 m and 300 m wide be maintained along the edge of the Clinch River/Melton Hill 14 Reservoir within this parcel. (0054-1 [Goss, Sandra])

15 Response: An assessment of site and regional land-use impacts from the proposed action of 16 building and operating the CRN Site will be discussed in EIS Section 4.1 and 5.1. This 17 assessment will address zoning issues and compatibility with nearby land uses. Cumulative 18 land-use impacts will be addressed in Section 7.1.

19 D.2.5 Comments Concerning Geology 20 Comment: In the geology -- that site is on karst terrain, and I was doing some reading last 21 night on the EIS and we go into 140-something pages of geology, but the fact is, it is karst 22 terrain. They found that when the Clinch River site was prepared. And it needs to be 23 thoroughly considered and thoroughly vetted.

24 The risks of sinkholes and active sinkholes -- I mean, we've all seen the sites in Florida of huge 25 apartment complexes ending up underground and people being buried in them. I understand 26 there will be a lot of geology work done, but that needs to be seriously considered, especially in 27 karst terrain. (0001-5-8 [Safer, Don])

28 Response: The geology of the site will be described in EIS Section 2.8. The effects of 29 geologic features such as karst on the occurrence and movement of groundwater at the CRN 30 Site will be discussed in EIS Section 2.3.1.2.

31 D.2.6 Comments Concerning Hydrology - Surface Water 32 Comment: In particular, I've heard a number of comments at this forum which I feel are beyond 33 the NRC's stated scope and mandate issues that are not germane to safety to -- particularly to 34 the site suitability or safety. And I would remind the audience and the NRC that the mandate 35 should properly be put on whether or not the site can be suitably host to a nuclear reactor 36 design. So in this sense then I think it's perfectly appropriate to consider things like level effects 37 on water quality (0001-10-2 [Skutnik, Steve])

38 Comment: [the erosion and all the things associated with soil toxics and those kinds of things 39 will eventually get to the river, the Clinch River. And that is not good for].... our drinking water, 40 for that matter, as it goes downstream. (0002-2-4 [Kurtz, Sandy])

D-17

1 Comment: [Then, we can talk about the climate change impacts, and I am hoping that in this 2 scoping, do you include that and address] .....any water flow issues ... (0002-2-7 [Kurtz, Sandy])

3 Comment: [When you are talking about climate change, ].... You are talking temperature. And 4 so, the temperature, water temperature is very important, especially when you're talking about 5 nuclear plants. And so, not only the water flow, but the water quantity should be addressed if it 6 is going to meet the needs of any nuclear plant work. (0002-2-9 [Kurtz, Sandy])

7 Comment: The impacts on water quality are another valid consideration I've seen brought up 8 that should be part of the NRC review, and we'll ultimately own that. (0002-5-2 [Skutnik, Steve])

9 Comment: And there was a previous comment on water temperatures. A few years ago we 10 had a summer where I think we hit 108 degrees. That's somewhat normal. So, severe 11 droughts, water temperatures are a concern. I know they limited one reactor based on its 12 operation. (0002-6-2 [Martin, Rodger])

13 Comment: it [SMRs] uses too much water. we need to move in the direction of clean 14 alternative solutions. there is so much unknown about this technology, and the clinch river is a 15 clean river now. (0023-2 [Grimes, Patricia])

16 Comment: [A reactor that produces long-lived and highly radioactive nuclear waste ....] and will 17 most likely pollute the community's clean water supply is just not wise. (0025-3 [Kirkman, Arden])

18 Comment: Given the expected activity associated with this proposed project, the following 19 TDEC permitting requirements are likely to apply.2 The construction of a Small Modular Reactor 20 (SMR) at the TVA CRN Site will require a construction storm water permit based on the land 21 disturbance at the site being more than one acre.3 A National Pollutant Discharge Elimination 22 Permit (NPDES) permit will be required for the discharge from the facility into the Clinch River.4 23 An Aquatic Resource Alteration Permit (ARAP) will be required for the water withdrawal at the 24 facility.5 This facility will also be required to have a Tennessee Storm Water Multi-Sector 25 General Permit, which will include the barge loading and offloading facility.6 26 [footnotes:]

27 2 As this is a scoping document for a forthcoming EIS, there is not sufficient information to 28 address the requirements for the permits in more detail. There have not been any public water 29 supply intakes, wells or springs identified that would be impacted from the proposed facility, but 30 as additional details are provided more permitting requirements may be necessary.

31 3 For more information on NPDES Stormwater Construction Permitting please visit 32 http://www.tn.gov/environment/article/permit-waternpdes-stormwater-construction-permit.

33 4 For more information on NPDES Discharge Permitting please visit 34 https://www.tn.gov/environment/article/permit-water-nationalpollutant-discharge-elimination-35 system-npdes-permit.

36 5 For more information on the ARAP program please visit 37 https://www.tn.gov/environment/article/permit-water-aquatic-resourcealteration-permit.

38 6 For more information on the NPDES Industrial Stormwater General Permit program please 39 visit http://www.tn.gov/environment/article/permit-water-npdes-industrial-stormwater-general-40 permit. (0043-2 [Abkowitz, Kendra])

41 Comment: The TVA CRN Site Part 3 - Environmental Report submitted to the NRC as part of 42 the ESP Application notes that due to the interactions of the Watts Bar Dam, Melton Hill Dam 43 and Fort Loudon Dam, that the river flow can be upstream, downstream or quiescent, 44 depending on the modes of operation" within the vicinity of the site. This could mean that for D-18

1 short periods of time, the intake at the CRN facility would be downstream of the NPDES 2 discharge point for the facility. It is not clear what impact if any this flow reversal would have, 3 but TDEC recommends that the forthcoming EIS consider this variable. (0043-3 [Abkowitz, 4 Kendra])

5 Comment: SMR's are extremely water-intensive, especially when compared to clean energy 6 choices such as wind, solar and energy efficiency and conservation. In these global warming 7 times of drought, squandering water in this way is the last thing we should be doing. (0051-11 8 [Anthony, Kate])(0051-5 [Anthony, Kate])

9 Comment: Water use could be an environmental concern, but it is impossible to comment 10 further on water consumption by the proposed reactors without more information about the 11 cooling-system water requirements and other water intake needs. In principle, the adjacent 12 river/reservoir could provide adequate water supply. (0054-2 [Goss, Sandra])

13 Comment: More intensive water use than clean energy sources (0059-3 [Anonymous, 14 Anonymous])

15 Response: Potential impacts on surface-water use and quality as a result of construction at the 16 CRN Site will be discussed in EIS Sections 4.2.2.1 and 4.2.3.1. The potential impacts on 17 surface-water use and quality as a result of plant operations at the CRN Site will be discussed in 18 EIS Sections 5.2.2.1 and 5.2.3.1. The effects of the CRN Site discharge on water temperature 19 in the Clinch River will be included in Section 5.2.3.1 and the resulting potential impacts on 20 aquatic ecology will be discussed in EIS Section 5.3.2. Permits and approvals will be discussed 21 in Chapter 1 and Appendix H of the EIS. Appendix L will discuss expected future changes in 22 climate at the CRN Site and will evaluate the potential effects of future climate change on the 23 assessed environmental impacts.

24 D.2.7 Comments Concerning Hydrology - Groundwater 25 Comment: I am looking at the coarse terrain of that site, and it is right along the Clinch River, 26 of course. So, I am hoping that the scoping will really take a look at more knowledge that we 27 know since the breeder reactor was referred to was studied, that they will look more carefully at 28 how this works, because this SMR will be in a hole in water.

29 And there are sinkholes around. I don't know who's responsible for dealing with the sinkholes, 30 but I know in the past that those sinkholes are often treated by filling them with concrete. That 31 doesn't seem like a good plan, in part because of the surface, and with the coarse terrain, you 32 never quite know where the water is going to do. (0002-2-2 [Kurtz, Sandy])

33 Comment: Let me say one final thing about this site. The site is, as has been mentioned, a 34 coarse site. And TVA in its application did some extensive hydrogeological descriptive material, 35 and as one gentleman mentioned, at a previous reactor site there was a good deal of work 36 done.

37 But you have to understand in coarse [karst] that core drilling doesn't really tell you. You can 38 drill down and you could be six inches from the edge of a gigantic cave and you will miss it, and 39 you will not know it's there. And ground-penetrating radar only works for the first few feet. You 40 cannot tell what's under there.

41 And there are two recent examples that I would offer you. One is that TVA created a new lime 42 waste site for coal ash over at Kingston. And I don't know if you've followed that. But the darned D-19

1 thing blew a hole in the bottom and a sinkhole and dumped a lot of ash out into the river. And 2 somebody came along in a boat and said, "What's all this gray stuff bubbling up in the water?"

3 And it was coal ash.

4 And they spent a lot of money on re-engineering that to TVA's satisfaction because they simply 5 could not tell. And to this day, none of the engineers who did the re-engineering can guarantee 6 you that what they have done --you know, they cut it down and relined it, and did a lot of things -

7 -that there are not sinkholes fairly near the surface that could burst through where there is 8 enough weight in that area. (0002-4-9 [Paddock, Brian])

9 Comment: I think that with that they hydrogeology is an entirely valid concern to be brought up, 10 no matter what reactor design should be put there. That is an entirely valid concern over siting 11 a reactor. And this is part of every, by now, it is part of every NRC review, and it should be.

12 (0002-5-1 [Skutnik, Steve])

13 Comment: My second concern comes from participation in design of groundwater monitoring 14 systems and groundwater tracing studies in East Tennessee over several decades. Because of 15 the statistical nature of radioactive emissions and the counting techniques typically used for 16 analysis of radionuclides, detection monitoring systems for releases of radioactive substances 17 into groundwater may yield ambiguous results. The scoping document, which contains much 18 general background information on geology and hydrogeology, indicates that the site 19 hydrogeology will be complicated due to extensive fracturing and to dissolution (karst) 20 processes. I have been on the site, and believe the scoping document presents a fair 21 assessment of the geology and hydrogeology of the site. My experience has been that 22 adequate groundwater monitoring for a release at such sites requires more sampling, both 23 spatially and temporally, than at sites without such extensive altering of primary bedrock 24 permeability. While TVA has reactors on karst sites, they were permitted before it was so well 25 understood that, on these sites, it is very difficult to adequately predict either direction or velocity 26 of groundwater flow.

27 At the proposed site, one monitoring well has already been contaminated with volatile organics.

28 TVA and TDEC sampling of well 422L at the site indicated non-aqueous phase diesel range 29 organics. This obviously adds a further complication to the question of site monitorability.

30 Presumably, TVA would need to remediate or isolate this contamination before attempting to 31 monitor groundwater on the site.

32 Finally, there are other potential sources of radioactive contamination nearby. The Clinch River 33 has received significant discharges of radioisotopes during legacy operations at Department of 34 Energy Oak Ridge facilities. River sediments retain significant concentrations of radionuclides, 35 and low levels of some radioactive isotopes persist in river water. Air emissions of radioactive 36 substances occurred near the site, possibly increasing the levels of radioactivity in soils.

37 My third concern about the site is related to the potential for flooding of the buried portions of the 38 planned reactor(s) should groundwater channeling through karst conduits increase the 39 groundwater flux into the excavation made to contain the reactor(s) due to soil piping or bedrock 40 collapse. While there is currently little indication that such channels are well developed on the 41 site, quarry operations and construction projects in East Tennessee frequently change 42 groundwater hydraulics in ways that negatively impact (or even stop) operations. (0031-2 [Jones, 43 Sid])

D-20

1 Comment: Investigations by DOE and TDEC's Division of Remediation (DoR) - Oak Ridge 2 Office have shown that there is deep ground water flow that goes under the Clinch River from 3 the Oak Ridge National Laboratory (ORNL).7 Migration of chlorinated solvents within the 4 Conasauga Group formation, under the Clinch River along strike to the southwest, has resulted 5 in contaminated private wells at Hoods Ridge. There is also suspected contamination from Oak 6 Ridge Reservation in the Jones Island area across the Clinch River from Oak Ridge 7 Reservation as well. TDEC recommends that any private well or spring use occurring in the 8 area be investigated as a part of the EIS to address the unique geology and hydraulic 9 connectivity of the site. TDEC also recommends that the extent of the existing ground water 10 contamination, including preexisting radiological constituents and volatile organic compounds in 11 the groundwater, at the proposed CRN Site be determined by TVA and addressed in the 12 forthcoming draft EIS.8 13 [footnotes:]

14 7 The proposed CRN Site is located in complex folded/faulted karst geology of the Valley and 15 Ridge Province. The Copper Creek Thrust Fault cuts southwest/northeast across the toe" of 16 the boot-shaped site. A lesser unnamed thrust fault cuts across the northern portion of the site.

17 Karst ground water flow does not behave as laminar flow and does not follow Darcy's Law -

18 interstitial porosity plays a very minor role but appears to be a significant focus in TVA's 19 investigations. The beds of the Chickamauga Group formations in the area are dipping at 30 20 plus degrees to the southeast. Ground water flow is going to generally be along strike of the 21 beds to the southwest, as is evidenced from the offsite contamination from the Department of 22 Energy (DOE) ORNL.

23 8 TVA notes in its CRN Site ESP Application Part 3 - Environmental Report that monitoring well 24 OW-422L in the center of the CRN Site has petroleum-based contamination. This location is 25 slightly more than 1/2 mile west of the area of Hoods Ridge where chlorinated solvent 26 contamination has been identified from the DOE ORNL. The existence of pre-existing site 27 contamination is an issue of concern for both TDEC Division of Remediation and Division of 28 Water Resources. (0043-4 [Abkowitz, Kendra])

29 Response: The occurrence and movement of groundwater at the CRN Site will be described in 30 EIS Section 2.3.1.2, including the effects of fractures, karst, and geologic unit bedding 31 planes. Existing groundwater quality will be described in EIS Section 2.3.3.2. Potential impacts 32 on groundwater use and quality as a result of construction at the CRN Site will be discussed in 33 EIS Sections 4.2.2.2 and 4.2.3.2. The potential impacts on groundwater use and quality as a 34 result of plant operations at the CRN Site will be discussed in EIS Sections 5.2.2.2 and 5.2.3.2.

35 D.2.8 Comments Concerning Ecology - Terrestrial 36 Comment: And to close with dignity of the Oak Ridge Reservation which is the largest 37 contiguous protected area. There's a lot of rare and endangered species and in terms of forest 38 and the rich and valued products -- ecological products. That's a great asset and a very 39 valuable natural resource and -- that is also endangered by this site -- this close proximity.

40 (0001-11-2 [Naegeli, Wolf])

41 Comment: We live in a temperate rainforest. This is an especially rare kind of area. And it 42 seems to me that we would want to preserve that, that temperate rainforest. It is one of the few 43 in the world. And the biodiversity here of our species is very, very rare, indeed, and we need to 44 take responsibility to protect it, another reason perhaps that this site is not suitable. (0002-2-5 45 [Kurtz, Sandy])

D-21

1 Comment: Then, we can talk about the climate change impacts, and I am hoping that in this 2 scoping, do you include that and address the loss of forest, soil disturbance, and ...the 3 biodiversity, indeed, of the forest itself. (0002-2-6 [Kurtz, Sandy])

4 Response: The staff will discuss potential impacts on terrestrial resources from construction 5 and operation of the proposed project, including forests and other natural habitats and 6 threatened and endangered species and critical habitats, in Sections 4.3 and 5.3 of the EIS, 7 respectively. The staff will address cumulative impacts on terrestrial resources surrounding the 8 project area, including on the Oak Ridge Reservation, in Section 7.3 of the EIS. Appendix L of 9 the EIS will discuss the effect of climate change on the evaluation of environmental impacts.

10 Comment: So, this Clinch River Site has two advantages by being there at Oak Ridge National 11 Laboratory because ORNL's Environmental Sciences Division has done extensive long-term 12 research on the environment very close to this site and has just many papers and species list, 13 and information about this area.

14 Also, for the past three years the National Ecological Observatory Network, or NEON, project of 15 Battelle has been doing a lot of ecological/environmental research on many different aspects.

16 And it is within the same area. All this environmental data is provided as a public service. So, 17 these may be two resources that we have here. (0002-3-1 [Cumberland, Margaret])

18 Response: The staff agrees that the Oak Ridge National Laboratory and the National 19 Ecological Observatory Network are beneficial sources of information that may be used, among 20 others, to describe and characterize in the EIS those ecological resources that may be affected 21 by the proposed action or alternatives.

22 Comment: The [U.S. Fish and Wildlife] Service [FWS] has reviewed recent and historical 23 endangered species collection records within the locality of the proposed project site. Records 24 indicate that several federally listed terrestrial and aquatic species occur within the vicinity of the 25 site identified by NRC/TVA. Due to the presence of these species within the proposed project 26 vicinity, we request that NRC, or a designated representative thereof, work closely with the 27 Service when addressing threatened and endangered species within the action area to ensure 28 that the appropriate species and federally designated critical habitats are included in an 29 assessment. While we realize that TVA has extensive records for federally listed and at-risk 30 species in its Natural Heritage Database, we also suggest that NRC utilize the U.S. Fish and 31 Wildlife Service Information for Planning and Conservation (IPaC) system located at:

32 https://ecos.fws.gov/ipac/, in addition to TVA's Natural Heritage Database, to obtain the most 33 comprehensive species information. The proposed action area can be input into IPaC and a 34 current species list, appropriate for the proposed project, will immediately be produced. (0003-1 35 [Boles, Dustin])

36 Comment: Furthermore, the Service [FWS] recommends the development of a Biological 37 Assessment, as required by 50 CFR 402.12, which would analyze the potential effects of the 38 action on listed and proposed species and designated and proposed critical habitat. The 39 Biological Assessment will identify whether any such species or habitat are likely to be 40 adversely affected by the action and is used in determining whether formal consultation or a 41 conference is necessary. When evaluating potential impacts to species, both direct and indirect 42 impacts should be considered. (0003-2 [Boles, Dustin])

D-22

1 Comment: Additionally, we [FWS] recommend that NRC address and include known locations 2 of wetlands during their analysis with determinations of potential future effects to the resource.

3 (0003-3 [Boles, Dustin])

4 Comment: We [FWS] also request that NRC coordinate frequently and early with the Service 5 regarding the proposed action to remain in compliance with Section 7 of the Endangered 6 Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.). Additionally, the 7 Service request that NRC coordinate in regards to any potential survey efforts for threatened 8 and endangered species. (0003-4 [Boles, Dustin])

9 Comment: We [FWS] further recommend that NRC address and include known locations of 10 migratory birds, afforded certain levels of protection under the Migratory Bird Treaty Act of 1918 11 (16 U.S.C., Chapter 7, Subchapter II), and determine potential future effects to these resources.

12 In addition, we request that NRC determine the potential for presence and effects to the bald 13 eagle (Haliaeetus leucocephalus) in the action area. This species is currently afforded certain 14 levels of protection under the Bald and Golden Eagle Protection Act (16 U.S.C. 668-668c),

15 enacted in 1940, and the MBTA. (0003-5 [Boles, Dustin])

16 Comment: NRC should also identify hibernacula utilized by at-risk or federally listed bat 17 species in the vicinity of the action area and determine if the proposed action could affect any 18 individuals. (0003-6 [Boles, Dustin])

19 Comment: As NRC proceeds with its analysis, we [FWS] will provide additional comments 20 specific to the action. We can also provide a comprehensive list of species which we feel could 21 be affected by the proposed action at a later date, upon request (0003-7 [Boles, Dustin])

22 Comment: We have included a species list as an enclosure to this letter [see ML17205A341 23 for the tables], which identifies a list of species that may occur near the identified action areas.

24 The Service recommends that you evaluate the proposed project for potential direction and 25 indirect impacts to these listed species or their habitats in compliance with Section 7 of the 26 Endangered Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.). While 27 evaluating potential impacts to these species, please also consider modification of any 28 associated critical habitat for listed species.

29 While the project proponent is not required to consult on petitioned species, Section 7(a)(4) of 30 the Endangered Species Act of 1973 does provide a mechanism for identifying and resolving 31 potential conflicts between a proposed action and a proposed species during the early planning 32 stages. Therefore, we take this opportunity to recommend that you consider impacts to the 33 hellbender (Cryptobranchus alleganiensis), petitioned for listing in FY18. There are historic 34 records of this species occurring near the proposed site of the CRN. Additionally, there are 35 records of the Berry Cave salamander (Gyrinophilus gulolineatus), which is petitioned for listing 36 in FY19.

37 The Service recommends that you coordinate with the Tennessee Wildlife Resource Agency 38 and Tennessee Department of Environment and Conservations Natural Heritage Program to 39 address concerns regarding state listed species.

40 Response: The NRC staff appreciates the U.S. Fish and Wildlife Service's request to work 41 cooperatively on the Endangered Species Act (ESA) consultation for the proposed project. The 42 staff will coordinate with the U.S. Fish and Wildlife Service on the Endangered Species Act 43 (ESA) consultation for the proposed project and in its development of a Biological Assessment D-23

1 to ensure that it properly addresses all potentially affected listed and proposed species (and 2 designated critical habitat), as well as habitats used by such species (e.g., hibernacula), and will 3 also coordinate with other state agencies as suggested. The staff will summarize relevant 4 information from the ESA consultation and will include it in Sections 2.4, 4.3, and 5.3 of the 5 EIS. The staff will similarly include evaluations of migratory birds, including the bald eagle, and 6 wetlands in the EIS.

7 D.2.9 Comments Concerning Ecology - Aquatic 8 Comment: And further on, really, the Tennessee River ecology, it's already temperature 9 stressed by the climate change -- the more extreme southern temperatures that we've been 10 experiencing at longer duration of them in the past two decades. So -- and even before Watts 11 Bar 2 came online, TVA had several times instructed their nuclear power plants to refrain from 12 really stressing the ecology of the river more. And so I think it's really a stupid idea to put more 13 nuclear plants upstream (0001-11-3 [Naegeli, Wolf])

14 Comment: The effect of the reactors on the river need -- I'm sure will be studied carefully, but I 15 hope it's given serious consideration. The downstream water quality and the aquatic life and 16 the effect really on the water temperature all the way down stream -- because there's been 17 issues by the time it gets to Browns Ferry (0001-5-11 [Safer, Don])

18 Comment: And so, the erosion and all the things associated with soil toxics and those kinds of 19 things will eventually get to the river, the Clinch River. And that is not good for aquatic 20 biodiversity .... as it goes downstream. (0002-2-3 [Kurtz, Sandy])

21 Response: Potential impacts on aquatic ecosystems from water quality effects during 22 construction and operation will be discussed in Sections 4.3.2 and 5.3.2. Thermal impacts on 23 aquatic organisms and habitats as a result of plant operations will be discussed in Section 5.3.2 24 of the EIS. Potential cumulative impacts on aquatic life will be discussed in Section 7.3.

25 D.2.10 Comments Concerning Socioeconomics 26 Comment: Also what needs to be considered in terms of the location is population growth, at 27 least over the next 20 years. And if local climate change goes on as it has, and has done for 28 the last two decades at least, been always at the upper range of what the experts predicted it 29 could be -- the change in temperatures. And so that could lead to a lot more population in this 30 part of Tennessee because a lot of people living further south may find it unbearable and people 31 who are north may find that extreme events which are precipitated by the climate change -- it's 32 not so much the temperature alone that is of concern, it's really that this causes much more 33 extreme conditions -- longer droughts, more floods, more severe storms and extended what 34 used to be natural disasters seem to be taking longer and longer before they settle down 35 anymore. And so that should be considered. There may be a quite populated area and a more 36 -- that have established here in 20 years. (0001-11-4 [Naegeli, Wolf])

37 Response: Potential impacts from the proposed action on socioeconomic factors, such as the 38 regional population, will be discussed in Section 4.4 and 5.4 of the EIS. These sections will 39 include consideration of the demographic impacts for the proposed action. Cumulative 40 socioeconomic impacts will be discussed in Section 7.4 of the EIS.

41 Comment: Second of all, several people here have talked about the -- the workforce. I hope 42 you will also take into consideration, Oak Ridge is very rich in nuclear workers. We understand D-24

1 nuclear operations. We understand the rigor and formality required with those kind of 2 operations. We have a governor who supports education in the state. We have a drive-to-55 3 program. That 55-percent of our adult population certificate or -- or qualified in some field.

4 Locally we have the University of Tennessee involved with the operations of Oak Ridge National 5 Lab. We have the Pellissippi Community College and Roane State Community College that all 6 work very close with our nuclear providers and actually curtail their -- or -- or custom their -- their 7 curriculum to make sure it matches us so that we have the workforce of the future that we need.

8 And as you look at -- at the amount of time these reactors are going to be online and operating, 9 that is a long time. And it is not just who we have today, it is what we want to also have in the 10 future. (0001-7-2 [Kohlhorst, Darrel])

11 Response: Potential impacts on socioeconomic factors from construction and operation of the 12 proposed action will be addressed in Sections 4.4 and 5.4 of the EIS. This impact assessment 13 will include consideration of the workforce requirements for the proposed action in conjunction 14 with the regional labor market outlook (e.g., skill sets and availability). Cumulative 15 socioeconomic impacts will be discussed in Section 7.4 of the EIS.

16 Comment: Another thing is the -- my -- I live on Dove Ridge and if you look at the aerial 17 photographs of the site, there is a long linear green space of trees that lead that site. And my 18 thinking is well, two reactors. Somebody said they could put 12 in if they need more power line 19 right away, I would think I would know where it was going -- right behind my house on the only 20 long linear forested areas there is leading that site. So those are my concerns. My property 21 value -- if it is built, I know it would go down. Will I be made whole? I'm concerned about that.

22 (0001-8-2 [Almond, Jake])

23 Response: Potential impacts from the proposed action on socioeconomic factors, such as 24 property values, will be addressed in Sections 4.4 and 5.4 of the EIS. Cumulative 25 socioeconomic impacts will be discussed in Section 7.4 of the EIS.

26 D.2.11 Comments Concerning Historic and Cultural Resources 27 Comment: TDEC concurs with the plan to conduct Phase I/II site evaluation of the property 28 proposed for the TVA CRN Site. This archaeological evaluation will determined if prehistoric 29 and/or historic sites eligible for the National Register of Historic Places (NRHP) are located 30 within the proposed property. If an archaeological site is determined eligible for inclusion on the 31 NRHP, additional archaeological considerations will be necessary for the project to move 32 forward.13 33 [footnote:]

34 13 For more information on the Tennessee Division of Archeology please visit 35 https://www.tn.gov/environment/section/arch-archaeology. If there are site specific 36 archaeological questions please contact Jennifer Barnett at (615) 687-4780 or 37 Jennifer.Barnett@tn.gov. (0043-11 [Abkowitz, Kendra])

38 Comment: The Cherokee Nation (CN) is in receipt of your correspondence about Clinch River 39 Nuclear Site Early Site Permit Application, and appreciates the opportunity to provide comment 40 upon this project. The CN maintains databases and records of cultural, historic, and pre-historic 41 resources in this area. Our Tribal Historic Preservation Office (THPO) reviewed this project, 42 cross referenced the project's legal description against our information, and found that this Area 43 of Potential Effect (APE) lies within our historic homelands.

D-25

1 In accordance with the National Historic Preservation Act (NHPA) [16 U.S.C. 470 §§ 470-2 470w6] 1966, undertakings subject to the review process are referred to in S101(d)(6)(A), which 3 clarifies that historic properties may have religious and cultural significance to Indian tribes.

4 Additionally, Section 106 of NHPA requires federal agencies to consider the effects of their 5 action on historic properties (36 CFR Part 800) as does the National Environmental Policy Act 6 (43 U.S.C. 4321 and 4331-35 and 40 CFR 1501.7(a) of 1969).

7 The CN has a vital interest in protecting its historic and cultural resources. The CN is in 8 concurrence that an Environmental Impact Statement (EIS) in compliance with NHPA should be 9 conducted for the Clinch River Nuclear Site, and is requesting a copy of this report. This office 10 looks forward to receiving and reviewing the EIS. Please contact the CN with response to this 11 request.

12 Additionally, we would request Department of the Interior conduct appropriate inquiries with 13 other pertinent Tribal and Historic Preservation Offices regarding historic and prehistoric 14 resources not included in the CN databases or records. If items of cultural significance are 15 discovered while developing this project report, the CN asks that activities halt immediately and 16 our offices be contacted for further consultation. (0016-1 [Toombs, Elizabeth])

17 Comment: Information on Native American use in the project vicinity shows that prehistoric, 18 ethnographic, historic, and traditional sites of value to the UKB [United Keetoowah Band]

19 surround the project area. We recommend that a cultural resources inventory be completed 20 prior to project implementation. (0061-1 [Pritchett, Karen])

21 Response: Potential impacts on historic and cultural resources will be discussed in Chapters 4, 22 5, and 7, based on the affected environment described in Chapter 2. The NRC will also fulfill its 23 responsibilities under Section 106 of the National Historic Preservation Act (54 U.S.C. § 24 306108-TN4839) with regard to historic properties for the project. The results of the Section 25 106 review will also be presented in the EIS. Copies of the EIS will be sent to Tribal consulting 26 parties (including Tribal Historic Preservation Officers [THPOs]), the Tennessee Historical 27 Commission, and the Advisory Council on Historic Preservation for their review and comment in 28 accordance with NHPA consultation requirements.

29 Comment: Thank you for the correspondence regarding the above referenced project. This 30 project lies outside of our area of historic interest. Therefore, the Choctaw Nation of Oklahoma 31 respectfully defers to the other Tribes that have been contacted. If you have any questions, 32 please contact me by email. (0032-1 [Rangle, Daniel])

33 Response: The NRC will remove the Choctaw Nation from the CRN ESP EIS mailing list. The 34 NRC will continue to consult with other Tribes contacted for the proposed project under Section 35 106 of the National Historic Preservation Act (54 U.S.C. § 306108-TN4839).

36 D.2.12 Comments Concerning Meteorology and Air Quality 37 Comment: When you are talking about climate change, you are talking catastrophic weather 38 events that need to be followed up. (0002-2-8 [Kurtz, Sandy])

39 Response: Potential impacts on meteorology and air quality from construction and operation of 40 the CNR Site will be discussed in Sections 4.7 and 5.7 of the EIS. Cumulative impacts will be 41 discussed in Section 7.6. Climate change will be discussed in Appendix L.

D-26

1 Comment: The site may have air contaminant emissions from other onsite air emission 2 sources that are required to have an air contaminant permit from the Division of Air Pollution 3 Control. TDEC recommends that appropriate entities involved in the project review potentially 4 applicable air permits as well as work with the Division of Air Pollution Control to ensure all 5 emission sources are properly identified and permitted.12 6 [footnote:]

7 12 For more information on TDEC Air Pollution Control permits please visit 8 https://www.tn.gov/environment/topic/permit-air. (0043-10 [Abkowitz, Kendra])

9 Comment: Water cooling tower emissions are evaluated for permitting and have been 10 permitted at other existing TVA nuclear plants. The water vapor itself is not a regulated 11 emission, however the resultant particulates that arise from evaporation (minerals found in the 12 local river water or streams) are considered to be potential emissions as are any algaecide or 13 slime mold/fungus treatments added to the water to act as a biocide. (0043-8 [Abkowitz, Kendra])

14 Response: The EIS addresses emission from the construction and operation of the proposed 15 facility, as well as the cumulative impacts from existing sources. These comments refer to 16 permits the applicant should apply for prior to operation of the CRN Site. The action before the 17 NRC is an ESP to determine whether the CRN Site is suitable for placement of one or more 18 SMRs. An ESP, if granted, does not authorize construction, and the applicant must obtain a 19 construction permit or a combined license from the NRC prior to building at the site. Any new 20 and significant information regarding emissions will be addressed at that time with another NRC 21 NEPA review. It is at that stage in the project that the applicant is likely to consider taking steps 22 to apply for air contaminant emission permits from the state.

23 Comment: Should any land clearing activities or disposal of brush or trees/tree limbs occur, 24 TDEC prefers that wood waste be disposed of by chipping, grinding, or composting rather than 25 open burning. However, if open burning does occur during site preparation and construction, 26 open burning regulations should be followed. TDEC recommends that detailed clearing 27 activities, total amount of areas where soils are to be disturbed, and associated impacts be 28 addressed in the draft EIS.11 29 [footnote:]

30 11 TDEC APC Rule 1200-3-4-.01 et seq., http://sos.tn.gov/effective-rules. Additional information 31 on open burning in Tennessee is available at https://tn.gov/environment/article/apc-open-32 burning and http://www.burnsafetn.org/. (0043-7 [Abkowitz, Kendra])

33 Response: Environmental impacts associated with the construction of the CRN Site will be 34 addressed in Chapter 4 of the EIS. The building-related air emissions and related impacts on 35 air quality, as well as the emissions from any open burning of vegetation, will be addressed.

36 D.2.13 Comments Concerning Health - Nonradiological 37 Comment: I am a neighbor to the site. I can -- from my house on my porch you can see this 38 site. You can see the buildings that are out there already. I've always not wanted to be NIMBY 39 about my backyard but I guess if I had to vote, I'd prefer it not be there. But my concerns are 40 the noise. It -- how much noise this plant would make not only in the -- when it's running but in 41 the building of it. When we moved there I had my family with me on my property, and I said can 42 you guys hear that? And they said Dad, I don't hear anything. What are you talking about? I 43 said that's it, I don't hear anything but the birds. So I am concerned about the noise. I'm 44 concerned -- I -- when this thing first got announced I tried to get in touch with Lamar Alexander.

45 He never returned my calls. But somebody finally did and I asked if there would be a cooling D-27

1 tower on this site, and they said yes. Talking to folks today, they don't know. But the cooling 2 tower would be looming in my -- from my porch. And I don't think that will help the property 3 values. (0001-8-1 [Almond, Jake])

4 Comment: Cooling towers are also associated with certain other potential pathogenic airborne 5 illnesses including Legionnaire's disease and some amoebae considered harmful. (0043-9 6 Abkowitz, Kendra])

7 Response: Potential impacts from nonradiological health factors, such as noise and etiological 8 agents associated with cooling towers, due to construction and operation of the CRN Site, will 9 be addressed in EIS Sections 4.8 and 5.8. Cumulative impacts from nonradiological health 10 factors will be discussed in Section 7.7.

11 D.2.14 Comments Concerning Health - Radiological 12 Comment: [I would remind the audience and the NRC that the mandate should properly be put 13 on whether or not the site can be suitably host to a nuclear reactor design. So in this sense 14 then I think it's perfectly appropriate to consider things like] ... radiological safety. (0001-10-3 15 [Skutnik, Steve])

16 Comment: And there is also much associated illness, cancers and such, both in children and 17 with workers, employees, in the nuclear site. So, that would be, I think, that people, that 18 scoping should address. (0002-2-12 [Kurtz, Sandy])

19 Comment: What impact does radiation have on the soil, the air, and the water, and noise?

20 Those are things that should be considered, it seems to me, in scoping. (0002-2-13 [Kurtz, Sandy])

21 Comment: As a public health professional, I am worried about keeping these highly toxic 22 [radioactive] materials out of the air and water for generations to come. (0014-3 [Holt, Cathy])

23 Response: Potential impacts on human health from radiological factors due to the construction 24 and operation of the CRN Site, such as radiological safety for workers, illness, and radiation 25 levels, will be addressed in EIS Sections 4.7 and 5.9. Cumulative impacts on human health 26 from radiological factors will be addressed in Section 7.8.

27 Comment: Just remember the background of that is that, right now, because of the 28 development of nuclear weapons here, you really have about a million tons of low-level 29 radioactive waste already in this area.

30 And the Canadians have been given permission to bring in 10,000 more metric tons from 31 Canada, with no permit or anything required. And they've said in their application that, while 32 they have to have an export permit, in fact, they are not sending anything back.

33 So, you folks are going to be host to another 10,000 tons of low-level radioactive waste. And it 34 is sort of a question about how much cumulative radioactive you want.

35 You are also storing a lot of high-level enriched uranium. Because, don't forget, when the 36 Soviet Union collapsed, there was a deal made to bring as much of that away and keep it safely 37 until it could be turned into fuel for reactors. So, you've already got yours. (0002-4-8 [Paddock, 38 Brian])

D-28

1 Comment: My Ph.D. research back in the mid-1960's involved radionuclide fallout in two 2 Piedmont Georgia ecosystems, granitic outcrops and adjacent woodlands. In my study, I 3 analyzed the radioisotope fallout from nuclear weapons testing taking place in our West and 4 Russia. The project sampled 9 radioisotopes using scintillation counting for gamma emissions 5 from these elements, particular Cs-127 and Mn-54. My results demonstrated the presence of 6 these radioisotopes in all parts of three tree species, Juniperus virginiana, Pinus taeda, and 7 Quercus georgiana. I also tested the presence of radionuclides in the soils of these trees. I 8 found that those trees at the lower edges of rock outcrops accumulate more radionuclides than 9 high on the outcrop and adjacent woodlands. Thus I am concerned with any potential release of 10 radionuclides into our atmosphere and aquatic ecosystems.

11 This brings me to the point that development of additional sources of release or potential 12 release will result in bioaccumulation of dangerous radionuclides. This is certainly a problem 13 that can occur in the Clinch River watershed. It could also affect a broad area downwind of the 14 proposed Small Modular Reactors on the Clinch. (0015-1 [Pittillo, Dan])

15 Response: A baseline preoperational radiological environmental monitoring program will be 16 addressed in Section 2.11 of the EIS. Exposure pathways used to assess dose to construction 17 workers is described in EIS Sections 4.9.1, 4.9.2 and 4.9.3. Exposure pathways used to assess 18 dose to the public and biota other than humans are discussed in EIS Sections 5.9.1 and 5.9.5.

19 Potential cumulative impacts of the radiological impacts of normal operations will be addressed 20 in EIS Section 7.8.

21 Comment: One thing, when you have that documentation in the Oak Ridge Library, you should 22 also have I can recommend a copy of the previous settlement. There was an environmental 23 statement I don't know how many decades ago for Clinch River. That would be useful to 24 compare it to in terms of the subtleties that go to the safety assessment. I don't know what 25 goes into the departmental [environmental] impact statements, but, you know, some things, if 26 you are looking at potential radiological releases, you should look at things like weather.

27 (0002-6-1 [Martin, Rodger])

28 Response: The staff agrees that the Final Environmental Statement related to the Construction 29 and Operation of the Clinch River Breeder Reactor Plant, dated February1977 (NRC 1977-30 TN5083), may be a useful document to support this review. Radiological impacts from 31 construction and operation of the CRN Site will be addressed in EIS Sections 4.7 and 5.9, while 32 cumulative impacts will be discussed in Section 7.8.

33 D.2.15 Comments Concerning Nonradiological Waste 34 Comment: According to the TVA CRN ESP Application Part 3 - Environmental Report, the 35 CRN Site SMR is expected to be a Small Quantity Generator (SQG) of Hazardous Waste and 36 will also construct and operate an on-site landfill9 for construction/demolition wastes. Any 37 nonradioactive hazardous and nonhazardous wastes associated with the construction, 38 operation, and decommissioning of the CRN facility as well as construction of an on-site landfill 39 must be handled in accordance the state's Solid and Hazardous Waste Rules and 40 Regulations.10 Furthermore, mixed wastes (e.g. containing low-level radioactive waste) with a 41 hazardous component must be handled in accordance with the NRC requirements but also with 42 the aforementioned Rules and Regulations. TDEC recommends that waste management 43 considerations as specifically regulated by the Rules and Regulations of the state of Tennessee 44 be incorporated in the forthcoming NRC EIS.

45 [footnotes:]

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1 9 If TVA wishes to construct and operate a solid waste disposal facility (i.e.,

2 construction/demolition landfill) at the CRN Site they will be required to obtain a landfill permit 3 from the TDEC Division of Solid Waste Management. Information about the permitting process 4 and required application materials can be found at http://www.tn.gov/environment/article/permit-5 waste-landfill-permit.

6 10 Reference TDEC SWM Rule 0400 Chapter 11 for Solid Waste and Chapter 12 for Hazardous 7 Waste http://sos.tn.gov/effective-rules. (0043-5 [Abkowitz, Kendra])

8 Comment: Sections 3.6 and 5.5 of the Environmental Report describe the various hazardous 9 and nonhazardous waste streams that are expected to be generated as well as their impacts 10 and procedures for management (e.g. Spill/Discharge Response Program, TVA-approved 11 vendors for transport and disposal, a Waste Minimization Plan). While this information is 12 informative, TDEC recommends further discussion of specific hazardous and mixed waste 13 management and monitoring practices, treatment methods, and storage areas for attaining 14 compliance with the state and limiting adverse environmental impacts and irreversible 15 environmental commitments during construction and operation of the facility and its offsite rail, 16 barge terminal, and underground transmission line improvement projects in the forthcoming 17 NRC EIS. (0043-6 [Abkowitz, Kendra])

18 Response: Nonradiological waste impacts due to the construction and operation of the CRN 19 Site will be addressed in Sections 4.10 and 5.10 of the EIS. Cumulative impacts will be 20 addressed in Section 7.9. Permits and authorizations for the CRN Site will be addressed in 21 Appendix H.

22 D.2.16 Comments Concerning Accidents - Severe 23 Comment: Contention 2 challenges TVA's failure to address the environmental impacts of 24 accidents involving ignition of spent fuel in the spent fuel storage pool(s) at the proposed SMR.

25 There is no question that the consequences of such accidents could be catastrophic, but TVA 26 has failed to show or even assert that the likelihood of such an accident is remote and 27 speculative. Therefore, the Environmental Report violates the National Environmental Policy 28 Act ("NEPA") by failing to address the environmental impacts of a spent fuel storage pool fire.

29 The NRC Staff should ensure that this deficiency is corrected in the EIS for the proposed Clinch 30 River Site ESP. (0052-1 [Curran, Diane])

31 Comment: Contention 1 raises safety issues under NRC regulations for the implementation of 32 the Atomic Energy Act. (0052-3 [Curran, Diane])

33 Comment: Contention 1 challenges TVA's application for an exemption from NRC's 34 emergency planning requirements with respect to the establishment of ten-mile emergency 35 planning zone ("EPZ"). As demonstrated in the contention, TVA has failed to justify its proposal 36 to reduce the size of the EPZ to the site boundary, or in the alternative a two mile radius. (0052-4 37 [Curran, Diane])

38 Comment: Contention 2 challenges TVA's failure to address the environmental impacts of 39 accidents involving ignition of spent fuel in the spent fuel storage pool(s) at the proposed SMR.

40 There is no question that the consequences of such accidents could be catastrophic, but TVA 41 has failed to show or even assert that the likelihood of such an accident is remote and 42 speculative. Therefore, the Environmental Report violates NEPA by failing to address the 43 environmental impacts of a spent fuel storage pool fire. (0052-5 [Curran, Diane])

D-30

1 Comment:

2 Contention 1: Inadequate Emergency Plan 3 1. Statement of the Contention: The Emergency Plan in the ESP application for the Clinch River 4 SMR is inadequate to satisfy 10 C.F.R. §52. l 7(b)(2) because the size of the proposed plume 5 exposure Emergency Planning Zone ("EPZ") is less than the minimum ten-mile radius required 6 by 10 C.F.R. §50.47(c)(2) for most nuclear power reactors. While TVA claims to qualify for an 7 exemption from 10 C.F.R. §50.47(c)(2) "due to the decreased potential consequences 8 associated with such a facility" (ESP Application, Part 6 at 1), TVA has not demonstrated that it 9 satisfies the NRC Staffs criterion for such an exemption with respect to the potential for a spent 10 fuel storage pool fire. As provided in an NRC guidance document that has been consistently 11 applied to exemption applications, the Staff will not approve an exemption to offsite emergency 12 planning requirements unless the applicant can demonstrate that the time between uncovering 13 of spent fuel and initiation of a zirconium fire in the spent fuel storage pool is ten hours or more.

14 Preliminary Draft, Regulatory Improvements for Power Reactors Transitioning to 15 Decommissioning at A-1 (RIN # 3150-AJ59, NRC Docket# NRC-2015-0070, 2015) ("Draft 16 Guidance for Decommissioning Reactors") (NRC ADAMS Accession No. ML16309A332). 1 17 Therefore, for consistency with this principle, in order for TVA to qualify for an exemption from 18 the ten-mile EPZ, TVA should have to demonstrate for the spent fuel storage pool(s) to be 19 located at the proposed site that in the event of a loss of cooling and adiabatic heating 20 conditions (i.e., conditions in which a range of factors may prevent heat from leaving individual 21 fuel assemblies or spent fuel racks), at least ten hours would elapse before a zirconium fire 22 would be initiated. Such an analysis would depend on fuel design features, as well as 23 operational factors that are not specified in the ESP application. If this information is not 24 available or not sufficiently well-defined to enable a technically sound analysis that could 25 plausibly demonstrate the condition is met with adequate margin, TVA's exemption request 26 should be rejected without prejudice and TVA should be advised to re-submit it at the COL 27 stage.

28 [footnote:]

29 1 In reliance on the Draft Guidance for Decommissioning Reactors, the NRC has issued 30 exemptions from emergency planning requirements for numerous reactors, including 31 Kewaunee, Crystal River, San Onofre, and Vermont Yankee. See Memorandum from Stephen 32 S. Koenick to William M. Dean re: Transition to Decommissioning Lessons Learned Report 33 (Oct. 28, 2016) (ADAMS Accession No. ML16176A339). (0052-7 [Curran, Diane])

34 Comment: 2. Brief Summary of Basis for the Contention: While detailed emergency plans are 35 not required for ESP applications, NRC regulation 10 C.F .R. § 52.17(b)(2) provides ESP 36 applicants with the option to submit emergency plans for approval by the NRC. As part of its 37 ESP, TVA has submitted two alternative emergency plans -one with an EPZ that conforms to 38 the site boundary (Part 5A of the ESP application) and the other with a two-mile EPZ (Part B of 39 the ESP application). Part 6 of TVA's ESP application consists of a request for an exemption 40 from the ten-mile EPZ requirement in 10 C.F.R. §§ 50.33(g), 50.47(b), and 50.47(c)(2).

41 As demonstrated in Draft Guidance for Decommissioning Reactors, the NRC considers pool 42 fires to constitute contributors to the accident risk that must be protected against through the 43 emergency planning process. Id. at A-1. In Part 6, entitled "Exemptions and Departures," TVA 44 asserts that an EPZ extending beyond the site boundary (or, alternatively, a two-mile radius) is 45 not necessary to achieve the purpose of NRC's emergency planning regulations because "there 46 are no offsite consequences from any credible event in excess of the [U.S. Environmental D-31

1 Protection Agency Protective Action Guidelines]." Id., Table 1-1. But TVA completely fails to 2 discuss any SMR design features that would decrease the potential for spent fuel pool fires to 3 result in significant off-site radiological releases.

4 The Draft Guidance for Decommissioning Reactors advocates the allowance of relaxation of the 5 ten-mile EPZ requirement for decommissioning reactors on the ground that after a reactor has 6 shut down and spent fuel has cooled for a period of years, the time between uncovering of 7 spent fuel and ignition of spent fuel zirconium cladding (assumed to occur when the cladding 8 temperature reaches 900°C) in a spent fuel storage pool increases to at least ten hours. Id.

9 This guidance is based in tum on NUREG-1738, Technical Study of Spent Fuel Pool Accident 10 Risk at Decommissioning Nuclear Power Plants (2001) (ADAMS Accession No. ML13251A342).

11 For operating plants, the NRC has demonstrated that cladding temperatures can reach 900°C 12 (1173 K) in less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months for certain accident scenarios. NUREG-2161, Consequence 13 Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a US Mark I 14 Boiling Water Reactor at 132-33 (2014) (ADAMS Accession No. ML13297070) ("Consequence 15 Study").

16 In the case of an operating SMR or other type of reactor, recently discharged hot spent fuel is 17 loaded periodically into the spent fuel pool. In the case of multiple modules that share one 18 spent fuel pool, like the NuScale SMR design, this could happen as often as every two months 19 or even more frequently, depending on the number of modules and the fuel management 20 strategy. As a result, the time between uncovering of spent fuel and ignition could be 21 significantly less than ten hours.

22 It is well established that significant radiological consequences of a pool fire could extend 23 beyond the site boundary, and for that matter well beyond a ten-mile EPZ. Consequence Study 24 at 169 (reporting that 4 million people could be displaced out to 500 miles). In the NRC's 25 License Renewal Generic Environmental Impact Statement, the NRC also concluded that the 26 environmental impacts of a pool fire are "comparable to those from the reactor accidents at full 27 power." NUREG-1437, Generic Environmental Impact Statement for License Renewal of 28 Nuclear Plants at 1-28 (2013). The potential for reactor accidents to have significant adverse 29 public health effects within at least a ten-mile radius --including early and latent fatalities --is 30 discussed in NRC's emergency planning guidance documents. See NUREG-0396, Planning 31 Basis for the Development of State and Local Government Radiological Emergency Response 32 Plans in Support of Light Water Nuclear Power Plants (1978) and NUREG-0654/FEMA-REP-l, 33 Rev. 1, Criteria for Protective Action Recommendations for Radiological Emergency Response 34 Plans and Preparedness in Support of Nuclear Power Plants (1980). Thus, before an 35 exemption from the ten-mile EPZ requirement in NRC's emergency planning regulations may be 36 approved, TVA should be required to demonstrate that the time between uncovering of spent 37 fuel and ignition of spent fuel is comparable to a spent fuel pool at a decommissioning reactor, 38 i.e., greater than ten hours.

39 The information provided by TVA should be sufficiently detailed to allow the NRC Staff, the 40 parties and the Atomic Safety and Licensing Board ("ASLB") to independently verify TVA's 41 representations. It appears doubtful that TVA will be able to supply the NRC with that 42 information, given that (a) TVA has not yet chosen a design for the proposed SMR, (b) only one 43 design (NuScale) has been submitted to the NRC, and (c) even the NuScale design has not 44 been reviewed or approved by the NRC, and is still in the early stages of review. If that is the 45 case, the NRC should reject TVA's exemption application without prejudice, and allow it to be 46 resubmitted at the COL stage.

D-32

1 3. Demonstration that the Contention is Within the Scope of the Proceeding: This contention is 2 within the scope of this ESP proceeding because it raises an issue of compliance with NRC 3 safety regulations for issuance of an ESP.

4 4. Demonstration that the Contention is Material to the Findings NRC Must Make to issue an 5 ESP for the proposed TVA SMR: The contention is material to the findings that NRC must 6 make in order to issue an ESP for the proposed TVA SMR because it seeks to ensure that TVA 7 fulfills NRC's emergency planning regulations with respect to the size of the EPZ. (0052-8 8 [Curran, Diane])

9 Comment:

10 Contention 2: Failure to Address Consequences of Pool Fires 11 1. Statement of the Contention: The Environmental Report fails to satisfy NEPA because it does 12 not address the consequences of a fire in the spent fuel storage pool, nor does it demonstrate 13 that a pool fire is remote and speculative.

14 2. Brief Summary of Basis for the Contention: The consequences of spent fuel pool fires must 15 be considered in any environmental analysis of the impacts of reactor operation, because the 16 NRC has not ruled out their likelihood as remote and speculative. State of New York v. NRC, 17 681F.3d471, 483 (D.C. Cir. 2012). See also NUREG-1437, Generic Environmental Impact 18 Statement for License Renewal of Nuclear Plants at 1-28 (2013) ("License Renewal GEIS")

19 (concluding the environmental impacts of pool fires are "comparable to those from the reactor 20 accidents at full power."). TVA claims that the design of the spent fuel storage pool(s) for the 21 proposed SMR has "spent fuel pool cooling without the need for active heat removal."

22 Environmental Report at 9.3-2. But the Environmental Report does not state that the cooling 23 system renders pool fires remote and speculative.

24 As discussed in Contention 1, it is well established that the radiological consequences of a pool 25 fire are potentially catastrophic. For instance, radioactive fallout from a pool fire could displace 26 as many as 4 million people out to 500 miles. Consequence Study at 169. The potential for 27 reactor accidents to have significant adverse public health effects within at least a ten-mile 28 radius --including early and latent fatalities --is also discussed in NRC's emergency planning 29 guidance documents. See NUREG-0396, NUREG-0654. In the License Renewal GEIS, the 30 NRC also concluded that the environmental impacts of a pool fire are "comparable to those from 31 the reactor accidents at full power." Id. at 1-28 (2013).

32 Therefore, in the absence of a documented and supported assertion that the potential for a pool 33 fire is remote and speculative, TVA must address the consequences of a pool fire in its 34 Environmental Report.

35 3. Demonstration that the Contention is Within the Scope of the Proceeding: This contention is 36 within the scope of this ESP proceeding because it seeks consideration of the consequences of 37 a type of severe accident that NRC views as reasonably foreseeable and therefore must 38 address in the EIS for the proposed ESP.

39 4. Demonstration that the Contention is Material to the Findings NRC Must Make to issue an 40 ESP for the proposed TVA SMR: The contention is material to the findings that NRC must make 41 in order to issue an ESP for the proposed TVA SMR because it relates to the question of 42 whether TVA has addressed all reasonably foreseeable impacts of operating an SMR in its D-33

1 Environmental Report, as required by NEPA. State of New York, 681 F.3d at 483. (0052-9 2 [Curran, Diane])

3 Response: The commenter's scoping comments were submitted to the NRC as part of a 4 separate hearing process. Please refer to ML17188A445 for the NRC staff's response to 5 the comments.

6 Comment: The EIS should go in detail with beyond design basis accidents. That's major 7 accidents where loss of coolant creates situations where massive amounts of radiation can be 8 released. The industry is wanting to say that these -- that can never happen. That was said 9 back in the '70s and '80s. I was there -- a critic then. And they said you could never have a 10 major loss of coolant accident and a major release of radiation. That was before Fukushima, of 11 course, and Fukushima proved that to be tragically wrong. And it almost happened at Three 12 Mile Island, but that containment held for the most part. Although people that live there say --

13 many people have stories of -- of tragedies after Three Mile Island because of radiation 14 exposure. So usually these environmental impact statements do not go into the details about 15 the beyond-design basis accident because they wouldn't build them if they really went into those 16 details. But I think it's a -- a travesty that these things aren't considered -- those types of 17 accidents. It's my understanding that the EIS is going to go into the problems. If you have one 18 of these reactors goes bad, well, the NuScale design, which is the only one that is on the books 19 now as being considered, can have up to 12 50-megawatt reactors. And in the same pool with 20 the spent fuel, all of that underground in a pool of water. If you start having one reactor go 21 seriously bad -- and you know, the industry will say, well, these are going to have passive 22 design where you can't have a -- a major meltdown, blah, blah, blah. Well, that was told us 30 23 years ago, 40 years ago when the GE Mark 1s, on the -- on the ice condenser designs. This is 24 all theoretical and the industry try and put their best face on it, but we need -- we've learned, I 25 hope, with nuclear energy we have to be prepared for the worst consequences because they 26 can happen even if they are unthinkable, they are happening now. Fukushima is still happening 27 now. So the effects of multiple cascading reactor failures and spent fuel burning due to the 28 emptying of that pool need to be considered in the environmental impact statement. (0001-5-7 29 [Safer, Don])

30 Comment: And I don't know what goes into a radiological release under accident conditions 31 when they do the site assessment. That would be good to look at..... One newspaper report 32 indicated that the Fukushima accident could never happen; that scenario could never happen.

33 So, we need to be practical. I'm not afraid of any of this stuff. I'm a nuclear engineer. But 34 sometimes we don't always look at things we should. (0002-6-5 [Martin, Rodger])

35 Response: EIS Chapter 5 will include an evaluation of the risks associated with potential 36 severe accidents. The evaluation will also include estimates of health and economic risk to a 37 distance of 50 miles from exposure to the plume and from exposure to contaminated land and 38 water.

39 D.2.17 Comments Concerning the Uranium Fuel Cycle 40 Comment: The spent fuel -- the impact of long-term storage needs to be considered in the EIS.

41 The failure of the planning -- the zirconium planning is being studied right now in Oak Ridge, just 42 now, for high burnup fuel. It's never been studied before. What's been studied is the low burnup 43 fuel. That's not what we're dealing with in this industry anymore. The burnup of -- of -- the -- I 44 don't know how they can know this, because they don't know the reactors of design, but in the --

45 the documents there was a talk of somewhere around 40 to 50 gigawatt days per metric ton.

D-34

1 The -- the crazy number they have for burnup, but -- measure for burnup. But the high burnup 2 fuel and the storage of that needs to be taken into account, and the possible impacts of that fuel 3 breaking containment through either the failure of the cladding, the failure of the pool, the failure 4 of the canisters over time -- the canisters are just thin-walled, half-inch stainless steel. And 5 there's been some indications recently that they are not -- they may not last as long as any of us 6 wants to -- think that they're going to last. That needs to be put into the environmental impact 7 statement. (0001-5-10 [Safer, Don])

8 Comment: And just like existing nuclear power plants, they produce long-lived, highly 9 radioactive nuclear waste for which no safe management and permanent storage exists. (0005-3 10 [McBride, Geoff] [McBride, Linda] [Sprignoli, Damon] [Turk, Lawrence "Butch"]) (0005-7 [McBride, Geoff]

11 [McBride, Linda] [Sprignoli, Damon] [Turk, Lawrence "Butch"])

12 Comment: They are expensive. They generate high-level waste which we do not know what to 13 do with in the US. (0006-2 [Sutlock, Dot])

14 Comment: It [nuclear power] also produces highly radioactive nuclear waste. SMRs need 15 disposal sites to contain this highly radioactive waste, but there is no safe management and no 16 safe permanent storage for this waste. (0007-3 [McFadden, Nancy])

17 Comment: I am concerned about not only the cost, but mainly the long-lived radioactive 18 nuclear waste, which there is no known way to store safely. (0014-2 [Holt, Cathy])

19 Comment: Also, I understand that this site will employ small modular reactors SMR). There 20 are no well tested and proven designs for SMR's. SMRs produce extremely toxic, highly 21 radioactive and long-lived nuclear waste for which no safe, long term management exists.

22 SMRs could greatly complicate the disposal of nuclear waste. The use of SMRs would increase 23 the number of designated locations for radioactive nuclear waste in the world, making it harder 24 to control, track and manage. (0021-4 [Harland, Donald])

25 Comment: A reactor that produces long-lived and highly radioactive nuclear waste that 26 threatens its down-wind neighbors....is just not wise. (0025-2 [Kirkman, Arden])

27 Comment: I do not live near the site or own property near the site, but I have worked 28 intermittently on problems with radioactive waste management and groundwater monitoring in 29 the Oak Ridge area for many years. My first concern comes both from my involvement with 30 attempts to resolve a number of issues with on-site management of low level radioactive waste 31 in Oak Ridge and an awareness of the difficulties encountered in attempts made to date to 32 manage transuranic waste, high level radioactive waste, and spent nuclear fuel. There have 33 been decades of work toward establishing an adequate disposal facility for high level radioactive 34 waste and spent nuclear fuel in the United States, yet little progress has been made toward 35 consensus of how and where this material can be safely disposed for the duration of the hazard.

36 Until some significant steps toward resolution of the waste disposal issues have been made, 37 expansion of nuclear power seems unwise. (0031-1 [Jones, Sid])

38 Comment: We do not need to be using money for a risky venture into unproven nuclear power 39 when we have no way to safely dispose of the waste which will remain dangerous for thousands 40 of years. We do not need to pollute the plane[t] and endanger ourselves and future 41 generations. (0048-1 [Hyche, Kenneth])

D-35

1 Response: These comments are concerned with continued storage and long-term disposal of 2 high-level waste. While a repository for final disposal of spent nuclear fuel has yet to be 3 constructed, the Commission has, through rulemaking, considered the environmental impacts of 4 spent fuel disposal in light of the current national policy regarding spent fuel. As directed by 10 5 CFR 51.23(b) (TN250), the impacts assessed in NUREG-2157 (NRC 2014-TN4117) are 6 deemed incorporated into this EIS in Section 6.1.6. Section 6.1.6 also explains that current 7 national policy mandates that high-level and transuranic wastes are to be buried at deep 8 geologic repositories and that no release to the environment is expected to be associated with 9 deep geologic disposal.

10 Comment: A major issue with nuclear facilities is the disposal of radioactive waste products.

11 NRC may want to consider an economic feasibility comparison study for vitrification of waste 12 products verses current storage and disposal practices as part of the EIS. (0026-3 [Long, Larry])

13 Response: An economic feasibility comparison study for vitrification of waste products versus 14 current storage and disposal practices is outside the scope of this EIS, and this comment does 15 not provide specific information related to the environmental effects of the proposed action.

16 D.2.18 Comments Concerning the Need for Power 17 Comment: TVA's 2015 Integrated Resource Plan for a 20-year long term energy plan that the 18 Southern Alliance for Clean Energy is closely working on showed that the utility did not succeed 19 any new base load generation beyond Watts Bar 2, and possible -- and the possible extended 20 power up rate at the three Browns Ferry Reactors. TVA did not include a need for power 21 analysis that is typically part of the environmental report in the ESP application. We are 22 concerned that was not included because it has been based on the outcome of the 2015 IRP, 23 TVA would not be able to demonstrate to the NRC a need for SMRs even 20 years from now.

24 Why spend tens of millions of dollars on a licensing process for something that is not even 25 needed? The NRC needs to conduct a full need-for-power analysis for this draft EIS, not punt 26 the essential review to the combined operating license stage. The NRC must not hide behind 27 the purported need as stated in TVA's ESP application to provide secure power to the DOE 28 facilities such as Oak Ridge National Lab. TVA repair money is being wasted on something that 29 is not needed. (0001-4-3 [Powell, Michelle])

30 Comment: The -- I second what's been said about having a need for power. That really needs 31 to be considered now. It's -- it's -- inexcusable to push that -- to spend the $70 million of 32 taxpayer money and TVA money when the power -- the technology -- TVA will not build the 33 power. And with the renewables coming online, it's likely they will never need power from these 34 SMRs. (0001-5-6 [Safer, Don])

35 Comment: AND they are not needed. We are not facing any energy shortage and if we 36 continue to make progress in conservation and clean, renewable energy, there is no reason to 37 expect that we will be.

38 This is a dangerous, expensive, wasteful boondoggle, using tax payer money to profit the 39 companies that manufacture these reactors and allowing them to test an experimental product 40 at our expense and risk. (0051-12 [Anthony, Kate])(0051-6 [Anthony, Kate])

41 Response: The action before NRC is the issuance of an ESP to determine whether the CRN 42 Site is environmentally suitable for placement of one or more SMRs. The ESP determination is 43 primarily a siting decision; in accordance with 10 CFR 51.50 (TN250), the applicants ER need D-36

1 not include an assessment of the need for power or of alternative energy sources. In 2 accordance with 10 CFR 51.75 (TN250), the ESP EIS will not include an assessment of the 3 need for power or an evaluation of alternative energy sources because these matters were not 4 addressed in the applicants ER.

5 If TVA were to apply for a construction permit or combined license at some time in the future, 6 the environmental review of that application would include an assessment of the need for 7 power. The review of that application would include the development of another EIS and the 8 opportunity to participate in another hearing.

9 D.2.19 Comments Concerning Alternatives - No-Action 10 Comment: I believe that if you are going to bring in considerations of the environmental impact, 11 the NRC should likewise consider the impacts of the alternative sources that would likely be 12 built in the event the site is not built. I would point out that while TVA recently completed Watts 13 Bar Unit 2, the predominant share of TVA's new electricity generation has not been renewables.

14 It has been natural gas.

15 The TVA in the last 15 years has replaced hundreds of megawatts of coal capacity almost 16 exclusively with natural gas. In that sense, then, I believe the avoided emissions from a nuclear 17 unit should be considered a bounding part of the scope. That this is -- this would inherently 18 result in a -- a net void emissions even with a substantial share of renewable capacity given the 19 requirements for natural gas back up. In as much, I believe, that the early site permit should 20 consider the countervailing environmental effects of pursuing this project. (0001-10-5 [Skutnik, 21 Steve])

22 Comment: And finally, perhaps I'm hoping that the scoping will list some alternative uses 23 because there are many other things that that forest --and it is a forested area --could be used 24 for. And probably the best thing would be no action at all because the climate change issues 25 that we need to address, then the forest. But it's hard to see the forestation action that it 26 provides free of charge would be perhaps the best use of all. (0002-2-14 [Kurtz, Sandy])

27 Comment: But I want to bring up, a lot of people brought up the issue of a no-action scenario.

28 And I think this is actually really important to go back to this. I agree that the no-action scenario 29 should be considered. I want to present some statistics.

30 TVA's generating portfolio generation capacity, 2012, was about 34 percent nuclear, 32 percent 31 coal, 9 percent hydro, 11 percent natural gas. Today it is about 37 percent nuclear, 24 percent 32 coal, 20 percent natural gas, 9 percent hydro, 3 percent wind and solar, and 7 percent of what is 33 termed "energy-efficiency".

34 There is something I want to highlight in these numbers; that while we have a moderate 35 increase in the nuclear generation capacity from the completion of Watts Bar Unit 2, the largest 36 and most substantial growth in TVA's electricity-generating portfolio has not been nuclear 37 energy; it has not been renewables; it has not been hydroelectric power. It is the natural gas.

38 The no-action scenario inherently will mean, with the growth in electricity demand, this means 39 displacing zero carbon-emitting sources for carbon-emitting sources. There is no way around 40 this. So, therefore, then, a no-action scenario should consider the environmental impacts of 41 likely alternative sources of generation that will be constructed in the absence of this source.

42 (0002-5-4 [Skutnik, Steve])

D-37

1 Comment: In considering alternatives, the agency must examine the alternative of no action.

2 10 C.F.R. §51.104(a). (0052-19 [Curran, Diane])

3 Response: The no-action alternative will be evaluated in Section 9.1 of the EIS with respect to 4 the purpose and need as it is defined in Section 1.3 of the EIS. Energy alternatives are not 5 required to be evaluated for an ESP. Because TVA has chosen not to evaluate energy 6 alternatives in its ER, the NRC staff will not evaluate energy alternatives in its EIS. If TVA were 7 to apply for a construction permit or combined license at some time in the future, the 8 environmental review of that application would include an assessment of energy alternatives.

9 D.2.20 Comments Concerning Alternatives - Energy 10 Comment: Contention 3 -Impermissible Discussion of Energy Alternatives and Technical 11 Advantages 12 1. Statement of Contention: The ESP application violates the National Environmental Policy Act 13 ("NEPA"), 42 U.S.C. § 4321-4370f, and NRC implementing regulations because it contains 14 impermissible language comparing the proposed SMR to other energy alternatives and 15 discussing the economic and technical advantages of the facility. The language is 16 impermissible because TVA has explicitly invoked 10 C.F.R. §5 l.50(b )(2), which excuses it 17 from discussing the economic, technical, or other benefits of the proposed facility such as need 18 for power. See Environmental Report, Chapter 8 (postponing need for power discussion),

19 Environmental Report Section 9.2 (postponing energy alternatives discussion).2 By formally 20 choosing to exclude consideration of alternatives from its Environmental Report, TVA has 21 effectively precluded Petitioners from submitting contentions on those subjects.

22 Under the circumstances, TVA must restrict the content of the Environmental Report to the 23 impacts of construction and operation and a limited evaluation of alternatives related solely to 24 the selection of the site. Any language comparing the proposed SMR to other energy 25 alternatives, or purporting to justify the need for the SMR, should be stricken from the 26 Environmental Report.

27 Furthermore, such language should not be included in the NRC's Environmental Impact 28 Statement ("EIS") for the proposed ESP. Such an EIS would end up becoming an advertisement 29 for SMRs rather than the rigorous, unbiased and independent scientific study required by NEPA.

30 Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 348 (1989); National Audubon 31 Society v. Dep't of Navy, 422 F.3d 174, 185 (4th Cir. 2005); 40C.F.R.§1500. l(b).

32 In the alternative TVA may elect to address energy alternatives and need for power in the 33 Environmental Report. In that case, fairness requires that Petitioners must be provided a 34 reasonable opportunity to submit contentions on the new alternatives analysis.

35 Title 10 of the Code of Federal Regulations 51.50(b)(2) does not require a need for power 36 discussion be included in an early site permit application. The need for power discussion is to 37 be included in the combined license application.

38 See also Environmental Report, Section 9.2, "Energy Alternatives." The "Energy Alternatives" 39 section is a blank page because "[t]his section is not required for an Early Site Permit 40 Application." Id. at 9.2-1.

41 [footnote:]

42 2 See Environmental Report at 8-1 (0052-10 [Curran, Diane])

D-38

1 Comment: b. Comparison of alternatives in TVA's ESP application 2 In its ESP application, TVA has chosen not to address the issues of energy alternatives or need 3 for the proposed SMR, and has instead postponed those issues to the Combined Operating 4 Licensing ("COL") stage. See Environmental Report, Chapter 8 (postponing need for power 5 discussion), Environmental Report Section 9.2 (postponing energy alternatives discussion).

6 Although the first paragraph of the "Purpose and Need" statement (Section 1.1.1) appropriately 7 defines the purpose and need for issuance of the ESP in the limited manner prescribed by NRC 8 regulations (i.e., "to provide for resolution of site safety and environmental issues, which 9 provides stability in the licensing process"), Chapter 1 of the Environmental Report is brimming 10 with claims that SMR technology is preferable to other energy technology on a host of issues, 11 including safety, security, reliability, carbon reduction, water use, and economies of scale. And 12 in Chapter 9, TVA's discussion of the "no action" alternative, TVA laments that all of these 13 asserted advantages of SMRs would be lost if TVA did not receive an ESP.

14 For instance, TVA promotes "SMR technology" as preferable for serving federal facilities: The 15 SMR technology is designed with inherent enhanced safety and security features. SMR 16 deployment will demonstrate that the technology is capable of incrementally supplying clean, 17 secure, reliable power that is less vulnerable to disruption to facilities owned by federal agencies 18 (e.g., U.S. Department of Energy (DOE), U.S. Department of Defense (DoD), TVA, etc.).

19 Environmental Report at 1-1. TVA asserts that building an SMR "near federal facilities" could 20 provide "enhanced reliability and other benefits, by providing continued operation during a 21 widespread and extended loss of the electrical power grid, meeting reliability needs with clean 22 energy that supports carbon reduction directives." Id. at 1-2. TVA also compares SMRs 23 favorably to coal, to "assist federal facilities with meeting carbon reduction objectives." Id. at 1-3.

24 To support its claims regarding the special suitability of SMRs to supply electricity to federal 25 facilities, TVA invokes the imprimatur of DOE:

26 DOE expressed its support to TVA for the development and licensing of SMRs as a means to 27 meet DOE goals of improving the environmental, economic, and energy security outlook for the 28 United States (Reference 1-5). DOE believes that SMR deployment near federal facilities could 29 provide enhanced reliability and other benefits, by providing continued operation during a 30 widespread and extended loss of the electrical power grid, meeting reliability needs with clean 31 energy that supports carbon reduction directives. DOE specifically requested TVA to assess, as 32 a part of the deployment project planning and licensing process, the ability of SMRs to continue 33 to supply electricity to nearby offsite customers during a disruption to offsite power supplies.

34 This includes electricity transmission to those customers in a manner less vulnerable to 35 intentional destructive acts and natural phenomena that could disrupt the power supply.

36 Environmental Report at 1-2.

37 TVA also asserts that SMRs have certain benefits in relation to light water reactors ("LWRs"):

38 SMRs provide the benefits of nuclear-generated power in situations where large nuclear units, 39 with an approximate electrical output exceeding 1000 MWe, are not practical, because of 40 transmission system constraints, limited space or water availability, or constraints on the 41 availability of capital for construction and operation. Environmental Report at 1-l. See also id at 42 1-4 ("SMRs may provide the benefits of nuclear-generated power in situations where large 43 nuclear units are not practical ...").

D-39

1 Further, TVA claims that an SMR would serve national security needs: Power generated by 2 SMRs could be used for addressing critical energy security issues. Their use on or immediately 3 adjacent to DoD or DOE facilities, using robust transmission (e.g., armored transformers, 4 underground transmission), could address national security needs by providing reliable electric 5 power in the event of a major grid disruption. A more reliable electric power supply could be 6 accomplished by the SMR operation in "power island" mode with robust transmission to critical 7 facilities. In addition, intentional destructive acts (e.g., terrorist attacks) and natural phenomena 8 (e.g., tornadoes, floods, etc.) could disrupt the grid and the ability to restore most generation 9 sources." Id. at 1-2.

10 In addition, TVA favorably compares the reliability SMRs to renewable energy sources, 11 asserting that SMRS: can provide reliable energy for extended operation. Because nuclear 12 reactors require fuel replenishment less frequently than other power generation sources (coal, 13 gas, wind and solar), SMRs are less vulnerable to interruptions of fuel supply and delivery 14 systems.

15 TVA could demonstrate this "power islanding" and secure supply concept as part of the [Clinch 16 River] SMR project by utilizing controls, .switching, and transmission capabilities to disconnect 17 the SMR power plant from the electrical grid while maintaining power from the SMR power plant 18 to a specified DOE power need. Such a demonstration would show that SMR technology is 19 capable of supplying reliable power that is less vulnerable to disruption from intentional 20 destructive acts and natural phenomena. Id. at 1-2. Finally, TVA asserts that SMRs are 21 preferable to other reactor designs for their safety features: SMR design features include 22 underground containment and inherent safe-shutdown features, longer station blackout coping 23 time without external intervention, and core and spent fuel pool cooling without the need for 24 active heat removal. These key features advance safety by eliminating several design basis 25 accident scenarios. Development of a security-informed design efficiently provides the same or 26 better protection against the threats large reactors must consider. Physical security is designed 27 into the SMR plant architecture, incorporating lessons learned from significant shifts in security 28 posture since 2001, and the opportunity to build more inherently secure features into the initial 29 design.

30 In Chapter 7, TVA also compares SMRs favorably to other reactors with respect to accident 31 risks.

32 In Section 9.1, TVA once again introduces impermissible energy alternative considerations by 33 describing the disadvantages of the "no-action alternative" as the lack of the supposed benefits 34 described above, as well as the failure to create "new jobs" or to realize the "technological and 35 financial benefits to the local, community Tennessee Valley, and the nation that would result 36 from the construction of the fist-of-its-kind SMRs." Id. at 9.1-1-9.1-2. Similarly, TVA includes the 37 same set of inappropriate energy-related alternatives in its discussion of alternative sites in 38 Section 9.3. Id. at 9.3-2-9.3-3. (0052-13 [Curran, Diane])

39 Comment: c. TVA's comparisons of SMRs with other technologies are unlawful 40 TVA's claims regarding the favorable comparison of SMRs with other energy alternatives must 41 be stricken from the Environmental Report, and may not be included in the EIS for the ESP, 42 because TVA has waived the right to make them by choosing not to address energy alternatives 43 or the need for power in the Environmental Report. Id., Chapter 8 and page 9-2. In addition, 44 TVA's claims regarding energy-related alternatives should be stricken in fairness to Petitioners, D-40

1 because Petitioners are precluded from raising issues related to energy alternatives and need 2 for power by virtue of TVA's decision not to formally address those alternatives.

3 TVA's claims regarding energy alternatives are not only impermissible, but they are 4 unsupported; some are even nonsensical. Thus, to allow them to remain, unchallenged, would 5 reduce the Environmental Report to an advertisement for SMRs, without support or verification, 6 and without providing the context of a comprehensive environmental analysis. For instance:

7 The Environmental Report lacks a thorough comparison of SMRs with other energy 8 technologies. TVA makes selective comparisons of SMRs with other energy technologies, 9 but does not provide a comprehensive comparison. For instance, TVA compares SMRs 10 with coal, gas, wind and solar on the factor of reliability. Environmental Report at 1-2. But it 11 does not make a comprehensive analysis that addresses all relevant factors, such as 12 carbon reduction, water use, air and water impacts, generation of waste products, and 13 costs.

14 The Environmental Report fails to acknowledge that solar and wind energy sources can 15 meet all the other objectives listed by TVA (carbon reduction, safety, and incremental 16 deployment), and have less deleterious environmental impacts, in particular water use. In 17 fact, the magnitude of impact on water use is listed in Table 3.1-2 of the Environmental 18 Report, which states that: "The expected (and maximum) rate of removal of water from a 19 natural source to replace water losses from closed cooling water system" are "17,078 gpm 20 (expected) [and] 25,608 gpm (maximum)." Assuming that TVA used a reactor capacity of 21 800 MW, that expected rate translates to 1,281 gallons/MW/hour. That rate of water 22 withdrawal is higher than almost any other form of electricity generation. A combined cycle 23 natural gas plant will be about a factor of four lower.3 Solar photovoltaics (PV) and wind use 24 negligible amounts of water; PV plants, for example, use about I gallon/MW/hour.

25 [footnote:]

26 3 J. Macknick et al., Operational water consumption and withdrawal factors for electricity 27 generating technologies: a review of existing literature, 7 ENVIRON. RES. LETT. 45802 (2012).

28 (0052-14 [Curran, Diane])

29 Comment: To the extent that the Environmental Report compares SMRs with other energy 30 sources on the factor of reliability, the comparison makes only partial sense. TVA asserts that:

31 "Because nuclear reactors require fuel replenishment less frequently than other power 32 generation sources (coal, gas, wind and solar), SMRs are less vulnerable to interruptions of fuel 33 supply and delivery systems." While the statement is true for coal and gas, it is irrational in the 34 case of wind and solar because they need no fuel replenishment. Renewable sources of power 35 like solar and wind are, therefore, not vulnerable to fuel disruption. Although these are 36 intermittent in nature, that concern can be addressed in a number of ways, in particular by 37 incorporating on-site energy storage technologies.

38 TVA asserts that SMR technology provides "a way to supply federal mission-critical loads with 39 reliable power from generation and transmission that is less vulnerable to supply disruption from 40 intentional destructive acts and natural phenomenon than typical commercial power generation 41 facilities and transmission systems." Environmental Report at 9.3-1. But TVA lumps generation 42 and transmission together, without justification. Reliance on SMR technology has nothing to do 43 with the security of transmission systems. In addition, TVA fails to address the United State's 44 history of unsuccessful experimentation with small reactors, which suggests that SMRs are 45 quite unlikely to be reliable sources of generating power in the first place. Prior experience that 46 is particularly important to take note of is the Army's Nuclear Power Program, which was started 47 in the 1950s, and resulted in the construction of eight small reactors. The experiences with D-41

1 these reactors reveal the potential for failure implicit with SMRs. The PM-3A reactor at 2 McMurdo Sound in Antarctica, for example, "developed several malfunctions, including leaks in 3 its primary system [and] cracks in the containment vessel that had to be welded."5 The leaks 4 from the plant resulted in significant contamination and nearly 14,000 tons of contaminated soil 5 was physically removed and shipped to Port Hueneme, a naval base north of Los Angeles, for 6 disposal. The Army eventually cancelled the program in 1976, due to poor economics as well 7 as the realization that diesel generators were a superior option for supplying power to remote 8 areas. The official history of the Army's Nuclear Power Program termed the development of 9 small reactors "expensive and time consuming."6 10 [footnotes]

11 4 M.V. Ramana, The Forgotten History of Small Nuclear Reactors, IEEE SPECTRUM, 2015, 12 http://spectrum.ieee.org/energy/nuclear/the-forgotten-history-of-small-nuclear-reactors (last 13 visited May 24, 2015); M. V. Ramana, The checkered operational history of high temperature 14 gas cooled reactors, 72 BULLETIN OF THE ATOMIC SCIENTISTS 171-79 (2016).

15 5 LAWRENCE H. Sum, THE ARMY'S NUCLEAR POWER PROGRAM: THE EVOLUTION OF 16 ASUPPORT AGENCY 111 (1990).

17 6 Suid, supra, at 93. (0052-15 [Curran, Diane])

18 Comment: In both Chapter 1 and Chapter 9, the Environmental Report asserts:

19 SMR technology can assist federal facilities with meeting carbon reduction objectives. Energy-20 related carbon dioxide (C02) emissions account for more than 80 percent of greenhouse gas 21 (OHO) emissions in the United States. Studies show that on average coal combustion 22 generates approximately 894-975 grams of C02 per kilowatt-hour (g/kWh) of electricity 23 generated. Natural gas generates an estimated 450-519 g/kWh. Nuclear power emission rates 24 have been calculated to range from 6 -26 g/kWh.

25 Id. at 1-3, 9.3-2. TVA's unsupported assertion that nuclear power emission rates have been 26 calculated to range from 6 to 26 grams per kilowatt hour is erroneous in two key respects. First, 27 independent studies suggest that there is much uncertainty about the level of emissions 28 associated with the generation of nuclear energy. A widely cited academic study shows that 29 estimates of lifecycle emissions from nuclear power plants vary by over two orders of 30 magnitude, from 1.4 to 288 g/kWh of C02, with a mean value of 66 g/kWh.7 Second, and more 31 important, SMRs require more uranium fuel for each kWh of electricity generated.8 Because of 32 their smaller size and higher area to volume ratio, SMRs will necessarily leak more neutrons 33 from the core when compared to larger reactors. As a result, SMRs need more fuel for each 34 kWh of electricity generated in comparison to the large LWRs that are most common around the 35 world, and that are the basis for the emission estimates made so far (either the 6-26 g/kWh or 36 the 1.4-288 g/kWh). Emissions of C02 associated with uranium mining, processing, and 37 enrichment are the dominant contributions to the lifecycle emissions associated with nuclear 38 power. Therefore, this increased need for fuel would result in a corresponding increase in the 39 C02 emissions per kWh.

40 [footnote:]

41 7 Benjamin K. Sovacool, Valuing the greenhouse gas emissions from nuclear power: A critical 42 survey, 36 ENERGY POLICY 2950-63 (2008).

43 8 Alexander Glaser, Laura Berzak Hopkins & M.V. Ramana, Resource Requirements and 44 Proliferation Risks Associated with Small Modular Reactors, 184 NUCLEAR TECHNOLOGY 45 12129 (2013). (0052-16 [Curran, Diane])

46 Comment: TVA claims that its SMR design improves on spent fuel pool safety by providing for 47 "spent fuel pool cooling without the need for active heat removal." Environmental Report at 1-3, D-42

1 9.3-2. But this assertion does not mention other relevant information demonstrating that SMRs 2 may require greater spent fuel storage capacity than LWRs, because they could generate a 3 larger quantity of spent fuel for each kWh of electricity generated -additional impacts that should 4 be compared with the safety benefits claimed by TVA. [See, e.g., Glaser et al., cited in note 8 5 above. For instance, TVA's calculations appear to use a burnup value of 51 gigawatt-days per 6 metric ton: of uranium ("GWD/tU"). This value is much higher than some of the reported 7 burnups of the designs of the four potential SMRs under consideration by TVA. For example, 8 the International Atomic Energy Agency lists the burnup of the Holtec SMR design as 32 9 GWD/tU.9 At this relatively low burnup, the Holtec SMR will generate more spent fuel than an 10 SMR design that has a burnup of 51 GWD/tU. In turn, this would mean that the fuel pool 11 capacity and, possibly, dry storage capacity, will have to be increased.

12 This is only a partial list of deficiencies in TVA's discussion of energy alternatives, provided for 13 purposes of illustrating the bias and lack of rigor in TVA's discussion, as further grounds for 14 Petitioners' argument that the discussion should be stricken from the Environmental Report. If 15 and when TVA decides to formally address the issue of energy alternatives in a revised 16 Environmental Report, Petitioners will review it and may submit a contention that challenges its 17 contents with a more comprehensive list of deficiencies.

18 [footnote:]9 IAEA, ADVANCES IN SMALL MODULAR REACTOR TECHNOLOGY 19 DEVELOPMENTS 89 (2014). (0052-17 [Curran, Diane])

20 Comment:

21 3. Demonstration that the Contention is Within the Scope of the Proceeding: This contention is 22 within the scope of this ESP proceeding because it seeks compliance with NEPA and NRC 23 regulations for the implementation of NEPA in ESP applications.

24 4. Demonstration that the Contention is Material to the Findings NRC Must Make to issue an 25 ESP for the proposed TVA SMR: The contention is material to the findings that NRC must make 26 in order to issue an ESP for the proposed TVA SMR because it relates to the question of 27 whether TVA's Environmental Report improperly addresses issues that TVA has determined 28 should be excluded from this ESP proceeding and therefore may not be addressed by TVA or 29 NRC and also may not be challenged by Petitioners in contentions. (0052-18 [Curran, Diane])

30 Comment: Contention 3 asserts that the Environmental Report for the proposed Clinch River 31 Site ESP is biased and unfair, because it advocates the technical advantages of SMRs as an 32 energy alternative, even though TVA formally elected not to address energy alternatives or the 33 need for power in the Environmental Report for the ESP.3 As discussed in Contention 3, when 34 an applicant elects not to address energy alternatives, the NRC follows a policy of not 35 addressing those issues, and does not take comments on those issues. Under the 36 circumstances, the NRC should not repeat or expand upon the discussion of energy alternatives 37 in the Environmental Report. To discuss energy alternatives would reduce the EIS to an 38 advertisement for SMRs instead of the rigorous, unbiased and independent scientific study 39 required by NEPA. (0052-2 [Curran, Diane])

40 [footnote:]

41 3 Contention 3 is supported by the expert declaration of Dr. M.V. Ramana, Professor and the 42 Simons Chair in Disarmament, Global and Human Security at the Liu Institute for Global Issues, 43 University of British Columbia, Vancouver, Canada.

D-43

1 Comment: Contention 3 asserts that the Environmental Report is biased and unfair, because it 2 advocates the technical advantages of SMRs as an energy alternative, even though TVA 3 formally elected not to address energy alternatives or the need for power in the Environmental 4 Report for the ESP. (0052-6 [Curran, Diane])

5 Response: The commenter's scoping comments were submitted to the NRC as part of a 6 separate hearing process. Please refer to ML17188A445 for the NRC staff's response to the 7 comments. Energy alternatives are not required to be evaluated for an ESP. Because TVA has 8 chosen not to evaluate energy alternatives in its ER, the NRC staff will not evaluate energy 9 alternatives in its EIS. If TVA were to apply for a construction permit or combined license at 10 some time in the future, the environmental review of that application would include an 11 assessment energy alternatives.

12 Comment: Regarding the fuel cost that has been mentioned earlier -- of natural gas, suppose 13 there are quite a lot of uncertainties in there. But there's also a lot of uncertainty about nuclear 14 fuel costs will work out in the future and -- in terms of climate and other impacts. Then the 15 workforce requirements will -- potential workforce benefits -- economic benefits from technology 16 -- it's certainly much less than what renewable resources for electricity could bring in the future.

17 This is a very accelerating economic sector now, and will be for the foreseeable future. At a --

18 much more affect the number of jobs that will be created, and it will be all dependent on the --

19 mostly on the wind and solar energy, which is very productive now -- predictable in terms of the 20 cost because, I don't know, but it can't really be easily changed.

21 Then regarding the safety -- safety is obviously a relative term particularly when one can predict 22 in advance. But it's certainly safer not to use nuclear power. And the long term management of 23 the waste -- the spent fuel -- is also not very well determined what the risks are for future 24 generations and for the ecology of the future. That's also very unpredictable (0001-11-1 [Naegeli, 25 Wolf])

26 Comment: I will talk briefly about some of the issues we plan to bring up in our intervention on 27 this reactor, which we plan to do in June by the deadline to intervene in the early site permit.

28 There is -- needs to be a basis for the plant and -- for the site permit. And that is something I 29 have looked at and read the documents for, for example, the -- TVA's application submitted and 30 on the record to the Commission's website. The basis -- part of the basis for the plant from TVA 31 is Executive Order 13514, which is Federal Leadership in Energy, Environment, Economic 32 Performance issued in 2009. It was to do this through an increased energy efficiency, reduction 33 of greenhouse gasses, elimination of waste, new designs, construction maintenance and 34 operating high performance, sustainable buildings in sustainable locations.

35 United States is the world's largest energy consumer. The Federal Government is the nation's 36 single largest energy user. The Department of Defense is the biggest energy user in the federal 37 system. And the leading use of -- leading in use of energy in the Defense Department is jet fuel.

38 In other words, energy used in the most energy intensive federal agency is used principally to fly 39 or to drive heavy equipment over long distances. A modular nuke at Clinch River would not 40 have any impact here.

41 Moreover, the general trend in energy use by the Federal Government has been downward for 42 the last four decades and is now in steep decline. According to the Federal Energy 43 Management Program this accomplishment is directly attributed to federal employees making D-44

1 choices for efficiency and striving to reduce operating costs. Tools employed by federal 2 agencies are training, technical assistance, energy performance, contracts. Not nuclear power.

3 A subsequent executive order, Executive Order 13693 entitled Planning for Federal 4 Sustainability in the Next Decade was issued in 2015. It revokes 13514, but reiterated overall 5 policy to -- to increase energy efficiency and improve environmental performance. Executive 6 Order 13693 also sent specific targets for cleaner energy sources with interim goals and 7 endpoints to be achieved by 2025, rebuilding electric energy and thermal energy. Two broad 8 energy categories are defined by EO 13693, renewable and alternative. They are not the same.

9 According to the order -- the executive order, alternative energy includes small modular nuclear 10 reactors. The order -- the order's definition of renewable energy does not include small modular 11 reactors. The differences are significant when applied to the 10-year sustainability goals in 12 section three of the executive order. Section 3b of the order specific to building electric energy, 13 that is heating and lighting, and thermal energy which shall be provided by renewable energy 14 and alternative energy not less than 25 percent by fiscal year 2025.

15 However, section 3c states that the percentage of building electric energy not thermal energy --

16 building electric energy -- keeping the lights on -- could be provided by renewable electric 17 energy. Renewable electric energy, not alternative energy, which would be the small modular 18 reactors -- is to be not less than 30 percent by fiscal year 2025. Clearly the executive order 19 contemplates alternative energy sources to be heat sources such as nuclear and other thermal 20 electric power plants. Renewable sources directed to be used solely for electrical generation 21 are largely solar, wind, wave, heat pumps and hydro-electric. The order provides TVA will the 22 bill of justification for so-called small modular reactors, particularly within the eight-year window 23 remaining between now and 2025.

24 I mentioned that we [Blue Ridge Environmental Defense League] plan to intervene in this 25 permit. We plan to do that. (0001-12-2 [Zeller, Lou])

26 Comment: In terms of our water resources, SMRs are even more water-intensive than 27 traditional nuclear reactors, which are already a water-hogging technology that strains water 28 resources. The NRC needs to analyze the fact that SMRs use more water per unit of electricity 29 produced in a plethora of actual clean, safe energy options. As climate change impacts such as 30 prolonged droughts potentially becoming more frequent, we must pursue water saving not 31 water-squandering energy choices. (0001-4-5 [Powell, Michelle])

32 Comment:

33 Global Warming 34 Executive Order 13514, titled "Federal Leadership in Environmental, Energy, and Economic 35 Performance," was issued on October 5, 2009. The public policy advanced by the President's 36 Order was:

37 [I]ncrease energy efficiency; measure, report, and reduce their greenhouse gas emissions from 38 direct and indirect activities; conserve and protect water resources through efficiency, reuse, 39 and stormwater management; eliminate waste, recycle, and prevent pollution; leverage agency 40 acquisitions to foster markets for sustainable technologies and environmentally preferable 41 materials, products, and services; design, construct, maintain, and operate high performance 42 sustainable buildings in sustainable locations; strengthen the vitality and livability of the D-45

1 communities in which Federal facilities are located; and inform Federal employees about and 2 involve them in the achievement of these goals. 2 3 The United States is the world's largest energy consumer; the federal government is the nation's 4 single largest energy user; the Department of Defense is the biggest energy user in the federal 5 government; and the leading use of energy in the Defense Department is...jet fuel. In other 6 words, energy use in the most energy-intensive federal agency is used principally to fly or drive 7 heavy equipment over long distances. A modular nuke at Clinch River would not have any 8 impact here.

9 Moreover, the general trend in energy use by the federal government has been downward for 10 the last four decades, and is now in steep decline. According to the Federal Energy 11 Management Program, "this accomplishment is directly attributed federal employees making the 12 choice for efficiency and striving to reduce operating costs." The tools employed by federal 13 agencies are: training, technical assistance and energy performance contracts. Not nuclear 14 power.

15 A subsequent executive order, EO 13693-"Planning for Federal Sustainability in the Next 16 Decade," was issued on March 19, 2015. This order revoked EO 13514 but reiterated the 17 overall policy: "It therefore continues to be the policy of the United States that agencies shall 18 increase efficiency and improve their environmental performance." EO 13693 also set specific 19 targets for cleaner energy sources with interim goals, the end points to be achieved by 2025 for 20 building electric energy and thermal energy.

21 Two broad energy categories are defined in EO 13693: Renewable and alternative. They are 22 not the same. According to the order, alternative energy includes small modular nuclear 23 reactors. The order's definition of renewable energy does not include small modular reactors.

24 The differences are significant when applied to the ten-year sustainability goals set by Section 3 25 of the order.5 Section 3(b) of the order is specific to building electric energy and thermal energy 26 which shall be provided by renewable electric energy and alternative energy, "not less than 25 27 percent by fiscal year 2025." However, Section 3(c) states that the percentage of building 28 electric energy to be provided by renewable electric energy is to be "not less than 30 percent by 29 fiscal year 2025."

30 Clearly, the Executive Order contemplates alternative energy sources to be heat sources, such 31 as nuclear and other thermoelectric power plants. The renewable sources, directed to be used 32 solely for electrical generation, are largely solar, wind, wave, heat pumps and hydroelectric.

33 The order provides TVA with little justification for so-called small modular reactors, particularly 34 within the eight-year window remaining between now and 2025; 35 [footnotes:]

36 2 Federal Register Vol. 74, No. 194, Page 52117, October 8, 2009 37 3 '"alternative energy' means energy generated from technologies and approaches that advance 38 renewable heat sources, including biomass, solar thermal, geothermal, waste heat, and 39 renewable combined heat and power processes; combined heat and power; small modular 40 nuclear reactor technologies; fuel cell energy systems; and energy generation, where active 41 capture and storage of carbon dioxide emissions associated with that energy generation is 42 verified." EO 13693, Section 19(c) 43 4 "'renewable electric energy' means energy produced by solar, wind, biomass, landfill gas, 44 ocean (including tidal, wave, current, and thermal), geothermal, geothermal heat pumps, 45 microturbines, municipal solid waste, or new hydroelectric generation capacity achieved from D-46

1 increased efficiency or additions of new capacity at an existing hydroelectric project." EO 13693, 2 Section I 9(v) 3 5 Sec. 3. Sustainability Goals for Agencies, In implementing the policy set forth in section I of 4 this order and to achieve the goals of section 2 of this order, the head of each agency shall, 5 where life-cycle cost-effective, beginning in fiscal year 2016, unless otherwise specified (0055-1 6 [Zeller, Lou])

7 Response: The action before NRC is whether to issue an ESP and to determine whether the 8 CRN Site is suitable under the NRCs regulations for placement of one or more SMRs. The 9 ESP determination is primarily a siting decision; in accordance with 10 CFR 51.50 (TN250), the 10 applicants ER need not include an evaluation of alternative energy sources. In accordance with 11 10 CFR 51.75 (TN250), the EIS will not include an evaluation of alternative energy sources 12 because these matters were not addressed in the applicants ER (TVA 2016-TN4637). If TVA 13 were to apply for a construction permit or combined license at some time in the future, the 14 impacts of energy alternatives would be assessed at that time. The review of that application 15 would include the development of another EIS and the opportunity to participate in another 16 hearing.

17 The scope of the present ESP environmental review includes water use impacts, socioeconomic 18 impacts, and uranium fuel cycle impacts; the review team will use the plant parameter envelope 19 values provided by the applicant to assess these impacts. In the EIS, water-related impacts will 20 be discussed in Sections 4.2 and 5.2; socioeconomic impacts will be discussed in Sections 4.4 21 and 5.4, and the uranium fuel cycle will be discussed in Section 6.1. Estimated greenhouse gas 22 emissions (GHG) emissions will be presented in Appendix K and an assessment of project 23 impacts given predicted regional climate change will be presented in Appendix L of the EIS.

24 Comment: Small modular reactors are too costly, too slow to bring online, too uncertain and 25 have a high environmental impact and risk. Current national high level radioactive waste 26 disposal practices would leave this dangerous waste on-site for decades, or much longer, after 27 final reactor shut down. The future belongs to renewable energy. All trends point in that 28 direction. The global increase in renewables in 2015 was 63 gigawatts of wind, 50 gigawatts of 29 solar, 28 of hydroelectric. Total nuclear capacity worldwide is going down, even France is 30 moving away from nuclear power. TVA should embrace the future and aggressively add 31 renewable generation to speed up the retirement of coal, nuclear and gas facilities. TVA should 32 partner with the Clean Line Project to lock in two cents per kilowatt hour of electricity now. TVA 33 should embrace all forms of solar energy and energy efficiency. The sooner TVA starts 34 changing course to put renewables first, the smoother the transition will be. (0001-5-3 [Safer, 35 Don])

36 Comment: SMRs are significantly more water-intensive than clean energy choices such as 37 wind, solar and energy efficiency and conservation. (0005-2 [McBride, Geoff] [McBride, Linda]

38 [Sprignoli, Damon] [Turk, Lawrence "Butch"]) (0005-6 [McBride, Geoff] [McBride, Linda] [Sprignoli, 39 Damon] [Turk, Lawrence "Butch"])

40 Comment: Nuclear power is more water intensive than wind, solar and energy efficiency and 41 conservation. (0007-2 [McFadden, Nancy])

42 Comment: Why choose such dangerous waste from SMRs, when wind, solar, energy 43 efficiency and conservation measures already exist and are effective. (0007-4 [McFadden, Nancy])

D-47

1 Comment: Solar based renewable energy resources will provide more jobs and a higher return 2 on investment. In addition, the negative environmental impacts of nuclear energy (mining, 3 disposal, etc.) far outweigh any possible short-tern benefits. Support the future, support solar 4 (0010-2 [Ellis, Daniel])

5 Comment: The TVA would do better addressing its responsibility of making the region a solar 6 powered residential region of world class status. I recently became aware that the TVA is a 7 hindrance, or more specifically, some obsolete law is a hindrance in completely solar powering 8 residential needs just because it makes TVA the sole legal supplier of energy to local 9 distributors, who are thus not allowed to buy solar power produced by residents. I think this is 10 outrageous obsolescence in this age of distributed solar power production capability (see 11 Knoxville Mercury, March 2017: Tale of the Two Meters). TVA was not a power company to 12 start with. Now it is time to remember its roots and promote residential solar power instead of 13 being a hindrance to solar energizing the Tennessee Valley Region. Many individuals in this 14 region have installed solar and it would turn into a tsunami if the thumb screws would not be 15 kept on people's initiative to produce their own power, but by far not enough. In countries which 16 are much less endowed with solar energy many more people have gone solar than here, where 17 a so-called regional development agency denies solar power to its residents just due to some 18 obsolete law. Actually, TVA and the region should be a world leader in residential solar energy 19 supply. How long have we still to wait for this to happen? (0013-4 [Wunderlich, Walt])

20 Comment: Thinking about TVA's wind power import project and also about the solar energizing 21 of the Tennessee Valley Region, the East Tennessee area that could be spoiled by a nuclear 22 mishap lends itself much more for cooperating in the renewable energy system by pumped 23 storage energy than for nuclear power experiments. We have the Cumberland rim with 24 hundreds of meters of head for any number of such plants that have relatively high efficiency, 25 are of proven technology and can be run totally automatic and totally pollution free. (0013-5 26 [Wunderlich, Walt])

27 Comment: Every nuclear power plant built in the United States has been plagued by budget 28 overruns and multiple delays. There are better alternatives for additional electrical power 29 generation including solar and wind energy. Solar is now less expensive than fossil fuel power 30 and vastly less expensive than nuclear power (0021-2 [Harland, Donald])

31 Comment: Plus it is not needed when there are better choices that are less expensive and less 32 highly water intensive, such as wind and solar.

33 The Clinch River site was previously abandoned, and should remain that way. Clean energy is 34 the way to go, if energy is needed. (0025-4 [Kirkman, Arden])

35 Comment: I am opposed to this expensive nuclear experiment. We cannot dispose of the 36 nuclear waste we have accumulated. Why do we persist in creating more? We need to put our 37 expertise on wind and solar, something we don't have to be concerned about polluting water, air 38 and soil with devastating health effects. These sources of power are on the rise world wide and 39 are much safer. They have provided many, safer jobs. Tennessee does not need to lag behind 40 and put us in nuclear jeopardy. (0030-1 [Sweeton, Beverly])

41 Comment: Thank you for your time in working for the good of our country, and its energy 42 needs. I am writing to express my deep concern about the Clinch River Small Modular Reactor 43 Project. These reactors are not needed and are prohibitively expensive when compared to 44 clean, renewable solar and wind power. What's more, the Tennessee Valley Authority is D-48

1 seeking site approval before reactor designs have been studied, much less approved. SMRs 2 are significantly more water-intensive than clean energy choices such as wind, solar and energy 3 efficiency and conservation. And just like existing nuclear power plants, they produce long-4 lived, highly radioactive nuclear waste for which no safe management and permanent storage 5 exists. I implore you to deny the permit. It does not make sense that we would allow them to go 6 in this direction when good, safe alternatives exist. My hope is that you and other earnest, 7 environmentally aware government administrators and leaders will encourage TVA to look at the 8 long-term implications, not just their present bottom line, and seek clean and safe energy 9 choices. (0034-1 [Bates, Renee])

10 Comment: Roane County, TN, is close to major populations centers: Knoxville, Chattanooga, 11 Nashville and Lexington, KY, as well as to many ecologically sensitive areas. Pollution of the 12 Clinch River and Watts Bar would be increased. I lived in East Tennessee for 15 years and I 13 know for a fact that nuclear reactors should not be built in this area.

14 This is an unproven, experimental technology which is not needed. We should instead be 15 emphasizing Solar and Wind Energy, which are much kinder to our precious fresh water. Solar 16 and Wind energy do not endanger residents and guests in the United States, unlike nuclear 17 energy. Small modular reactors are extremely expensive. Thank you for denying TVA the ESP 18 to build such a nuclear device. (0045-1 [Mortenson, Julia])

19 Comment: Small Modular Reactors have not been proven safe, and theres no reason to try 20 such an uncertain and expensive source of energy. I would love to see TVA take a leading role 21 in forward-thinking, sustainable energy resources instead of wasting needed funds on this 22 uncertain and experimental method. (0046-1 [Johnston, Susan])

23 Comment: Build a solar installation. Tennessee needs renewable energies, not more 24 pollution! (0056-2 [Goins, Joe])

25 Response: These comments express opposition to nuclear power or to building SMRs at the 26 CRN Site, and express support for alternative sources of power generation. Because an ESP is 27 primarily a siting decision, and analysis of energy sources is not required, energy alternatives 28 will not be evaluated in the EIS. If TVA were to apply for a construction permit or combined 29 license at some time in the future, the environmental impacts of energy alternatives relative to 30 those of the proposed project would be assessed at that time. The review of that application 31 would include the development of another EIS.

32 D.2.21 Comments Concerning Alternatives - Sites 33 Comment: The exposure of freshwater resources to nuclear contamination is more or less 34 critical depending on what this SMR really is. Sometimes it is presented as if it were just the 35 size of a Truck trailer, sometimes one has the impression it is a huge structure. How much 36 output does it provide? Is it relevant to the TVA system? Probably not, but as a small self-37 contained power source it could well be of national importance. Still the question remains: Do 38 these experiments have to be conducted in a river bend of the Clinch River, in a relatively 39 densely populated area of a very scenic part of the country,that has many other potentials.

40 Putting nuclear weapons facilities there is bad enough, but this was a war time decision and 41 was made at a time when the ramification of nuclear contamination were either not recognized 42 or belittled. (0013-2 [Wunderlich, Walt])

D-49

1 Response: The EIS will include an evaluation of the construction and operation impacts of a 2 SMR at the CRN Site in Chapters 4 and 5. The EIS will also include an evaluation of the 3 construction and operation impacts of a SMR facility at alternative sites, such as other property 4 within the Oak Ridge Reservation, in Chapter 9 of the EIS, and will include an evaluation of 5 alternative sites to determine whether there is an obviously superior alternative to the proposed 6 site.

7 Comment: I find the site very precarious. It should never have been chosen for any nuclear 8 experiments. It is surrounded on three sides by the Clinch River, a major waterway that feeds 9 into the Tennessee river which feeds into the Mississippi River, the short stretch of Ohio River 10 discounted. The recent experience with the Japanese Daiichi plant makes one to think about it.

11 What if this thing explodes, what if its containment cracks? What is the geology around the 12 site? Is it rocky, is it shaly, is it loamy? seismicity? One would assume that these elementary 13 questions have been asked and answered satisfactorily by now. (0013-1 [Wunderlich, Walt])

14 Comment: The plan to site the proposed TVA SMR at the former CRBR location in Oak Ridge, 15 TN is in essence using a greenfield returned to its natural landscape over the intervening 35 16 years since the CRBR was canceled. This fully recovered natural environment is habitat to 17 diverse and extensive numbers of wildlife species and wildlife habitat. The Federal Government 18 is spending billions of dollars cleaning and rehabilitating legacy nuclear sites in Oak Ridge and 19 across the US. Before another greenfield becomes a new legacy nuclear site every 20 consideration should be given to using a recently or soon to be deactivated nuclear power plant 21 site, closed coal fired power plant, or other nuclear era legacy site. One such nuclear era 22 legacy brownfield site is the S-50 -- K-25 Power House site barely 3 miles from the proposed 23 site. It has all the attributes of the proposed location, even more so -- including a railroad, barge 24 terminal, high voltage power line infrastructure, water supply, security (water on three sides and 25 a single entry point) no nearby public/private land owners, and it is owned by the Federal 26 Government (DOE). In addition, using it for a nuclear reactor site would save the $100's of 27 millions in cleanup costs faced with making it acceptable for private industrial use.

28 https://en.wikipedia.org/wiki/S-50_(Manhattan_Project).

29 Are you aware of the S K-25 Power House Area and it close proximity?

30 Have your toured the area and been briefed on its attributes and been made aware of it as a 31 viable location?

32 Why can't it be transferred to TVA from DOE in exchange for the CRBR site which can then be 33 returned as part of the DOE Reservation Environmental Research landscape?

34 What are the life cycle costs savings using it as compared to a greenfield site?

35 These are a few of the questions that when fully and independently addressed will conclude that 36 the SMR project located on a brownfield can go forward at a major savings in cost and 37 environmental impact. The last thing a new nuclear project should result in is creating another 38 nuclear liability for our Nation. Especially when so many alternatives exist, (0042-1 [Colclasure, 39 Doug])

40 Response: Chapter 9 will describe the TVA's site selection process and the NRC staffs 41 evaluation of that process. In Chapter 9, the NRC staff will also independently compare the 42 alternative sites to the proposed site to determine if any of the alternative sites are 43 environmentally preferable to the proposed site.

D-50

1 D.2.22 Comments Concerning Benefit-Cost Balance 2 Comment: Billions of dollars could be spent on the nuclear reactor technology that is 3 unproven, untested and significantly more expensive than other types of energy technologies 4 that are actually available today including renewables, such as solar, wind, energy efficiency 5 and demand site management measures.

6 The economics of new nuclear have only worsened since 2010 while the economics for 7 renewables and energy efficiency have improved. The NRC must include updated economic 8 cost analysis of the actual costs of many nuclear reactors. This can be done by looking into 9 nearby Georgia and South Carolina where the under-construction Toshiba/Westinghouse AP 10 1000 reactors are years delayed and billions of dollars over budget. In fact, Westinghouse has 11 filed for bankruptcy and is out of the construction business and parent company, Toshiba may 12 be next in line. These projects may never be finished. The reality is that new nuclear power is 13 losing the bet and draft environmental impact statement must consider accurate cost statement 14 estimates as compared to other energy technologies that have only seen cost drop as new 15 nuclear power costs sour. (0001-4-2 [Powell, Michelle])

16 Comment: The economics of small modular reactors do not make sense, even with optimistic 17 pre-construction cost projections. It is impossible to say how much actual spending would 18 exceed these estimates, but it is almost certain to be substantial. Watts Bar 1 and 2 were 19 originally projected to cost under $700 million. They were completed decades later at an 20 acknowledged cost of over $13 billion. Watts Bar 2 is currently inoperable due to a structural 21 failure in a 40-year old steam condenser. It is unknown when repairs will be completed, but not 22 for months. The once hyped U.S. SMR business is down to one manufacturer with two possible 23 customers, TVA and UAMPS, the Utah Associated Municipal Power Systems. In 2009, TVA 24 made a great decision when it withdrew from plans to be the first in the US to build a 25 Westinghouse AP1000 reactors. Construction delays from cost overruns have forced 26 Westinghouse into bankruptcy and the VC Summer and Vogtle reactors may never be finished 27 after billions have been spent. (0001-5-2 [Safer, Don])

28 Comment: And just a footnote, the total estimated cost for TVA to develop SMRs to the point 29 of getting this application -- early site permit -- is $72 million. Half of that will be given to TVA by 30 the DOE. So -- so far TVA has spent around $23 million on SMR activities through fiscal year 31 2015, and estimates are about $5 million in the fiscal year 2016. And it will be at least five years 32 before TVA will decide whether to build these or not. That's from Bill Johnson and Joe 33 Hoagland, CEO and vice president at TVA. It's very uncertain whether they'll do these. (0001 34 4 [Safer, Don])

35 Comment: They are not cost effective. They may cost less per reactor, but the cost per 36 kilowatt-hour of the electricity produced by a small reactor will be higher than that of a large 37 reactor. Perhaps eventually costs per kwh will be reduced as SMR's are mass produced, but 38 we are decades away from that. Wind, solar and other clean renewable sources are continually 39 reducing in price. And that is even before external costs are included. All fossil fuel energy 40 sources are heavily subsidized in that society bears much of the actual cost of environmental 41 destruction through mining, pollution of air and water, and impacts of global warming.(0051-3 42 [Anthony, Kate])(0051-9 [Anthony, Kate])

43 Comment: 4. [illegible] and most renewables are already cheaper 44 5. Obviously, its not about science but the money D-51

1 6. Time it takes to certify SMR's will do little to help with global warming (0059-4 [Anonymous, 2 Anonymous])

3 Response: The cost of the proposed action need not be considered in an ESP ER or in the 4 NRCs EIS (10 CFR 51.50(b)(2) [TN250]; NUREG-1555 [NRC 2000-TN614]). If TVA were to 5 apply for a construction permit or combined license at some time in the future, the 6 environmental review of that application would include an assessment of the proposed projects 7 benefit-cost balance. Therefore, this issue will not be assessed further during the ESP review 8 or in the ESP EIS.

9 D.2.23 References 10 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 11 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

12 Washington, D.C. TN250.

13 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, "Licenses, 14 Certifications, and Approvals for Nuclear Power Plants." Washington, D.C. TN251.

15 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 16 Part 800, "Protection of Historic Properties." Washington, D.C. TN513.

17 82 FR 17885. April 13, 2017. "Tennessee Valley Authority; Clinch River Nuclear Site; Early 18 Site Permit Application." Federal Register. U.S. Nuclear Regulatory Commission, Washington, 19 D.C. TN4910.

20 42 U.S.C. § 4321 et seq. National Environmental Policy Act (NEPA) of 1969, as amended.

21 TN661.

22 54 U.S.C. § 306108. National Historic Preservation Act Section 106, "Effect of Undertaking on 23 Historic Property." TN4839.

24 NRC (U.S. Nuclear Regulatory Commission). 1977. Final Environmental Impact Statement 25 Related to the Construction and Operation of Clinch River Breeder Reactor Plant. NUREG-26 0139, Washington, D.C. Accession No. ML082610503. TN5083.

27 NRC (U.S. Nuclear Regulatory Commission). 2000. Environmental Standard Review Plan 28 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 29 Main Report and 2007 Revisions, Washington, D.C. Available at http://www.nrc.gov/reading-30 rm/doc-collections/nuregs/staff/sr1555/toc/. TN614.

31 NRC (U.S. Nuclear Regulatory Commission). 2014. Generic Environmental Impact Statement 32 for Continued Storage of Spent Nuclear Fuel. Final Report, NUREG-2157, Washington, D.C.

33 Accession No. ML14198A440. TN4117.

34 TVA (Tennessee Valley Authority). 2016. "Clinch River Nuclear Site Early Site Permit 35 Application, Part 03Environmental Report (Revision 0)." Chattanooga, Tennessee.

36 Accession No. ML16144A145. TN4637.

D-52

1 APPENDIX E 2 DRAFT ENVIRONMENTAL IMPACT STATEMENT 3 COMMENTS AND RESPONSES 4 This appendix is intentionally left blank. In the final environmental impact statement, this 5 appendix will contain the comments on and responses to comments on the draft environmental 6 impact statement.

E-1

1 APPENDIX F 2 KEY CONSULTATION CORRESPONDENCE 3 Consultation correspondence sent and received during the environmental review of the early 4 site permit application for the Tennessee Valley Authoritys (TVAs) Clinch River Nuclear (CRN) 5 Site in Roane County, Tennessee, is identified in Table F-1. The correspondence can be found 6 in the U.S. Nuclear Regulatory Commissions (NRCs) Agencywide Document Access and 7 Management System (ADAMS), which is accessible from the NRC website at 8 http://www.nrc.gov/readingrm/adams.html (the Public Electronic Reading Room) (note that the 9 URL is case sensitive). ADAMS accession numbers also are provided in Table F-1.

10 A copy of the correspondence received from Native American Tribes is presented in 11 Section F.1. Copies of correspondence received from the U.S. Army Corps of Engineers are 12 presented in Section F.2.

13 Section F.3 contains copies of correspondence (excluding attachments) from Federal and State 14 agencies regarding threatened, endangered, and sensitive species and their habitats. Appendix 15 M is reserved for a full copy of the U.S. Fish and Wildlife (FWS) Biological Assessment upon its 16 completion.

17 Table F-1. Key Early Site Permit Consultation Correspondence Regarding the CRN Site Date and Accession Source Recipient Number Correspondence with Native American Tribes (see Section F.1)

U.S. Nuclear Regulatory Absentee Shawnee Tribe April 20, 2017 Commission (NRC) (Allen Fetter) (Edwina Butler-Wolfe) (ML17041A081)

NRC (Allen Fetter) Thlopthlocco Tribal Town April 20, 2017 (Ryan Morrow) (ML17047A682)

NRC (Allen Fetter) Choctaw Nation of Oklahoma April 20, 2017 (Gary Batton) (ML17041A086)

NRC (Allen Fetter) Poarch Band of Creek Indians April 20, 2017 (Stephanie A. Bryan) (ML17047A676)

NRC (Allen Fetter) Alabama-Coushatta Tribe of Texas April 20, 2017 (Jo Ann Battise) (ML17041A082)

NRC (Allen Fetter) Eastern Band of Cherokee Indians of April 20, 2017 North Carolina (Patrick Lambert) (ML17017A123)

NRC (Allen Fetter) Cherokee Nation of Oklahoma Bill April 20, 2017 (John Baker) (ML17041A085)

NRC (Allen Fetter) Alabama-Quassarte Tribal Town April 20, 2017 (Tarpie Yargee) (ML17041A084)

NRC (Allen Fetter) Jena Band of the Choctaw Indians April 20, 2017 (B. Cheryl Smith) (ML17047A407)

NRC (Allen Fetter) The Chickasaw Nation April 20, 2017 (Bill Anoatubby) (ML17047A681) 18 F-1

Table F-1. (contd)

Date and Accession Source Recipient Number NRC (Allen Fetter) Quapaw Tribe of Oklahoma April 20, 2017 (John Berrey) (ML17047A677)

NRC (Allen Fetter) Seminole Tribe of Florida April 20, 2017 (Marcellus W. Osceola Jr.) (ML17047A679)

NRC (Allen Fetter) United Keetoowah Band of Cherokee April 20, 2017 Indians (Joe Bunch) (ML17047A683)

NRC (Allen Fetter) Coushatta Tribe of Louisiana April 20, 2017 (Lovelin Poncho) (ML17047A405)

NRC (Allen Fetter) Mississippi Band of Choctaw Indians April 20, 2017 (Phyliss J. Anderson) (ML17047A409)

NRC (Allen Fetter) Muscogee (Creek) Nation of Oklahoma April 20, 2017 (James Floyd) (ML17047A675)

NRC (Allen Fetter) Seminole Nation of Oklahoma April 20, 2017 (Leonard M. Harjo) (ML17047A678)

NRC (Allen Fetter) Eastern Shawnee Tribe of Oklahoma April 20, 2017 (Glenna J. Wallace) (ML17047A406)

NRC (Allen Fetter) Shawnee Tribe of Oklahoma April 20, 2017 (Ron Sparkman) (ML17047A680)

NRC (Allen Fetter) Kialegee Tribal Town (Jeremiah Hobia) April 20, 2017 (ML17047A408)

United Keetoowah Band of Cherokee NRC (Allen Fetter) June 28, 2017 Indians (Karen Pritchett) (ML17206A450)

Cherokee Nation (Elizabeth Toombs) NRC (Allen Fetter) May 12, 2017 (ML17145A580)

Choctaw Nation of Oklahoma NRC (Allen Fetter) June 5, 2017 (Daniel Rangle) (ML17157B749)

NRC (Jennifer Davis) Seminole Nation of Oklahoma January 19, 2018 (Theodore Isham) (ML18031A950)

NRC (Jennifer Davis) Alabama-Quassarte Tribal Town January 19, 2018 (Samantha Robison) (ML18046A410)

NRC (Jennifer Davis) Alabama-Coushatta Tribe of Texas January 19, 2018 (Bryant Celestine) (ML18058B560)

Seminole Nation of Oklahoma NRC (Jennifer Davis) January 20, 2018 (Theodore Isham) (ML18046A412)

NRC (Jennifer Davis) Seminole Tribe of Florida January 22, 2018 (Victoria Menchaca) (ML18059A157)

The Chickasaw Nation NRC (Jennifer Davis) January 22, 2018 (Karen Brunso) (ML18031A976)

NRC (Jennifer Davis) Thlopthlocco Tribal Town January 29, 2018 (Terry Clouthier) (ML18040A439)

NRC (Jennifer Davis) Choctaw Nation of Oklahoma February 9, 2018 (Daniel Ragle) (ML18044A843)

F-2

Table F-1. (contd)

Date and Accession Source Recipient Number NRC (Jennifer Davis) Poarch Band of Creek Indians February 16, 2018 (Carolyn White) (ML18051A746)

Thlopthlocco Tribal Town NRC (Jennifer Davis) February 19, 2018 (Terry Clouthier) (ML18051A738)

NRC (Jennifer Davis) Seminole Nation of Oklahoma March 5, 2018 (Theodore Isham) (ML18064A222)

Correspondence with U.S. Army Corps of Engineers (see Section F.2)

NRC USACE Nashville District April 12, 2017 (Tammy Turley) (ML17065A237)

USACE Nashville District NRC (Allen Fetter) May 2, 2017 (Tammy Turley) (ML17205A413)

Correspondence Regarding Historic and Cultural Resources)

NRC (Allen Fetter) Tennessee Historical Commission April 20, 2017 (E. Patrick McIntyre, Jr.) (ML17061A428)

NRC (Allen Fetter) Advisory Council on Historic April 20, 2017 Preservation (Reid Nelson) (ML17065A239)

Correspondence Regarding Threatened, Endangered, and Sensitive Species and their Habitats (See Section F.3)

NRC (Allen Fetter) U.S. Fish and Wildlife Service (FWS) April 20, 2017 (Mary Jennings) (ML17069A249)

NRC (Allen Fetter) FWS (Bill Pearson) April 20, 2017 (ML17088A264)

FWS (Mary Jennings) NRC (Cindy Bladey) April 21, 2017 (ML17145A505)

FWS (Mary Jennings) NRC (Allen Fetter) May 5, 2017 (ML17205A341)

U.S. Environmental Protection NRC May 30, 2017 Agency, Region 4 (Larry Long) (ML17157B742)

Tennessee Department of NRC (Patricia Vokoun) June 12, 2017 Environment and Conservation (ML17170A310)

(TDEC) (Kendra Abkowitz)

FWS (Mary Jennings) NRC (Allen Fetter) July 20, 2017 (ML17205A342)

Tennessee Wildlife Resource PNNL (James Becker) September 6, 2017 Agency (Pat Black) (ML18022A346)

Tennessee Department of PNNL (James Becker) September 6, 2017 Environment and Conservation (ML18019A036)

(Gerry Middleton)

Tennessee Department of PNNL (James Becker) September 11, 2017 Environment and Conservation (ML18026A552)

(Stephanie Williams)

F-3

Table F-1. (contd)

Date and Accession Source Recipient Number PNNL (James Becker) Kentucky State Nature Preserve September 13, 2017 Commission (Ian Horn) (ML18059A130)

Oak Ridge National Laboratory PNNL (James Becker) September 18, 2017 (Kitty McCracken) (ML18016A334)

Georgia Department of Natural PNNL (James Becker) September 24, 2017 Resources (Anna Yellin) (ML18012A447)

Kentucky State Nature Preserves PNNL (James Becker) September 29, 2017 Commission (Ian Horn) (ML18012A656)

Tennessee Wildlife Resource PNNL James Becker) November 3, 2017 Agency (Brian Flock) (ML18064A895)

Oak Ridge National Laboratory PNNL (James Becker) November 8, 2017 (Neil Giffen) (ML18022A742)

Oak Ridge National Laboratory PNNL (James Becker) December 7, 2017 (Neil Giffen) (ML18010A883)

F-4

) &RUUHVSRQGHQFH5HFHLYHGIURP1DWLYH$PHULFDQ7ULEHV ClinchRiverESPEISCEm Resource From: karen pritchett <kpritchett@ukb-nsn.gov>

Sent: Wednesday, June 28, 2017 2:57 PM To: ClinchRiverESPEIS Cc: Jennifer.Barnett@tn.gov; Eric Oosahwee-Voss; karen pritchett

Subject:

[External_Sender] Clinch River Nuclear Site, Roane County, Tennessee

Dear Sir,

On behalf of Tribal Historic Preservation Officer (THPO) Eric Oosahwee-Voss, please accept this digital communication regarding the Environmental Review of the Early Site Permit Application for the Clinch River Nuclear Site in Roane County, Tennessee.

Please be advised that the proposed undertaking lies within the traditional territory of the United Keetoowah Band of Cherokee Indians in Oklahoma (UKB). This opinion is being provided by UKB THPO, pursuant to authority vested by the UKB Corporate Board and under resolution 16-UKB-34. The United Keetoowah Band is a Federally Recognized Indian Nation headquartered in Tahlequah, OK.

Information on Native American use in the project vicinity shows that prehistoric, ethnographic, historic, and traditional sites of value to the UKB surround the project area. We recommend that a cultural resources inventory be completed prior to project implementation.

Thank you for consulting with the UKB. Please note that these comments are based on information available to us at the time of the project review. We reserve the right to revise our comments as information becomes available. If you have any questions or concerns, please contact me at (918) 458-6715 or kpritchett@ukb-nsn.gov or THPO Eric Oosahwee-Voss at (918) 458-6717 or eoosahwee-voss@ukb-nsn.gov U17-849 UKB#

17.0871 Thank you, Karen Pritchett TCNS Coordinator Tribal Historic Preservation Office United Keetoowah Band of Cherokee Indians in Oklahoma P. O. Box 1245 Tahlequah, OK 74465 918-458-6715 F-5

May 12, 2017 Allen H. Fetter, Acting Branch Chief Licensing Branch 3 Division of New Reactor Licensing, Office of New Reactors United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Re: Clinch River Nuclear Site Early Site Permit Application Mr. Allen H. Fetter:

The Cherokee Nation (CN) is in receipt of your correspondence about Clinch River Nuclear Site Early Site Permit Application, and appreciates the opportunity to provide comment upon this project. The CN maintains databases and records of cultural, historic, and pre-historic resources in this area. Our Tribal Historic Preservation Office (THPO) reviewed this project, cross referenced WKHSURMHFW¶VOHJDOGHVFULSWLRQDJDLQVWRXULQIRUPDWLRQ, and found that this Area of Potential Effect (APE) lies within our historic homelands.

In accordance with the National Historic Preservation Act (NHPA) [16 U.S.C. 470 §§ 470-470w6]

1966, undertakings subject to the review process are referred to in S101(d)(6)(A), which clarifies that historic properties may have religious and cultural significance to Indian tribes. Additionally, Section 106 of NHPA requires federal agencies to consider the effects of their action on historic properties (36 CFR Part 800) as does the National Environmental Policy Act (43 U.S.C. 4321 and 4331-35 and 40 CFR 1501.7(a) of 1969).

The CN has a vital interest in protecting its historic and cultural resources. The CN is in concurrence that an Environmental Impact Statement (EIS) in compliance with NHPA should be conducted for the Clinch River Nuclear Site, and is requesting a copy of this report. This office looks forward to receiving and reviewing the EIS. Please contact the CN with response to this request.

Additionally, we would request Department of the Interior conduct appropriate inquiries with other pertinent Tribal and Historic Preservation Offices regarding historic and prehistoric resources not included in the CN databases or records. If items of cultural significance are discovered while developing this project report, the CN asks that activities halt immediately and our offices be F-6

Clinch River Nuclear Site Early Site Permit Application May 12, 2017 Page 2 of 2 contacted for further consultation. If you require additional information or have any questions, please contact me at your convenience.

Thank you for your time and attention to this matter.

Wado, Elizabeth Toombs, Special Projects Officer Cherokee Nation Tribal Historic Preservation Office elizabeth-toombs@cherokee.org 918.453.5389 CC: Patricia Vokoun, NRC Environmental Project Manager F-7

ClinchRiverESPEISCEm Resource From: Daniel R. Ragle <dragle@choctawnation.com>

Sent: Monday, June 05, 2017 5:25 PM To: ClinchRiverESPEIS

Subject:

[External_Sender] RE: Initiation of Section 106 and Scoping Process for the Environmental Review of the Early Site Permit Application for the Clinch River Nuclear Site in Roane County, Tennessee Thank you for the correspondence regarding the above referenced project. This project lies outside of our area of historic interest. Therefore, the Choctaw Nation of Oklahoma respectfully defers to the other Tribes that have been contacted. If you have any questions, please contact me by email.

Daniel Ragle Compliance Review Officer Historic Preservation Dept.

Choctaw Nation of Oklahoma (800) 522-6170 Ext. 2727 dragle@choctawnation.com www.choctawnation.com www.choctawnationculture.com This message is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure. If you have received this message in error, you are hereby notified that we do not consent to any reading, dissemination, distribution or copying of this message. If you have received this communication in error, please notify the sender immediately and destroy the transmitted information. Please note that any view or opinions presented in this email are solely those of the author and do not necessarily represent those of the Choctaw Nation.

F-8

From: Theodore Isham To: Davis, Jennifer Cc: Vokoun, Patricia

Subject:

[External_Sender] RE: Early Site Permit Application for the Clinch River Nuclear Site in Roane County, Tennessee Date: Saturday, January 20, 2018 10:45:07 AM This Opinion is being provided by Seminole Nation of Oklahomas Cultural Advisor, pursuant to authority vested by the Seminole Nation of Oklahoma General Council. The Seminole Nation of Oklahoma is an independently Federally-Recognized Indian Nation headquartered in Wewoka, OK.

In keeping with the National Environmental Policy Act (NEPA)d, and Section 106 of the National Historic Preservation Act (NHPA), 36 CFR Part 800, this letter is to acknowledge that the Seminole Nation of Oklahoma has received notice of the proposed project at the above mentioned location.

Based on the information provided and because the potential for buried cultural resources, the proposed project has an extreme probability of affecting archaeological resources, some of which may be eligible for listing in the National Register of Historic Places (NRHP).

We recommend that an intensive literature/phaseI survey reports of the nearby archaeological sites be conducted and sent to SNO. Also, we request that a listing of all the flora in the affected area be provided.

We do request that if cultural or archeological resource materials are encountered at all activity cease and the Seminole Nation of Oklahoma and other appropriate agencies be contacted immediately.

Furthermore, due to the historic presence of our people in the project area, inadvertent discoveries of human remains and related NAGPRA items may occur, even in areas of existing or prior development. Should this occur we request all work cease and the Seminole Nation of Oklahoma and other appropriate agencies be immediately notified.

Theodore Isham Seminole Nation of Oklahoma Historic Preservation Officer PO Box 1498 Seminole, Ok 74868 Phone: 405-234-5218 Cell: 918-304-9443 e-mail: isham.t@sno-nsn.gov From: Davis, Jennifer [1]

Sent: Friday, January 19, 2018 3:07 PM To: Theodore Isham F-9

Cc: Vokoun, Patricia

Subject:

Early Site Permit Application for the Clinch River Nuclear Site in Roane County, Tennessee Mr. Isham, My colleague Pat Vokoun and I called your office to follow up on a letter sent by our agency (U.S. Nuclear Regulatory Commission (NRC)) from April 2017. Per request, we are re-sending this letter for your files.

The NRC is reviewing an application for an early site permit (ESP) from Tennessee Valley Authority for the proposed construction and operation of two or more Small Modular Reactors (SMRs) at the Clinch River site in Oak Ridge, Roane County, Tennessee. As part of this application process, the NRC will be completing an environmental impact statement in compliance with the National Environmental Policy Act (NEPA). NRC will also be coordinating its National Historic Preservation Act (NHPA) Section 106 review through the NEPA process in accordance with 36 CFR 800.8(c).

The ESP application and review process makes it possible to evaluate and resolve safety and environmental issues related to siting potential future SMRs at the CRN Site. An ESP does not, however, authorize construction and operation of the SMRs. Such authorization would require a separate application by TVA to the NRC, necessitating additional NEPA and NHPA review.

If you have any questions, please feel free to reach out to me or with Patricia Vokoun.

Patricia is the environmental project manager for this review. Her contact information is provided in the attached letter.

Thank you, Jennifer Jennifer A. Davis Senior Project Manager Office of New Reactors U.S. Nuclear Regulatory Commission (301) 415-3835 F-10

From: Karen Brunso To: Davis, Jennifer

Subject:

[External_Sender] Application for the Clinch River Nuclear Site in Roane County, Tennessee Date: Monday, January 22, 2018 3:36:41 PM Attachments: image001.gif

Dear. Ms. Davis,

Thank you for the letter for the initiation of Section 106 and scoping process for the environmental review of the early site permit application for the Clinch River Nuclear Site in Roan County, Tennessee. The Chickasaw Nation has no additional comments on the proposed permit. Please let us know if there are any questions.

Respectfully, Karen Brunso Tribal Historic Preservation Officer The Chickasaw Nation Department of Culture & Humanities Division of Historic Preservation P.O. Box 1548 Ada, OK 74821-1548 Phone: 580-272-1106 Cell: 580-399-6017 Email: karen.brunso@chickasaw.net F-11

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) &RUUHVSRQGHQFH5HFHLYHG5HJDUGLQJ7KUHDWHQHG(QGDQJHUHGDQG6HQVLWLYH 6SHFLHVDQGWKHLU+DELWDWV United States Department of the Interior FISH AND WILDLIFE SERVICE Tennessee ES Office 446 Neal Street Cookeville, Tennessee 38501 April 21, 2017 Ms. Cindy Bladey Office of Administration OWFN-12-H08 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

Docket ID NRC-2016-0119 FWS#2017-CPA-0711. Notice of Intent for the Nuclear Regulatory Commission to Prepare an Environmental Impact Statement and Conduct a Scoping Process for the Clinch River Nuclear Site located in Roane County, Tennessee.

Dear Ms. Bladey:

U.S. Fish and Wildlife Service (Service) personnel have reviewed the Nuclear Regulatory Commissions (NRC) Notice of Intent to prepare an Environmental Impact Statement (EIS) to address the proposed Clinch River Nuclear Site (CRN), which would be situated on an approximately 1,200 acre site along the Clinch River in Roane County, Tennessee. The NOI indicates that Tennessee Valley Authority (TVA) has submitted an early site permit for the CRN.

The proposed EIS would consider the environmental impacts of two (2) or more small modular reactor modules (up to 800 MWe, 2420 MWt).

Potential natural resource impacts evaluated in the EIS would include air quality, surface water, groundwater, aquatic ecology, vegetation, wildlife, threatened and endangered species, wetlands, forest resources, and natural areas and parks. In addition, NRC would evaluate socioeconomic impacts and impacts on archaeological and historic resources and aesthetics (visual, noise and odors).

The Service has reviewed recent and historical endangered species collection records within the locality of the proposed project site. Records indicate that several federally listed terrestrial and aquatic species occur within the vicinity of the site identified by NRC/TVA. Due to the presence of these species within the proposed project vicinity, we request that NRC, or a designated representative thereof, work closely with the Service when addressing threatened and endangered species within the action area to ensure that the appropriate species and federally designated critical habitats are included in an assessment. While we realize that TVA has extensive records F-14

for federally listed and at-risk species in its Natural Heritage Database, we also suggest that NRC utilize the U.S. Fish and Wildlife Service Information for Planning and Conservation (IPaC) system located at: https://ecos.fws.gov/ipac/, in addition to TVAs Natural Heritage Database, to obtain the most comprehensive species information. The proposed action area can be input into IPaC and a current species list, appropriate for the proposed project, will immediately be produced. Furthermore, the Service recommends the development of a Biological Assessment, as required by 50 CFR 402.12, which would analyze the potential effects of the action on listed and proposed species and designated and proposed critical habitat. The Biological Assessment will identify whether any such species or habitat are likely to be adversely affected by the action and is used in determining whether formal consultation or a conference is necessary. When evaluating potential impacts to species, both direct and indirect impacts should be considered.

Additionally, we recommend that NRC address and include known locations of wetlands during their analysis with determinations of potential future effects to the resource. We also request that NRC coordinate frequently and early with the Service regarding the proposed action to remain in compliance with section 7 of the Endangered Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.). Additionally, the Service request that NRC coordinate in regards to any potential survey efforts for threatened and endangered species.

We further recommend that NRC address and include known locations of migratory birds, afforded certain levels of protection under the Migratory Bird Treaty Act of 1918 (16 U.S.C.,

Chapter 7, Subchapter II), and determine potential future effects to these resources. In addition, we request that NRC determine the potential for presence and effects to the bald eagle (Haliaeetus leucocephalus) in the action area. This species is currently afforded certain levels of protection under the Bald and Golden Eagle Protection Act (16 U.S.C. 668-668c), enacted in 1940, and the MBTA. NRC should also identify hibernacula utilized by at-risk or federally listed bat species in the vicinity of the action area and determine if the proposed action could affect any individuals.

As NRC proceeds with its analysis, we will provide additional comments specific to the action.

We can also provide a comprehensive list of species which we feel could be affected by the proposed action at a later date, upon request. Please anticipate that a representative of the Service will attend the Public Scoping Meeting on May 15, 2017. If you have any questions regarding our comments, please contact Dustin Boles of my staff at 931/525-4984 or by email at dustin_boles@fws.gov.

Sincerely, Mary E. Jennings Field Supervisor 2

F-15

United States Department of the Interior FISH AND WILDLIFE SERVICE Tennessee ES Office 446 Neal Street Cookeville, Tennessee 38501 May 5, 2017 Mr. Allen H. Fetter Licensing Branch 3 Division of New Reactor Licensing Office of New Reactors U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

FWS# 2017-I-0473. U.S. Nuclear Regulatory Commission - Requests for Participation in the Environmental Scoping Process and a List of Federally Protected Species Within the Area Under Evaluation for the Proposed Clinch River Nuclear Site Located in Oak Ridge, Roane County, Tennessee.

Dear Mr. Fetter:

Thank you for your correspondence dated April 20, 2017, regarding the U.S. Nuclear Regulatory Commissions (NRC) request for participation in the environmental scoping process and request for a list of federally protected species within the area under evaluation for the proposed Clinch River Nuclear Site (CRN) located in Oak Ridge, Roane County, Tennessee. The proposed action to issue an early site permit (ESP) would grant approval of a site that could be used for the future construction and operation of two (2) or more small modular reactors (SMRs). If approved, the ESP would not authorize the applicant, Tennessee Valley Authority (TVA), to begin construction of the SMRs. U.S. Fish and Wildlife Service (Service) personnel have reviewed the information submitted, and we offer the following comments.

Correspondence indicates that the proposed CRN would be located on an approximate 935 acre site on the northern bank of the Clinch River arm of Watts Bar Reservoir. Furthermore, the proposed site is located downstream of Melton Hill Dam between Clinch River Mile 14.5 and 19. The site was evaluated in the 1970s by the TVA for a breeder reactor, which resulted in some site excavation being performed. However, the breeder reactor was not completed and the site was revegetated.

To support the CRN, it would be necessary for the TVA to construct a new 69-kV underground transmission line, approximately 5-miles long, within existing right-of-ways (ROWs) for an active 500-kV overhead transmission line to connect the CRN switchyard to 69-kV transformers at the Bethel Valley Substation on the Oak Ridge Reservation (ORR). TVA would also re-route an existing 161-kV overhead transmission line to avoid the proposed new power block location. Establishment of a barge/traffic area (BTA) on the ORR just north of the CRN site would also be necessary. The BTA would encompass an inactive barge terminal that would be refurbished and roadways would be improved in order to receive and transport SMR components to the CRN site. Additionally, segments of transmission systems well beyond the CRN site would require modifications to support the proposed facility. According to the proposal, these locations are in the following counties: Franklin, Warren, White, Van Buren, Bledsoe, Rhea, Putnam, Cumberland, Roane, F-16

Anderson, Scott, Knox, Campbell, Grainger, Hawkins, Greene, Jefferson, Hamblen, and Cocke. These modifications would include uprating, reconductoring, or rebuilding existing transmission lines.

Correspondence indicates that additional ROWs would not be established, cleared, or widened to support these activities.

The proposed CRN cooling system consist of an intake system, discharge system, and an atmospheric discharge for heat. As indicated in the correspondence, a maximum of 25,608 gallons per minute (gpm) would be withdrawn from the Clinch River to make up for water lost or used via drift (8 gpm), evaporation (12,800 gpm), and blowdown (12,800 gpm). The Clinch River would receive the discharge from the blowdown.

According to the Services IPaC database, several federally threatened and endangered species potentially occur within near proximity of the proposed CRN site, ORR (site 2 and 8), and the proposed transmission line upgrades. We have included a species list as an enclosure to this letter, which identifies a list of species that may occur near the identified action areas. The Service recommends that you evaluate the proposed project for potential direct and indirect impacts to these listed species or their habitats in compliance with section 7 of the Endangered Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.).

While evaluating potential impacts to these species, please also consider modification of any associated critical habitat for listed species.

While the project proponent is not required to consult on petitioned species, Section 7(a)(4) of the Endangered Species Act of 1973 does provide a mechanism for identifying and resolving potential conflicts between a proposed action and proposed species during the early planning stage. Therefore, we take this opportunity to recommend that you consider impacts to the hellbender (Cryptobranchus alleganiensis),

petitioned for listing in FY18. There are historic records of this species occurring near the proposed site of the CRN. Additionally, there are records of the Berry Cave salamander (Gyrinophilus gulolineatus), which is petitioned for listing in FY19.

The Service recommends that you coordinate with the Tennessee Wildlife Resources Agency and Tennessee Department of Environment and Conservations Natural Heritage Program to address concerns regarding state listed species. Please anticipate that a Service representative will attend the public meeting on May 15, 2017. Thank you for the opportunity to comment on the proposed action. If you have any questions regarding our comments, please contact Dustin Boles of my staff at 931/525-4984 or at dustin_boles@fws.gov.

Sincerely, Mary E. Jennings Field Supervisor Enclosures as stated 2

F-17

Table 1. Federally listed species which may occur within near proximity of the proposed CRN and ORR sites.

Critical Habitat Species - Common Name Scientific Name Federal Status Within Action Area Alabama Lampmussel Lampsillis virescens Endangered No Anthony's Riversnail Athearnia anthonyi Endangered No Cracking Pearlymussel Hemistena lata Endangered No Cumberland Bean Villosa trabalis Endangered No Dromedary Pearlymussel Dromus dromas Endangered No Fanshell Cyprogenia stegaria Endangered No Finerayed Pigtoe Fusconaia cuneolus Endangered No Gray bat Myotis grisescens Endangered No Indiana bat Myotis sodalis Endangered No Northern Long-eared Bat Myotis septentrionalis Threatened No Orangefoot Pimpleback Plethobasus cooperianus Endangered No Pink Mucket Lampsillis abrupta Endangered No Purple Bean Villosa perpurpurea Endangered No Ring Pink Obovaria retusa Endangered No Rough Pigtoe Pleurobema plenum Endangered No Sheepnose Mussel Plethobasus cyphyus Endangered No Shiny Pigtoe Fusconaia cor Endangered No Snail Darter Percina tanasi Threatened No Spectaclecase Cumberlandia monodonta Endangered No Spotfin Chub Erimonax monachus Threatened No Turgid Blossom Epioblasma turgidula Endangered No Virginia Spiraea Spiraea virginiana Threatened No White Fringeless Orchid Platanthera integrilabia Threatened No White Wartyback Plethobasus cicatricosus Endangered No 3

F-18

Table 2. Federally listed species which may occur within near proximity of the proposed transmission line upgrades.

Critical Habitat Species - Common Name Scientific Name Federal Status Within Action Area Anthony Riversnail Athearnia anthonyi Endangered No Appalachian Elktoe Alasmidonta raveneliana Endangered No Birdwing Pearlymussel Lemiox rimosus Endangered No Blackside Dace Chrosomus [= Phoxinus] cumberlandensis Threatened No Bluemask (Jewel) Darter Etheostoma akatulo Endangered No Catspaw Epioblasma obliquata obliquata Endangered No Chucky Madtom Noturus crypticus Endangered Yes Clubshell Pleurobema clava Endangered No Cracking Pearlymussel Hemistena lata Endangered No Cumberland Bean Vilosa trabalis Endangered No Cumberland Elktoe Alasmidonta atropurpurea Endangered Yes Cumberland Monkeyface Quadrula intermedia Endangered No Cumberland Pigtoe Pleurobema gibberum Endangered No Cumberland Rosemary Conradina verticillata Threatened No Cumberland Sandwort Arenaria cumberlandensis Endangered No Cumberlandian Combshell Epioblasma brevidens Endangered Yes Dromedary Pearlymussel Dromus dromas Endangered No Duskytail Darter Etheostoma percurum Endangered No Fanshell Cyprogenia stegaria Endangered No Finerayed Pigtoe Fusconaia cuneolus Endangered No Fluted Kidneyshell Ptychobranchus subtentum Endangered Yes Gray Myotis Myotis grisescens Endangered No Hart's-tongue Fern Asplenium scolopendrium var. americanum Threatened No Indiana Myotis Myotis sodalis Endangered No Large-flowered Skullcap Scuttellaria montana Threatened No Laurel Dace Chrosomus saylori Endangered Yes Littlewing Pearlymussel Pegias fabula Endangered No Morefield's Leather-flower Clematis morefieldii Endangered No Northern Long-eared Bat Myotis septentrionalis Threatened No Orangefoot Pimpleback Plethobasus cooperianus Endangered No Oyster Mussel Epioblasma capsaeformis Endangered Yes Pale Lilliput Toxolasma cylindrellus Endangered No Palezone Shiner Notropis albizonatus Endangered No 4

F-19

Pink Mucket Lampsillis abrupta Endangered No Price's Potato-bean Apios priceana Threatened No Purple Bean Vilosa perpurpurea Endangered Yes Rabbitsfoot Quadrula cylindrica cylindrica Threatened No Rayed Bean Villosa fabalis Endangered No Ring Pink Obovaria retusa Endangered No Rough Pigtoe Pleurobema plenum Endangered No Rough Rabbitsfoot Quadrula cylindrica strigillata Endangered No Sheepnose Plethobasus cyphyus Endangered No Shiny Pigtoe Fusconaia cor Endangered No Slabside Pearlymussel Pleuronaia dolabelloides Endangered Yes Slender Chub Erimystax cahni Threatened No Small Whorled Pogonia Isotria medeoloides Threatened No Snail Darter Percina tanasi Threatened No Snuffbox Epioblasma triquetra Endangered No Spectaclecase Cumberlandia monodonta Endangered No Spotfin Chub Erimonax monachus Threatened Yes Tan Riffleshell Epioblasma florentina walkeri Endangered No Virginia Spiraea Spiraea virginiana Threatened No White Fringeless Orchid Platantherea integrilabia Threatened No White Wartyback Plethobasus cicatricosus Endangered No Yellowfin Madtom Noturus flavipinnis Threatened No 5

F-20

ClinchRiverESPEISCEm Resource From: Long, Larry <Long.Larry@epa.gov>

Sent: Tuesday, May 30, 2017 2:56 PM To: ClinchRiverESPEIS Cc: Vokoun, Patricia; Militscher, Chris

Subject:

[External_Sender] Informal Pre-permit Clinch River Nuclear Site I have reviewed the Nuclear Regulatory Commissions Opens House materials and the federal registry solicitation for public comments in reference to Tennessee Valley Authoritys (TVA) Pre-Permit application for the Clinch River Nuclear generation station in Oak Ridge TN. Keeping with Nuclear Regulatory s (NRCs) mission to protect public health and safety, promote common defense and security, and to protect the environment, along with EPAs mission for the protection of public health and the environment, Region 4 NEPA Program Office provides the following comments for your considerations.

NRC and TVA may want to consider the advantages of early consultation with federal, state and tribal agencies for the purpose of streamlining the permitting process during the NEPA analysis. One advantage of an early consultation process could be TVA obtaining their environmental permits shortly after the NEPA Record of Decision (ROD) issuance.

The inclusion of NRCs systematic approach (10 CFR Part 51) along with state and federal permitting issues into the NRCs pre-permitting process can provide a streamline NEPA analysis that helps to eliminate duplications in the permitting analysis. This will help to provide a more productive analytical process overall.

NRC and TVA may also want to consider incorporating the Army Corps of Engineers into the early consultation process to include Clean Water Act (CWA) 404 permitting requirements, such as avoidance and minimization, along with mitigation requirements, if any.

A major issue with nuclear facilities is the disposal of radioactive waste products. NRC may want to consider an economic feasibility comparison study for vitrification of waste products verses current storage and disposal practices as part of the EIS.

Please provide us with a copy (electronic, CD with two hardcopies) of future NEPA documents when they become available.

Thank you for your time.

Larry Long Physical Scientist/Sr. Principle Reviewer NEPA Resource Conservation & Restoration Division EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303 404-562-9460 404-562-9598(FAX) long.larry@epa.gov CONFIDENTIALITY NOTICE: This message is being sent by or on behalf of the Environmental Protection Agency. It is intended exclusively for the individuals(s) or entity(s) to whom or to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempted from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy, or disseminate this message or any 1

F-21

part of it. If you have received this message in error, please notify the sender immediately by email and delete all copies of the message.

2 F-22

STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION NASHVILLE, TENNESSEE 37243-0435 ROBERT J. MARTINEAU, JR. BILL HASLAM COMMISSIONER GOVERNOR June 12, 2017 Via Electronic Mail to ClinchRiverESPEIS@nrc.gov Attn: Patricia Vokoun, NRC Environmental Project Manager Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Ms. Vokoun:

The Tennessee Department of Environment and Conservation (TDEC) appreciates the opportunity to provide comments on the Nuclear Regulatory Commission (NRC) Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS) related to the Tennessee Valley Authority (TVA) early site permit (ESP) for the Clinch River Nuclear (CRN) Site near Oak Ridge, Tennessee.1 TDEC understands that the ESP application by TVA is an initial determination process for resolving safety and environmental siting issues for a potential future Small Modular Reactor (SMR) at the CRN Site, but does not authorize construction and operation of a nuclear power plant. Additionally, as a Federal agency, TVA is required to comply with the National Environmental Policy Act (NEPA) and the National Historic Preservation Act (NHPA) independently of NRC requirements. The NRC expects to publish a draft EIS in June 2018.

The proposed CRN Site, is located in Roane County, Tennessee, along the Clinch River, approximately 25 miles west-southwest of downtown Knoxville, Tennessee.

Water Resources x Given the expected activity associated with this proposed project, the following TDEC permitting requirements are likely to apply.2 The construction of a Small Modular Reactor (SMR) at the TVA CRN Site will require a construction storm water permit based on the land disturbance at the site being more than one acre.3 A National Pollutant Discharge Elimination 1

For more information on the TVA CRN proposal, including the ESP Application (ML16144A086) please visit https://www.nrc.gov/reactors/new-reactors/esp/clinch-river.html. Specific information regarding the TVA CRN proposal as is discussed in TDECs consolidated response is taken from the Part 3 - Environmental Report submitted as part of TVAs ESP to NRC. The Part 3 -

Environmental Report can be found at https://www.nrc.gov/docs/ML1614/ML16144A145.html.

2 As this is a scoping document for a forthcoming EIS, there is not sufficient information to address the requirements for the permits in more detail. There have not been any public water supply intakes, wells or springs identified that would be impacted from the proposed facility, but as additional details are provided more permitting requirements may be necessary.

3 For more information on NPDES Stormwater Construction Permitting please visit http://www.tn.gov/environment/article/permit-water-npdes-stormwater-construction-permit.

F-23

Permit (NPDES) permit will be required for the discharge from the facility into the Clinch River.4 An Aquatic Resource Alteration Permit (ARAP) will be required for the water withdrawal at the facility.5 This facility will also be required to have a Tennessee Storm Water Multi-Sector General Permit, which will include the barge loading and offloading facility.6 x The TVA CRN Site Part 3 - Environmental Report submitted to the NRC as part of the ESP Application notes that due to the interactions of the Watts Bar Dam, Melton Hill Dam and Fort Loudon Dam, that the river flow can be upstream, downstream or quiescent, depending on the modes of operation within the vicinity of the site. This could mean that for short periods of time, the intake at the CRN facility would be downstream of the NPDES discharge point for the facility. It is not clear what impact if any this flow reversal would have, but TDEC recommends that the forthcoming EIS consider this variable.

x Investigations by DOE and TDECs Division of Remediation (DoR) - Oak Ridge Office have shown that there is deep ground water flow that goes under the Clinch River from the Oak Ridge National Laboratory (ORNL).7 Migration of chlorinated solvents within the Conasauga Group formation, under the Clinch River along strike to the southwest, has resulted in contaminated private wells at Hoods Ridge. There is also suspected contamination from Oak Ridge Reservation in the Jones Island area across the Clinch River from Oak Ridge Reservation as well. TDEC recommends that any private well or spring use occurring in the area be investigated as a part of the EIS to address the unique geology and hydraulic connectivity of the site. TDEC also recommends that the extent of the existing ground water contamination, including pre-existing radiological constituents and volatile organic compounds in the groundwater, at the proposed CRN Site be determined by TVA and addressed in the forthcoming draft EIS.8 Solid Waste Management x According to the TVA CRN ESP Application Part 3 - Environmental Report, the CRN Site SMR is expected to be a Small Quantity Generator (SQG) of Hazardous Waste and will also construct and operate an on-site landfill9 for construction/demolition wastes. Any nonradioactive 4

For more information on NPDES Discharge Permitting please visit https://www.tn.gov/environment/article/permit-water-national-pollutant-discharge-elimination-system-npdes-permit.

5 For more information on the ARAP program please visit https://www.tn.gov/environment/article/permit-water-aquatic-resource-alteration-permit.

6 For more information on the NPDES Industrial Stormwater General Permit program please visit http://www.tn.gov/environment/article/permit-water-npdes-industrial-stormwater-general-permit.

7 The proposed CRN Site is located in complex folded/faulted karst geology of the Valley and Ridge Province. The Copper Creek Thrust Fault cuts southwest/northeast across the toe of the boot-shaped site. A lesser unnamed thrust fault cuts across the northern portion of the site. Karst ground water flow does not behave as laminar flow and does not follow Darcys Law - interstitial porosity plays a very minor role but appears to be a significant focus in TVAs investigations. The beds of the Chickamauga Group formations in the area are dipping at 30 plus degrees to the southeast. Ground water flow is going to generally be along strike of the beds to the southwest, as is evidenced from the offsite contamination from the Department of Energy (DOE) ORNL.

8 TVA notes in its CRN Site ESP Application Part 3 - Environmental Report that monitoring well OW-422L in the center of the CRN Site has petroleum-based contamination. This location is slightly more than 1/2 mile west of the area of Hoods Ridge where chlorinated solvent contamination has been identified from the DOE ORNL. The existence of pre-existing site contamination is an issue of concern for both TDEC Division of Remediation and Division of Water Resources.

9 If TVA wishes to construct and operate a solid waste disposal facility (i.e., construction/demolition landfill) at the CRN Site they will be required to obtain a landfill permit from the TDEC Division of Solid Waste Management. Information about the permitting process and required application materials can be found at http://www.tn.gov/environment/article/permit-waste-landfill-permit.

F-24

hazardous and nonhazardous wastes associated with the construction, operation, and decommissioning of the CRN facility as well as construction of an on-site landfill must be handled in accordance the states Solid and Hazardous Waste Rules and Regulations.10 Furthermore, mixed wastes (e.g. containing low-level radioactive waste) with a hazardous component must be handled in accordance with the NRC requirements but also with the aforementioned Rules and Regulations. TDEC recommends that waste management considerations as specifically regulated by the Rules and Regulations of the state of Tennessee be incorporated in the forthcoming NRC EIS.

x Sections 3.6 and 5.5 of the Environmental Report describe the various hazardous and non-hazardous waste streams that are expected to be generated as well as their impacts and procedures for management (e.g. Spill/Discharge Response Program, TVA-approved vendors for transport and disposal, a Waste Minimization Plan). While this information is informative, TDEC recommends further discussion of specific hazardous and mixed waste management and monitoring practices, treatment methods, and storage areas for attaining compliance with the state and limiting adverse environmental impacts and irreversible environmental commitments during construction and operation of the facility and its offsite rail, barge terminal, and underground transmission line improvement projects in the forthcoming NRC EIS.

Air Pollution Control x Should any land clearing activities or disposal of brush or trees/tree limbs occur, TDEC prefers that wood waste be disposed of by chipping, grinding, or composting rather than open burning.

However, if open burning does occur during site preparation and construction, open burning regulations should be followed. TDEC recommends that detailed clearing activities, total amount of areas where soils are to be disturbed, and associated impacts be addressed in the draft EIS.11 x Water cooling tower emissions are evaluated for permitting and have been permitted at other existing TVA nuclear plants. The water vapor itself is not a regulated emission, however the resultant particulates that arise from evaporation (minerals found in the local river water or streams) are considered to be potential emissions as are any algaecide or slime mold/fungus treatments added to the water to act as a biocide. Cooling towers are also associated with certain other potential pathogenic airborne illnesses including Legionnaires disease and some amoebae considered harmful. The site may have air contaminant emissions from other onsite air emission sources that are required to have an air contaminant permit from the Division of Air Pollution Control. TDEC recommends that appropriate entities involved in the project review potentially applicable air permits as well as work with the Division of Air Pollution Control to ensure all emission sources are properly identified and permitted.12 10 Reference TDEC SWM Rule 0400 Chapter 11 for Solid Waste and Chapter 12 for Hazardous Waste http://sos.tn.gov/effective-rules.

11 TDEC APC Rule 1200-3-4-.01 et seq., http://sos.tn.gov/effective-rules. Additional information on open burning in Tennessee is available at https://tn.gov/environment/article/apc-open-burning and http://www.burnsafetn.org/.

12 For more information on TDEC Air Pollution Control permits please visit https://www.tn.gov/environment/topic/permit-air.

F-25

Archaeology x TDEC concurs with the plan to conduct Phase I/II site evaluation of the property proposed for the TVA CRN Site. This archaeological evaluation will determined if prehistoric and/or historic sites eligible for the National Register of Historic Places (NRHP) are located within the proposed property. If an archaeological site is determined eligible for inclusion on the NRHP, additional archaeological considerations will be necessary for the project to move forward.13 TDEC appreciates the opportunity to comment on this NOI from NRC to prepare an EIS for the TVA CRN Site. Please note that these comments are not indicative of approval or disapproval of the proposed action or its alternatives, nor should they be interpreted as an indication regarding future permitting decisions by TDEC. Please contact me should you have any questions regarding these comments.

Sincerely, Kendra Abkowitz, PhD Director of Policy and Planning Tennessee Department of Environment and Conservation Kendra.Abkowitz@tn.gov (615) 532-8689 cc: Barry Brawley, TDEC, DOR Lacey Hardin, TDEC, APC Lisa Hughey, TDEC, SWM Tom Moss, TDEC, DWR Mark Norton, TDEC, DOA 13 For more information on the Tennessee Division of Archeology please visit https://www.tn.gov/environment/section/arch-archaeology. If there are site specific archaeological questions please contact Jennifer Barnett at (615)687-4780 or Jennifer.Barnett@tn.gov.

F-26

United States Department of the Interior FISH AND WILDLIFE SERVICE Tennessee ES Office 446 Neal Street Cookeville, Tennessee 38501 July 20, 2017 Mr. Allen H. Fetter Licensing Branch 3 Division of New Reactor Licensing Office of New Reactors U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 John T. Baxter, Jr.

Manager Biological Compliance Tennessee Valley Authority WT 11C-K 400 West Summit Hill Drive Knoxville, Tennessee 37902

Subject:

FWS# 2017-I-0473. U.S. Nuclear Regulatory Commission (NRC) - Updated List of Federally Threatened and Endangered Species that Potentially Occur near the Proposed Clinch River Small Modular Nuclear Reactor Facility in Oak Ridge, Roane County, Tennessee.

Dear Mr. Fetter and Mr. Baxter:

At the request of the Tennessee Valley Authority (TVA), the U.S. Fish and Wildlife Service (Service) attended a meeting with TVA and NRC staff on July 11, 2017, in regards to the proposed Clinch River Small Modular Reactor Nuclear Facility (CRN) in Oak Ridge, Roane County, Tennessee. The meeting included discussions and verification of the federally threatened and endangered species list provided by the Service and addressed to the NRC in a letter dated May 5, 2017.

TVA provided the Service with a CRN species list based upon the TVA database, which was addressed to the Service dated September 7, 2016. The Service did not respond to this letter, which was a request to verify the species list; however, receipt of this correspondence by the Service has not been verified.

The species list provided by TVA identified only those species that could occur on or in proximity to the CRN site in Roane County, Tennessee. At the time of this TVA correspondence, transmission system work associated with development of the CRN site had not been identified.

F-27

As previously established during NRCs Environmental Impact Statement Scoping Meeting on May 17, 2017, the species lists in TVAs September 7, 2016, correspondence to the Service and the Services May 15, 2017, correspondence to NRC were not identical. The Service attributes these differences, in part, to the lack of a completely defined action area at the time of the NRC species list request. The Services species list was compiled using the IPaC database for Roane County, Tennessee, which represents a 326.18 square mile area, according to IPaC. The TVA has now described the action area in Roane County as the 935-acre CRN site, the Clinch River embayment of Watts Bar Reservoir, and the mainstem Tennessee River portion of Watts Bar Reservoir downstream to Watts Bar Dam. Also included in the current action area are segments of TVAs transmission system in Franklin, Warren, White, Van Buren, Bledsoe, Rhea, Putnam, Cumberland, Roane, Anderson, Scott, Knox, Campbell, Grainger, Hawkins, Greene, Jefferson, Hamblen, and Cocke counties, Tennessee. The Service considers several previously identified species extirpated from the described action area. As a result of these discussions and determinations, the TVA and Service have examined each federally protected species previously identified and have mutually agreed upon which species warrant further consideration.

The proposed CRN facility would be located on an approximate 935-acre site on the northern bank of the Clinch River arm of Watts Bar Reservoir. Furthermore, the proposed site is located downstream of Melton Hill Dam between Clinch River Mile 14.5 and 19. The site was evaluated in the 1970s by the TVA for a breeder reactor, which resulted in some site excavation being performed. However, the breeder reactor was not completed and the site was revegetated. The proposed action is to construct and operate two (2) or more small modular reactors at the CRN site.

The proposed CRN cooling system consist of an intake system, discharge system, and an atmospheric discharge for heat. As indicated in the correspondence, a maximum of 25,608 gallons per minute (gpm) would be withdrawn from the Clinch River to make up for water lost or used via drift (8 gpm),

evaporation (12,800 gpm), and blowdown (12,800 gpm). The Clinch River would receive the discharge from the blowdown.

To support the CRN, it would be necessary for the TVA to construct a new 69-kV underground transmission line, approximately 5-miles long, within existing right-of-ways (ROWs) for an active 500-kV overhead transmission line to connect the CRN switchyard to 69-kV transformers at the Bethel Valley Substation on the Oak Ridge Reservation (ORR). TVA would also re-route an existing 161-kV overhead transmission line to avoid the proposed new power block location. Establishment of a barge/traffic area (BTA) on the ORR just north of the CRN site would also be necessary. The BTA would encompass an inactive barge terminal that would be refurbished and roadways would be improved in order to receive and transport SMR components to the CRN site. Additionally, segments of transmission systems well beyond the CRN site would require modifications to support the proposed facility. According to the proposal, these modification locations are all within the nineteen (19) counties listed above. These modifications could include uprating, re-conductoring, or rebuilding existing transmission lines. Correspondence indicates that additional ROWs would not be established, cleared, or widened to support these activities. The current action area, as defined by TVA and the Service, would include all affected transmission line segments within the previously identified counties, as well as the CRN site in Roane County, Tennessee.

F-28

As discussed, the Service originally identified species with potential to occur within or in near proximity of the area using the Services IPaC database for Roane County, Tennessee. Upon further consideration, the Service has removed several federally threatened and endangered species from the CRN list. We have included this updated species list as an enclosure to this letter (Table 1.). The following species are not considered extant within the project action area and have been removed from the Services species list: Alabama lampmussel (Lampsillis virescens), Anthonys riversnail (Athearnia anthonyi), cracking pearlymussel (Hemistena lata), Cumberland bean (Villosa trabalis), dromedary pearlymussel (Dromus dromas), fanshell (Cyprogenia stegaria), finerayed pigtoe (Fusconaia cuneolus), orangefoot pimpleback (Plethobasus cooperianus), purple bean (Villosa perpurpurea), ring pink (Obovaria retusa), rough pigtoe (Pleurobema plenum), shiny pigtoe (Fusconaia cor), snail darter (Percina tanasi), spectaclecase (Cumberlandia monodonta), turgid blossom (Epioblasma turgidula), Virginia spiraea (Spiraea virginiana), white fringeless orchid (Platanthera integrilabia), and white wartyback (Plethobasus cicatricosus).

The entire species list for the transmission line upgrades provided by the Service in May 5, 2017, correspondence to NRC should be carried forward for further analysis; including designated critical habitat (DCH) crossed by or adjacent to the proposed transmission line upgrades. Species with DCH within or adjacent to the project action area are identified in the species list (Table 2.). The Service recommends that you evaluate the proposed project for potential direct, indirect, and cumulative impacts to these listed species or their habitats in compliance with section 7 of the Endangered Species Act of 1973 (87 Stat. 884, as amended; 16 U.S.C. 1531 et seq.).

While the project proponent is not required to consult on petitioned species, Section 7(a)(4) of the Endangered Species Act of 1973 does provide a mechanism for identifying and resolving potential conflicts between a proposed action and proposed species during the early planning stage. Therefore, we take this opportunity to recommend that you consider impacts to the hellbender (Cryptobranchus alleganiensis), petitioned for listing in FY18. IPaC and TVA data indicate there are historic records of this species occurring near the proposed site of the CRN.

The Service recommends that you coordinate with the Tennessee Wildlife Resources Agency and Tennessee Department of Environment and Conservations Natural Heritage Program to address concerns regarding state listed species. If you have any questions regarding our comments, please contact Dustin Boles of my staff at 931/525-4984 or at dustin_boles@fws.gov.

Sincerely, Mary E. Jennings Field Supervisor Enclosures as stated F-29

Table 1. Federally listed species, occurring near the CRN site, Roane County, Tennessee.

Critical Habitat Species - Common Name Scientific Name Federal Status Within Action Area Gray bat Myotis grisescens Endangered No Indiana bat Myotis sodalis Endangered No Northern Long-eared Bat Myotis septentrionalis Threatened No Pink Mucket Lampsillis abrupta Endangered No Sheepnose Mussel Plethobasus cyphyus Endangered No Spotfin Chub Erimonax monachus Threatened No Table 2. Federally listed species, which may occur within near proximity of the proposed transmission line upgrades: Franklin, Warren, White, Van Buren, Bledsoe, Rhea, Putnam, Cumberland, Roane, Anderson, Scott, Knox, Campbell, Grainger, Hawkins, Greene, Jefferson, Hamblen, and Cocke counties, Tennessee.

Critical Habitat Within or Species - Common Name Scientific Name Federal Status Adjacent to the Action Area Anthony Riversnail Athearnia anthonyi Endangered No Appalachian Elktoe Alasmidonta raveneliana Endangered No Birdwing Pearlymussel Lemiox rimosus Endangered No Chrosomus [= Phoxinus]

No Blackside Dace cumberlandensis Threatened Bluemask (Jewel) Darter Etheostoma akatulo Endangered No Catspaw Epioblasma obliquata obliquata Endangered No Chucky Madtom Noturus crypticus Endangered Yes Clubshell Pleurobema clava Endangered No Cracking Pearlymussel Hemistena lata Endangered No Cumberland Bean Vilosa trabalis Endangered No Cumberland Elktoe Alasmidonta atropurpurea Endangered Yes Cumberland Monkeyface Quadrula intermedia Endangered No Cumberland Pigtoe Pleurobema gibberum Endangered No Cumberland Rosemary Conradina verticillata Threatened No Cumberland Sandwort Arenaria cumberlandensis Endangered No Cumberlandian Combshell Epioblasma brevidens Endangered Yes Dromedary Pearlymussel Dromus dromas Endangered No Duskytail Darter Etheostoma percurum Endangered No Fanshell Cyprogenia stegaria Endangered No F-30

Finerayed Pigtoe Fusconaia cuneolus Endangered No Fluted Kidneyshell Ptychobranchus subtentum Endangered Yes Gray Myotis Myotis grisescens Endangered No Asplenium scolopendrium var.

No Hart's-tongue Fern americanum Threatened Indiana Myotis Myotis sodalis Endangered No Large-flowered Skullcap Scuttellaria montana Threatened No Laurel Dace Chrosomus saylori Endangered Yes Littlewing Pearlymussel Pegias fabula Endangered No Morefield's Leather-flower Clematis morefieldii Endangered No Northern Long-eared Bat Myotis septentrionalis Threatened No Orangefoot Pimpleback Plethobasus cooperianus Endangered No Oyster Mussel Epioblasma capsaeformis Endangered Yes Pale Lilliput Toxolasma cylindrellus Endangered No Palezone Shiner Notropis albizonatus Endangered No Pink Mucket Lampsillis abrupta Endangered No Price's Potato-bean Apios priceana Threatened No Purple Bean Vilosa perpurpurea Endangered Yes Rabbitsfoot Quadrula cylindrica cylindrica Threatened No Rayed Bean Villosa fabalis Endangered No Ring Pink Obovaria retusa Endangered No Rough Pigtoe Pleurobema plenum Endangered No Rough Rabbitsfoot Quadrula cylindrica strigillata Endangered No Sheepnose Plethobasus cyphyus Endangered No Shiny Pigtoe Fusconaia cor Endangered No Slabside Pearlymussel Pleuronaia dolabelloides Endangered Yes Slender Chub Erimystax cahni Threatened No Small Whorled Pogonia Isotria medeoloides Threatened No Snail Darter Percina tanasi Threatened No Snuffbox Epioblasma triquetra Endangered No Spectaclecase Cumberlandia monodonta Endangered No Spotfin Chub Erimonax monachus Threatened Yes Tan Riffleshell Epioblasma florentina walkeri Endangered No Virginia Spiraea Spiraea virginiana Threatened No White Fringeless Orchid Platantherea integrilabia Threatened No White Wartyback Plethobasus cicatricosus Endangered No Yellowfin Madtom Noturus flavipinnis Threatened No F-31

From: Pat Black To: Becker, James M

Subject:

RE: thanks for the Watts Bar Reservoir creel survey report Date: Wednesday, September 06, 2017 2:15:19 PM Attachments: Count_WB_4_2016.xlsx Inter_WB_4_2016.xlsx Harv_WB_4_2017.xlsx SurveyCodes_TWRA.pdf Hey Jim, I queried the three tables that make up our creel database to only include data taken from area 4 on Watts Bar from 2016. I also included a list of survey codes used to help you make sense of it.

Below is a description of the area from the Region 3 Reservoir Manager, Mike Jolley.

Pat, The creel area on Watts Bar that you were inquiring about is area #4. This incorporates the area that Mr. Beckor referenced. The lower boundary is the Kingston Steam Plant (Clinch River) and the upper boundary is Melton Hill Dam also located on the Clinch River. This area

4 also includes the Emory River from its mouth up to the city of Harriman. The Emory River empties into the Clinch River a mile or so above the Kingston Steam Plant. I hope this helps!

Mike Jolley TWRA Region 3 Reservoir Fisheries Manager/Biologist Pat Black, TWRA Reservoir Program Coordinator From: Becker, James M [2]

Sent: Wednesday, September 06, 2017 12:07 PM To: Pat Black

Subject:

RE: thanks for the Watts Bar Reservoir creel survey report Hi Pat, Hows it coming with the below? Thank you, Jim From: Pat Black [3]

Sent: Friday, August 18, 2017 1:08 PM To: Becker, James M

Subject:

RE: thanks for the Watts Bar Reservoir creel survey report

Yes, F-32

Once I get that info from the Reg. 3 manager Ill pass it on to you.

From: Becker, James M [4]

Sent: Friday, August 18, 2017 3:06 PM To: Pat Black

Subject:

RE: thanks for the Watts Bar Reservoir creel survey report All right. Thanks Pat. Could you also indicate where the Watts Bar zone starts and stops.

Thank you, Jim From: Pat Black [5]

Sent: Friday, August 18, 2017 7:25 AM To: Becker, James M

Subject:

RE: thanks for the Watts Bar Reservoir creel survey report Hey Jim, I can give you the raw data. Ive contacted our region 3 reservoir manager to get the zone delineations for Watts Bar. He said the zone will encompass a larger area than just the Clinch river portion. This will be the smallest scale available. We dont record location on individual interviews.

Once I get the delineations and zone number that contains the area you are interested in, I can query our statewide database and send you the Watts Bar data. We are moving offices today so It will be next week before I will be able to finish this.

Pat Black From: Becker, James M [6]

Sent: Thursday, August 17, 2017 7:28 PM To: Pat Black

Subject:

RE: thanks for the Watts Bar Reservoir creel survey report Or would we be able to identify and break out 2) the surveys from Melton Hill dam down to where interstate 40 crosses the Clinch River (just below the confluence with the Emory River)?

Or if that wont work, could you send us the data for 3) Roane County (its a longer stretch of river but at least its not all of Watts Bar Reservoir)?

From: Becker, James M Sent: Thursday, August 17, 2017 5:16 PM To: 'Pat Black'

Subject:

RE: thanks for the Watts Bar Reservoir creel survey report Hi Pat, Thanks again for the report. You mentioned that the analysis in the report pertaining to Watts Bar F-33

Reservoir is reservoir-wide and cannot be broken down to parse out the evaluation for from Melton Hill dam down to the confluence of the Emory River. Can you give us the raw creel data for Watts Bar Reservoir? If you can, would we be able to identify and break out, in order of preference, 1) the surveys from Melton Hill dam down to the confluence of the Emory River?

Thank you, Jim From: Pat Black [7]

Sent: Wednesday, August 16, 2017 10:21 AM To: Becker, James M

Subject:

RE: thanks for the Watts Bar Reservoir creel survey report Youre Welcome.

From: Becker, James M [8]

Sent: Wednesday, August 16, 2017 12:15 PM To: Pat Black

Subject:

thanks for the Watts Bar Reservoir creel survey report F-34

From: Gerry Middleton <Gerry.Middleton@tn.gov>

Sent: Thursday, September 07, 2017 1:46 AM To: Becker, James M

Subject:

Re: Bat data report 2013 Attachments: Acoustic Monitoring of ORR Bats 2013.docx HiJames,

I'msending3OakRidgeReservationacousticbatsurveydata(2013,2014,&2015)via3emails.Youmayhave

todoabitof"datamining"tofindwhatyouneedinthereports,buthopefullythesewillbehelpful.Ifyou've

anyquestionsorneedfurtherinformationpleaseletmeknow.

thanks!

Gerry

From:Becker,JamesM<James.Becker@pnnl.gov>

Sent:Thursday,August17,20175:06PM

To:GerryMiddleton

Subject:

RE:hiandthanks

- - This is an EXTERNAL email. Please exercise caution. DO NOT open attachments or click links from unknown senders or unexpected email - STS-Security. ***

1 F-35

2 F-36

3 F-37

From: Stephanie.Ann Williams To: Becker, James M

Subject:

RE: Map package for TN NHP Date: Monday, September 11, 2017 3:17:30 PM Attachments: image001.png Hi Jim-I should have mentioned in the first email that the missing t-lines (092, 186, 624, 659, 697, and 940) are because there are no rare species observations within the buffer distance for those required lines. Sorry for any confusion.

Please let me know if you have any additional questions.

Kind regards-Stephanie Stephanie Williams l Data Manager Division of Natural Areas - Natural Heritage Program Tennessee Tower, 2nd Floor 312 Rosa L. Parks Avenue, Nashville, TN 37243 MAP

p. 615-532-4799 c. 256-337-3858 stephanie.ann.williams@tn.gov tn.gov/environment Natural Areas Facebook We value your feedback! Please complete our customer satisfaction survey.

From: Becker, James M [9]

Sent: Friday, September 08, 2017 5:10 PM To: Stephanie.Ann Williams

Subject:

RE: Map package for TN NHP Hi Stephanie, I looked at the spreadsheets you sent and it appears data for some t-lines is missing (092, 186, 624, 659, 697, and 940).

Thank you, Jim From: Stephanie.Ann Williams [10]

Sent: Friday, September 01, 2017 12:37 PM To: Becker, James M

Subject:

RE: Map package for TN NHP F-38

Hi Jim-I parsed out sites 2 and 8 of the attached excel workbook.

Yes, it is OK to have our response docketed.

Have a great weekend!

Stephanie Stephanie Williams l Data Manager Division of Natural Areas - Natural Heritage Program Tennessee Tower, 2nd Floor 312 Rosa L. Parks Avenue, Nashville, TN 37243 MAP

p. 615-532-4799 c. 256-337-3858 stephanie.ann.williams@tn.gov tn.gov/environment Natural Areas Facebook We value your feedback! Please complete our customer satisfaction survey.

From: Becker, James M [11]

Sent: Wednesday, August 30, 2017 4:47 PM To: Stephanie.Ann Williams

Subject:

RE: Map package for TN NHP Hi Stephanie, Thank you very much for your response to our data request.

We routinely acknowledge the source of NHP data we use in producing documents on behalf of the Nuclear Regulatory Commission (NRC), and will do so with the TN NHP data.

The NRC must docket the NHP data referenced in its documents to make the data available to the general public (beyond those organizations you indicated in #1 in your below email). Per the data request, it appears you did not provide location-specific information (e.g., coordinates) in your response, so is it OK to have your response docketed? Please confirm or let me know what modifications you would need to make to your data package in order to make it acceptable to TN NHP for NRC docketing.

In the data package, the data for alternative sites 2 and 8 are grouped together. Would it be possible for you to put the data for each alternative site in its own spreadsheet and re-send?

Thank you, Jim F-39

From: Stephanie.Ann Williams [12]

Sent: Wednesday, August 30, 2017 1:12 PM To: Becker, James M Cc: Montgomery, Sadie A

Subject:

RE: Map package for TN NHP Mr. Becker-Please find attached the Tennessee Natural Heritage Programs (TNHP) rare species data and invoice. The excel workbook contains sheets for each of the requested buffer areas.

Reminder about our data:

1. The information provided to you by TNHP is intended for distribution or use only within your department, agency, organization, or business. Should individuals or entities outside your organization/project team ask you for data that we are providing, please refer them to TNHP.

2. As a professional courtesy, we ask that you acknowledge TNHP as a source of your information whenever you use TNHP data in your reports, papers, or publications that incorporate TNHP data. However, site-specific locational information should not be provided to third parties, published, or otherwise distributed in any way without written permission by TNHP.

Please contact me should you have any questions.

Kind regards-Stephanie Stephanie Williams l Data Manager Division of Natural Areas - Natural Heritage Program Tennessee Tower, 2nd Floor 312 Rosa L. Parks Avenue, Nashville, TN 37243 MAP

p. 615-532-4799 c. 256-337-3858 stephanie.ann.williams@tn.gov tn.gov/environment Natural Areas Facebook We value your feedback! Please complete our customer satisfaction survey.

From: Becker, James M [13]

Sent: Friday, August 18, 2017 2:23 PM To: Stephanie.Ann Williams; David Withers Cc: Montgomery, Sadie A

Subject:

Map package for TN NHP

- - This is an EXTERNAL email. Please exercise caution. DO NOT open attachments or click links from unknown senders or unexpected email - STS-Security. ***

F-40

Hi Stephanie and Dave, I enjoyed our conversations earlier this week. We have two requests.

The first request concerns the attached map package (mpk) containing the following files, with the buffers within which we would like TN NHP to identify species and habitat (terrestrial and aquatic) (of concern to both the State and Federal governments) occurrences in parentheses:

CRN Site Boundary (within 2 miles of the site boundary on all sides)

Barge Area (within 2 miles of the site boundary on all sides)

Potential Candidate (aka Alternative) Sites 2 & 8 (within 2 miles of the boundary on all sides of each site)

Transmission Line Segments requiring upgrades (within 1/8 [0.125] mile on either side of each line [identified as LXXXX])

CRN Site Vicinity Transmission Line (extending east of CRN Site boundary to the Bethel Valley substation) (within 1/8 [0.125] mile on either side)

I am copying Sadie Montgomery on this email, as she is the one who put the attached mpk file together and can answer any questions you might have regarding extracting the files, etc.

The second request concerns aquatic species and habitat occurrences only, in the Clinch River between Melton Hill dam and the confluence of the Emory River (located just east of where Interstate 40 crosses the Clinch River). Note that there is no line feature (in a shape file) we can send you that defines this reach of the Clinch River. I hope you can identify it from the above description.

If you could report findings for the 5 attached files and the Clinch River in a sortable spreadsheet (or each in its own individual Excel spreadsheet), that would be much appreciated. Note that we do not need coordinates for species/habitat locations rather just a list of the species/habitats with occurrences within the specified buffers.

Thank you very much for helping us with this. If you have any other questions, besides regarding extracting the mpk files, please call me at 509-371-7186.

Thank you, Jim Becker F-41

From: McCracken, Kitty To: Becker, James M

Subject:

Fish data for Ish Creek, Oak Ridge, TN Date: Monday, September 18, 2017 4:29:08 PM Attachments: IshCk_fishdata.xlsx Hi Jim.

Attached is fish population data from Fall 2016 and Spring 2017 for Ish Creek on the Oak Ridge Reservation.

Let me know if you need any other data.

Thanks, Kitty McCracken From: Jett, Robert T.

Sent: Monday, September 18, 2017 4:02 PM To: McCracken, Kitty <mccrackenmk@ornl.gov>

Subject:

RE: Ish Creek data Heres data from the last year. Numbers w/o parentheses are density values numbers in parentheses are biomass values.

Trent From: McCracken, Kitty Sent: Monday, September 18, 2017 8:23 AM To: Jett, Robert T. <jettrt@ornl.gov>

Subject:

Ish Creek data Hi Trent, Would you send me the latest Ish Creek data you have for fish?

Thanks.

Kitty F-42

From: Nongame Review To: Becker, James M

Subject:

Environmental Review Date: Sunday, September 24, 2017 9:09:34 AM Attachments: ir-17418-asy-2017-09-24-10-53-49.pdf Hi James-Please see attached Environmental Review for the Georgia portion of the proposed transmission line (SMR ESP) project. If I can be of additional assistance, do not hesitate to contact me-Thanks!

Anna Anna Yellin Environmental Review Coordinator, Nongame Conservation Wildlife Resources Division (706) 557-3283 l M: (678) 459-8393 Facebook

Twitter

Instagram Buy a hunting or fishing license today!

A division of the GEORGIA DEPARTMENT OF NATURAL RESOURCES F-43

September 29, 2017 James Becker Pacific Northwest National Laboratory 902 Batelle Blvd Richland, WA 99354 Data Request 18-020

Dear Mr. Becker,

This letter is in response to your data request of September 27, 2017 for the Clinch River Small Modular Reactor in Bell and Whitley Counties, Kentucky. We have reviewed our Natural Heritage Program Database to determine if any of the endangered, threatened, or special concern plants and animals or exemplary natural communities monitored by the Kentucky State Nature Preserves Commission occur near the project area on Eagan, Frakes, Kayjay, and Artemus USGS Quadrangles as indicated in the file provided to us. Please see the attached Excel file and geodatabase for more information.

Element Occurrence Records 1-mile for all records - 42 records 5-mile for aquatic records - 81 records 5-mile for federally listed species - 55 records 10-mile for mammals and birds - 38 records This project intersects four different managed areas and three conservations sites including a Kentucky Division of Water Outstanding Resource Water. Please use the attached geodatabase with corresponding feature classes (managed areas and conservation sites) to determine proximity and impact. KSNPC is not regulatory but recommends contacting the proper authorities (KDOW, KY DEP, KDFWR, USFWS, etc.) about impacts to the managed lands and conservation lands.

Certain taxa are considered sensitive by KSNPC because either they exist in limited geographic areas, or they have certain characteristics or habitat requirements that make them especially vulnerable to specific pressures such as collection, human disturbance, etc. Measures should be taken to avoid the disturbance of possible habitat for these species. For this reason, the exact location of some species has not been included in the enclosed data report. Please contact F-44

KSNPC for more information.

This project as planned goes through one or more large forest blocks. KSNPC is now monitoring large forest blocks, which are defined as 900 or more acres of contiguous forest. Large forest blocks were determined using the best available data at this time. Forest fragmentation is one of the primary impacts to plants and animals that require large tracts of forest for all parts of their life cycles. Fragmenting or impacting large forest blocks should be avoided.

I would like to take this opportunity to remind you of the terms of the data request license, which you agreed upon in order to submit your request. The license agreement states "Data and data products received from the Kentucky State Nature Preserves Commission, including any portion thereof, may not be reproduced in any form or by any means without the express written authorization of the Kentucky State Nature Preserves Commission." The exact location of plants, animals, and natural communities, if released by the Kentucky State Nature Preserves Commission, may not be released in any document or correspondence. These products are provided on a temporary basis for the express project (described above) of the requester, and may not be redistributed, resold or copied without the written permission of the Kentucky State Nature Preserves Commission's Heritage Branch (801 Teton Trail, Frankfort, KY, 40601. Phone: (502) 573-2886).

Please note that the quantity and quality of data collected by the Kentucky Natural Heritage Program are dependent on the research and observations of many individuals and organizations. In most cases, this information is not the result of comprehensive or site-specific field surveys; many natural areas in Kentucky have never been thoroughly surveyed and new plants and animals are still being discovered. For these reasons, the Kentucky Natural Heritage Program cannot provide a definitive statement on the presence, absence, or condition of biological elements in any part of Kentucky. Heritage reports summarize the existing information known to the Kentucky Natural Heritage Program at the time of the request regarding the biological elements or locations in question. They should never be regarded as final statements on the elements or areas being consid-ered, nor should they be substituted for on-site surveys required for environmental assessments. We would greatly appreciate receiving any pertinent information obtained as a result of on-site surveys.

F-45

If you have any questions or if I can be of further assistance, please do not hesitate to contact me.

Sincerely, Ian Horn Geoprocessing Specialist

Enclosures:

Data Report and Interpretation Key F-46

From: Brian Flock To: Becker, James M

Subject:

RE: Climch River small modular nuclear reactor project- 2 figures this time Date: Friday, November 03, 2017 12:10:29 PM Unfortunately the way the data is aggregated it is difficult to really give you good answers on some of this. I know that all the data is based on bats in hand because it was from scientific permits and we dont have any way with our system to track acoustics. For the roost data I know that in those two areas I have clusters of bats data and my familiarity with the projects that were done there I know that in those clusters were at least 1 maternity roost.

Closest known IBat Hibernacula are Grassy Cove Saltpeter (Cumberland County) and White Oak Blowhole (Blount County, Smoky National Park) both 30+ miles Closest known NLEB is Marble Bluff Cave (Roane County) 8 miles It also has summer record of Gray Bats (TVA data)

Hibernacula data with cave name and county can be found here http://www.tnbwg.org/TNBWG_WNS.html Brian Flock, Ph. D.

From: Becker, James M [14]

Sent: Friday, November 3, 2017 12:44 PM To: Brian Flock

Subject:

RE: Climch River small modular nuclear reactor project- 2 figures this time Thank you for helping. I have some further questions. Hope you dont mind.

To what do the distances refer, mist net captures or acoustic recordings of the species within those distances from the peninsula? Or is it something else?

When you say the closest roost, does that mean maternity roost or non-maternity (satellite male/non-reproductive female) roost?

Anything on gray bat roosts or hibernacula? Anything on NLEB or IB hibernacula?

Are you at liberty to release data or reports related to the above?

Thanks again, Jim From: Brian Flock [15]

Sent: Friday, November 03, 2017 8:18 AM F-47

To: Becker, James M

Subject:

RE: Climch River small modular nuclear reactor project- 2 figures this time Sorry, It took me longer than expected. I lost access to ArcGIS for about 3 weeks, which put me behind. I used the peninsula to estimate distances.

Here is what I can give you.

0 to 4 miles Gray bat 8 to 12 miles Gray bat and Northern Myotis 16 to 20 miles Gray bat Closest Indiana bat roost we have data on is Blount County, Cherokee Forest Closest Northern Myotis roost we have data on is Morgan County, Catoosa WMA Hope this helps for your review.

Brian Flock, Ph. D.

Wildlife Action Plan Coordinator Tennessee Wildlife Resources Agency PO Box 40747 Nashville, TN 37204 Ph: 615-781-6569 From: Becker, James M [16]

Sent: Thursday, August 17, 2017 1:40 PM To: Brian Flock

Subject:

FW: Climch River small modular nuclear reactor project- 2 figures this time

- - This is an EXTERNAL email. Please exercise caution. DO NOT open attachments or click links from unknown senders or unexpected email - STS-Security. ***

Trying again From: Becker, James M Sent: Thursday, August 17, 2017 11:09 AM To: 'brian.flock@tn.gov'

Subject:

FW: Climch River small modular nuclear reactor project From: Becker, James M F-48

Sent: Wednesday, August 16, 2017 9:06 AM To: 'Chris Simpson'

Subject:

RE: Climch River small modular nuclear reactor project Thought I did but didnt. Here they are. Thanks, Jim From: Chris Simpson [17]

Sent: Wednesday, August 16, 2017 6:52 AM To: Becker, James M

Subject:

RE: Climch River small modular nuclear reactor project Thank you, did you send any attachments? Thanks, Chris.

From: Becker, James M [18]

Sent: Tuesday, August 15, 2017 7:01 PM To: Chris Simpson

Subject:

Climch River small modular nuclear reactor project Hi Chris, I have attached several figures to help you find and orient yourself to the above project. As we discussed on the phone, TVA proposes to construct and operate a small modular nuclear reactor on what I will call the Clinch River peninsula in the Clinch River arm of Watts Bar Reservoir. The Clinch River Site (CRN Site) is labeled in pink in the first figure. The CRN Site and the adjacent Grassy Creek Habitat Protection Area (HPA) is shown in the 2nd figure. In addition to these, the Barge Traffic Area (BTA) is found in the 3rd figure. The BTA would also be developed and road improvements made for the unloading of large components transported upriver.

Note that TVAs environmental report (part of its application to the Nuclear Regulatory Commission for this project) states that there are no known caves or mines on the Clinch River Site, the 935 acre project area. There are also no known caves in the Grassy Creek HPA. Liz Hamricks bat survey report for the project states the following about nearby caves, Exposed rock features reflect that underground karst features are present in some areas, which may provide habitat for small mammals, green salamanders, and roosting bats. Two previously documented caves (Gage 2011), Rennies Cave and 2-Batteries Cave, are located within Grassy Creek HPA. Three additional caves/karst openings near Grassy Creek were encountered by botanical staff during surveys of the HPA....Roosting bats were observed in Rennies Cave by archaeological surveyors in April, 2011. Photos of 2 individual bats were taken by surveyors and later reviewed by terrestrial zoology staff. One bat was identified as a tricolored bat (Perimyotis subflavus); the other bat individual could not be identified based on the photo.

Hope this helps. There may well be more caves in the nearby area, but these are the F-49

only ones noted in TVAs references. If you have any questions, call at 509-371-7186.

Thank you, Jim F-50

From: Giffen, Neil R.

To: Becker, James M

Subject:

RE: Question about a former area of "very high biological significance" on the Clinch River Site Date: Wednesday, November 08, 2017 8:01:11 AM Attachments: Nature Conservancy BSR Table.pdf Nature Conservancy BSR Map.pdf Nature Conservancy BSR Descriptions.pdf

Jim, This area was originally identified to be of significance in a 1995 Nature Conservancy report that studied biodiversity on the Oak Ridge Reservation (ORR). You are correct when you say that the area was not noted in the 2009 Baranski report because is not part of the reservation. However, there is still a portion of that area that is on the reservation (shown as RA22 in the 2009 Baranski Report).

The current description of that area in the ORR natural areas database is the following:

RA22 GRASSY CREEK SECURITY SITE Location: Northwest-facing slope of Chestnut Ridge in the Grassy Creek watershed. Grid E5; section 2E.

Size: 43.1 acres (17.4 ha)

General description: This area contains limestone outcrops on the slope. Two of the species found here, Wild Ginger (Asarum canadense) and Jacobs Ladder (Polemonium reptans), are uncommon on the ORR.

Status species present:

Rare communities present:

Wetlands:

Other factors: The area probably consisted of intact forest in 1935.

Disturbances and external effects: Gas line on northeastern edge. Adjacent to private land.

Disturbance impacts = Low to Intermediate.

Previous recognitions: Part of BSR2-5.

The Nature Conservancy assigned biodiversity significance ranks (BSRs) to areas based on the resources found in the particular area. I have attached the table from the 1995 document that describes those ranks. The full 100 acre area noted in the 2006 Parr report was known as BSR2-5 in the 1995 Natural Conservancy report. I have attached the map and relevant text from that report that describes the site. The description is similar to how we describe the current RA22. Please also note BSR2-6, is another area of significance in that area. The reference for the 1995 Nature Conservancy report is the following:

TNC (The Nature Conservancy). 1995. Oak Ridge Reservation, Biodiversity, and the Common Ground Process: Preliminary Biodiversity Report on the Oak Ridge Reservation. Unpublished report. TNC, Arlington, Virginia.

I hope this helps. If you have any questions or need anything further, let me know.

Neil F-51

Neil R. Giffen Natural Resources Manager office phone: 865-241-9421 cell phone: 865-963-9974 email: giffennr1@ornl.gov From: Becker, James M [19]

Sent: Friday, November 03, 2017 8:00 PM To: Giffen, Neil R.

Subject:

Question about a former area of "very high biological significance" on the Clinch River Site Hi Neil. I was wondering if you can help me with the following.

Parr and Hughes (2006, see Figures 12 and 13) identified an area of about 100 ac in the eastern portion of the CRN Site that extended from just east of the CRBR footprint to the Clinch River as having very high biological significance due to confirmed and potential habitat for (unidentified species of) rare plants and wildlife. It is likely this area contained the (unidentified) rare plant species that were located just beyond the Clinch River Breeder Reactor (CRBR) footprint and which were protected from disturbance during redress (DOE 1984, DOE et al. 1984). However, Parr and Hughes (2006) was superseded by Baranski (2009) which does not indicate any important habitats occurring on the Clinch River Site (see Figure 1 in Baranski 2009), including this approximate 100-ac area.

Baranski (2009) did not indicate why this area identified by Parr and Hughes (2006-TN5058) was excluded.

My question is why this 100-ac area was excluded by Baranski (2009). Was it because the species found there (which are not identified) were no longer considered rare or of concern (would be odd given the area probably supported the rare plant species noted by DOE in 1984 and that the area was again referenced for rare plants by Parr and Hughes in 2006 after 20 years)? Was it because suddenly it was decided that since the Clinch River Site was not part of the Oak Ridge Reservation (ORR) that the area wasnt included (note that the Clinch River Site has not been part of the ORR since before the Clinch River Breeder Reactor and yet the 100-ac area was included in the Parr and Hughes [2006] document)?

If you could answer this for me, I would greatly appreciate it.

Thank you, Jim References Baranski, M.J. 2009. Natural Area Analysis and Evaluation, Oak Ridge Reservation.

ORNL/TM-2009-201, Oak Ridge National Laboratory, Oak Ridge, Tennessee. Accession No. ?? TN 5133.

Parr, P.D. and J.F. Hughes. 2006. Oak Ridge Reservation Physical Characteristics and Natural Resources. ORNL-2006-G01046/lmh, Oak Ridge National Laboratory, Oak Ridge, F-52

Tennessee. Accession No. ?? TN5058.

F-53

From: Giffen, Neil R.

To: Becker, James M

Subject:

RE: Question about a former area of "very high biological significance" on the Clinch River Site Date: Thursday, December 07, 2017 10:02:32 AM

Jim, Yes, BSR2-6 is not included in the Baranski report because it is no longer part of the Oak Ridge Reservation. The site was recognized by The Nature Conservancy back in 1995 for the areas significant river bluffs. I believe you have that referenced in the previous information I sent to you.

If you cant find it, please let me know. There is also a record for Appalachian bugbane (Cimicifuga rubifolia) for that area. This is a species that was previously listed by the state of Tennessee, but is no longer. It is considered as a G3 on the global scale. We still consider it of conservation concern for the reservation because of its rarity.

I hope this helps. If you need anything further, please let me know.

Neil Neil R. Giffen Natural Resources Manager office phone: 865-241-9421 cell phone: 865-963-9974 email: giffennr1@ornl.gov From: Becker, James M [20]

Sent: Wednesday, December 06, 2017 8:45 PM To: Giffen, Neil R.

Subject:

RE: Question about a former area of "very high biological significance" on the Clinch River Site Hi Neil. I just realized we had confusion over the 100-ac area I had questions on in my original email to you from Nov 3 below at the beginning of the string. The 100-ac area I was referring to is BSR2-6 (not BSR2-5 for which I believe your answer applies). My question is the same, namely:

Why this 100-ac area was excluded by Baranski (2009). Was it because the species found there (which are not identified) were no longer considered rare or of concern (would be odd given the area probably supported the rare plant species noted by DOE in 1984 and that the area was again referenced for rare plants by Parr and Hughes in 2006 after 20 years)?

Was it because suddenly it was decided that since the Clinch River Site was not part of the Oak Ridge Reservation (ORR) that the area wasnt included (note that the Clinch River Site has not been part of the ORR since before the Clinch River Breeder Reactor and yet the 100-ac area was included in the Parr and Hughes [2006] document)?

Thank you, Jim F-54

From: Giffen, Neil R. [21]

Sent: Friday, November 10, 2017 4:41 AM To: Becker, James M

Subject:

RE: Question about a former area of "very high biological significance" on the Clinch River Site Youre very welcome. If you need anything else, let me know. Best of luck with the writing!

Neil R. Giffen Natural Resources Manager office phone: 865-241-9421 cell phone: 865-963-9974 email: giffennr1@ornl.gov From: Becker, James M [22]

Sent: Thursday, November 09, 2017 4:27 PM To: Giffen, Neil R.

Subject:

RE: Question about a former area of "very high biological significance" on the Clinch River Site Thank you very much Neil!

F-55

1 APPENDIX G 2 SUPPORTING INFORMATION FOR RADIOLOGICAL 3 DOSE ASSESSMENTS OF ROUTINE OPERATIONS (G.1) AND 4 POSTULATED SEVERE ACCIDENTS (G.2) 5 G.1 Supporting Documentation for Radiological Dose Assessment from Normal 6 Effluent Releases 7 The U.S. Nuclear Regulatory Commission (NRC) staff reviewed and performed an independent 8 dose assessment of the radiological impacts resulting from normal operation of small modular 9 reactors (SMRs) at the Clinch River Nuclear (CRN) Site The results of these assessments are 10 presented in this appendix and are compared to the results from the Tennessee Valley 11 Authoritys (TVA) assessment of routine operations found in Section 5.9 of this EIS, Radiological 12 Impacts of Normal Operations.

13 Section G.1 is divided into four subsections that address estimates of dose to the public from 14 liquid effluents (G.1.1), estimates of dose to the public from gaseous effluents (G.1.2), estimates 15 of cumulative and population doses (G.1.3), and estimates of dose to nonhuman biota from 16 liquid and gaseous effluents (G.1.4).

17 G.1.1 Estimates of Dose to the Public from Normal Liquid Effluents 18 The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109 19 (NRC 1977-TN90) and the LADTAP II computer code (Strenge et al. 1986-TN82) to estimate 20 doses to the maximally exposed individual (MEI) and population from the liquid effluent pathway 21 of SMRs at the CRN Site.

22 G.1.1.1 Scope 23 Doses from SMRs on the CRN Site to the MEI were calculated and compared to regulatory 24 criteria for the following:

25 Total Body dose was the total for all pathways (i.e., ingestion of aquatic organisms as food 26 and recreational activity on and near the Clinch River), and the highest value for either the 27 adult, teen, child, or infant was compared to the 3-mrem/yr per reactor design objective in 28 Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix I (10 CFR Part 50-29 TN249).

30 Organ dose was the total for each organ for all pathways (i.e., ingestion of aquatic 31 organisms as food and recreational activity on and near the Clinch River), and the highest 32 value for the adult, teen, child, or infant was compared to the 10-mrem/yr per reactor design 33 objective specified in 10 CFR Part 50, Appendix I (TN249).

34 The NRC staff reviewed the assumed exposure pathways and the input parameters and values 35 used by TVA (2017-TN4921l). The NRC staff concluded that TVA accurately described the 36 exposure pathways. Except where noted in Table G-1, the input parameters and values 37 provided by TVA were found to be appropriate for the analyses. Where NRC staff took 38 exception, alternative values were taken from either Regulatory Guide 1.109 (NRC 1977-TN90) 39 or from other sources, as documented.

G-1

1 Table G-1. Parameters Used in Calculating Dose to the Public from Liquid Effluent 2 Releases Parameter NRC Staff Value Comments Nuclide Per Unit(a) Per Site(b)

New unit liquid effluent source H-3 2.21 x 10+2 8.85 x 10+2 Values from Environmental term (Ci/yr) Na-24 2.80 x 10-3 8.40 x 10-3 Report (ER) Tables 3.5-1 and Cr-51 1.07 x 10-2 1.28 x 10-1 3.5-2 (TVA 2017-TN4921).

Mn-54 5.44 x 10-3 6.53 x 10-2 Fe-55 4.06 x 10-3 4.87 x 10-2 Mn-56 2.72 x 10-4 1.09 x 10-3 Fe-59 9.92 x 10-4 1.19 x 10-2 Co-58 5.20 x 10-3 5.51 x 10-2 Co-60 2.05 x 10-3 8.21 x 10-3 Zn-65 1.76 x 10-3 2.11 x 10-2 W-187 2.10 x 10-4 6.30 x 10-4 Np-239 2.49 x 10-3 2.99 x 10-2 C-14 8.19 x 10-4 9.83 x 10-3 P-32 7.57 x 10-5 3.03 x 10-4 Ni-63 1.53 x 10-2 1.84 x 10-1 Cu-64 1.68 x 10-3 6.72 x 10-3 Br-82 1.87 x 10-6 7.48 x 10-6 Br-83 3.52 x 10-6 1.41 x 10-5 Br-84 8.38 x 10-5 1.01 x 10-3 Br-85 2.42 x 10-9 9.68 x 10-9 Rb-86 1.87 x 10-5 7.48 x 10-5 Rb-88 3.73 x 10-3 1.49 x 10-2 Rb-89 5.15 x 10-5 6.18 x 10-4 Sr-89 4.19 x 10-5 1.67 x 10-4 Sr-90 3.57 x 10-6 1.43 x 10-5 Y-90 1.55 x 10-7 1.86 x 10-6 Sr-91 1.67 x 10-4 6.67 x 10-4 Y-91 3.13 x 10-5 1.25 x 10-4 Y-91m 6.67 x 10-6 2.67 x 10-5 Sr-92 5.91 x 10-5 2.36 x 10-4 Y-92 2.25 x 10-4 9.01 x 10-4 Y-93 1.81 x 10-4 7.25 x 10-4 Zr-95 1.83 x 10-4 2.20 x 10-3 Nb-95 2.67 x 10-4 1.07 x 10-3 Zr-97 1.10 x 10-7 4.40 x 10-7 Mo-99 3.77 x 10-3 4.52 x 10-2 Tc-99 4.40 x 10-9 1.76 x 10-8 Tc-99m 1.89 x 10-3 2.27 x 10-2 Ru-103 6.57 x 10-4 2.63 x 10-3 Rh-103m 3.64 x 10-7 4.37 x 10-6 Ru-105 1.76 x 10-8 7.04 x 10-8 Rh-105 1.07 x 10-7 4.27 x 10-7 Ru-106 9.80 x 10-3 3.92 x 10-2 Rh-106 9.35 x 10-8 3.74 x 10-7 Ag-110 8.69 x 10-9 3.48 x 10-8 Ag-110m 2.22 x 10-3 2.66 x 10-2 Sb-124 5.73 x 10-5 2.29 x 10-4 Sb-125 1.98 x 10-9 7.92 x 10-9 Sb-127 1.10 x 10-8 4.40 x 10-8 Te-127 3.19 x 10-6 1.28 x 10-5 Te-127m 1.43 x 10-6 5.72 x 10-6 Sb-129 4.40 x 10-9 1.76 x 10-8 Te-129 4.13 x 10-5 1.65 x 10-4 I-129 4.20 x 10-10 5.04 x 10-9 Te-129m 2.30 x 10-2 6.90 x 10-2 I-130 4.62 x 10-6 1.85 x 10-5 3

G-2

Table G-1. (contd)

Parameter NRC Staff Value Comments Te-131 1.01 x 10-5 4.05 x 10-5 I-131 1.38 x 10-2 1.66 x 10-1 Te-131m 6.60 x 10-4 1.98 x 10-3 Te-132 4.40 x 10-2 1.32 x 10-1 I-132 4.40 x 10-2 1.32 x 10-1 I-133 2.30 x 10-2 2.76 x 10-1 Te-134 2.64 x 10-7 1.06 x 10-6 I-134 3.26 x 10-3 3.91 x 10-2 Cs-134 2.87 x 10-3 3.44 x 10-2 I-135 1.37 x 10-2 1.64 x 10-1 Cs-136 2.93 x 10-3 1.17 x 10-2 Cs-137 3.53 x 10-3 4.24 x 10-2 Ba-137m 5.17 x 10-4 2.07 x 10-3 Cs-138 1.18 x 10-3 1.42 x 10-2 Ba-139 1.54 x 10-8 6.16 x 10-8 Ba-140 1.60 x 10-2 4.80 x 10-2 La-140 1.07 x 10-3 4.27 x 10-3 La-141 2.20 x 10-8 8.80 x 10-8 Ce-141 3.96 x 10-5 1.58 x 10-4 La-142 2.97 x 10-9 1.19 x 10-8 Ce-143 8.13 x 10-5 3.25 x 10-4 Pr-143 1.73 x 10-5 6.93 x 10-5 Ce-144 7.47 x 10-4 2.99 x 10-3 Pr-144 4.21 x 10-4 1.69 x 10-3 Nd-147 2.67 x 10-7 1.07 x 10-6 Pu-238 6.60 x 10-10 2.64 x 10-9 Pu-239 8.47 x 10-11 3.39 x 10-10 Pu-240 1.07 x 10-10 4.27 x 10-10 Pu-241 3.19 x 10-8 1.28 x 10-7 Am-241 4.62 x 10-11 1.85 x 10-10 Cm-242 9.46 x 10-9 3.78 x 10-8 Cm-244 4.40 x 10-10 1.76 x 10-9 Discharge rate 4,670 ft3/s Value from ER Section 5.4.1.1 based on mean flow rate past Melton Hill Dam from 2004-2013 (TVA 2017-TN4921). TVA used 4,000 ft3/s in its analysis.

Source term multiplier 1 Calculation on a per unit basis.

Same value used by TVA in its analysis.

Site type Fresh water Discharge to Clinch River arm of Watts Bar Reservoir. Same assumption used by TVA in its analysis.

Impoundment reconcentration None No impoundment. Same model assumption used by TVA in its analysis.

Dilution factors for aquatic food 1 Value used by TVA in its and boating, shoreline, and analysis (conservative).

swimming.

Transit time to receptor (hr) 0 hr Value used by TVA in its analysis (conservative).

G-3

Table G-1. (contd)

Parameter NRC Staff Value Comments Consumption and usage factors Fish consumption (kg/yr) LADTAP II code default values for adults, teens, children, and 21 (adult) used (NRC 1977-TN90; Strenge infants 16 (teen) et al. 1986-TN82), except where 6.9 (child) noted.

0 (infant)

Crustacean consumption (kg/yr) Note: TVA used 5, 3.8, 1.7, and 0 (adult) 0 kg/yr for crustacean 0 (teen) consumption rates that 0 (child) correspond to LADTAP default 0 (infant) values for saltwater sites.

Aquatic plant consumption (kg/yr) 0 (adult) 0 (teen) 0 (child) 0 (infant)

Drinking water (l/yr) 730 (adult) 510 (teen) 510 (child) 330 (infant)

Shoreline usage (hr/yr) 12 (adult) 67 (teen) 14 (child) 0 (infant)

Swimming (hr/yr) Note: TVA used default 0 (adult) shoreline usage values for 0 (teen) swimming (i.e., 12, 67, 14, and 0 0 (child) hr/yr).

0 (infant)

Boating (hr/yr) Note: TVA used default 0 (adult) shoreline usage values for 0 (teen) boating (i.e., 12, 67, 14, and 0 0 (child) hr/yr).

0 (infant) 50-mi population 2,643,269 Value from ER Section 2.5.1.4 estimated for year 2067. TVA used 2,658,157 in its analysis.

50-mi sport fishing(c) 1.87 x 10 6 Value used by TVA in its analysis.

50-mi commercial fishing(c) 5.93 x 10 6 Value used by TVA in its analysis.

50-mi sport invertebrate 0 Minimal invertebrate harvest.

ingestion(c) 50-mi commercial invertebrate(c) 0 Minimal invertebrate harvest.

50-mi drinking water(d) 5.80 x 104 TVA used a value of 2.49 x 105 for the population within 50 mi served by Clinch or Tennessee Rivers for its source of drinking water.

G-4

Table G-1. (contd)

Parameter NRC Staff Value Comments 50-mi shoreline usage(c) 3.38 x 107 person-hr/yr Time spent by the average individual on shoreline activities was taken from NRC RG 1.109 Table E-4 (NRC 1977-TN90).

Person-hours per year were determined by multiplying the average rate of 12.8 hr/yr by the projected 2067 population of 2,643,269.

50-mi swimming usage(c) 3.38 x 107 person-hr/yr Time spent by the average individual on shoreline activities was taken from NRC RG 1.109 Table E-4 (NRC 1977-TN90).

The time spent swimming is assumed to be identical to that spent on shoreline activities.

Person-hours/year were determined by multiplying the average rate of 12.8 hr/yr by the projected 2067 population of 2,643,269.

50-mi boating usage(c) 3.38 x 107 person-hr/yr Time spent by the average individual on shoreline activities was taken from NRC RG 1.109 Table E-4 (NRC 1977-TN90).

The time spent boating is assumed to be identical to that spent on shoreline activities.

Person-hours/year were determined by multiplying the average rate of 12.8 hr/yr by the projected 2067 population of 2,643,269.

Milk production using Clinch River 30,800 kg/yr TVA value. Production within 50 for irrigation mi was determined by multiplying the projected 2067 milk production within 50 mi by the percentage of irrigated state land within 50 mi (2.41 percent) and by the percentage of irrigation occurring with water from the Clinch River arm of Watts Bar Reservoir within 50 mi (0.67 percent).

G-5

Table G-1. (contd)

Parameter NRC Staff Value Comments Meat production using Clinch 26,200 kg/yr TVA value. Production within 50 River for irrigation mi was determined by multiplying the projected 2067 meat production within 50 mi by the percentage of irrigated state land within 50 mi (2.41 percent) and by the percentage of irrigation occurring with water from the Clinch River arm of Watts Bar Reservoir within 50 mi (0.67 percent).

Produce production using Clinch 113,000 kg/yr TVA value. Production within 50 River for irrigation mi was determined by multiplying the projected 2067 produce production within 50 mi by the percentage of irrigated state land within 50 mi (2.41 percent) and by the percentage of irrigation occurring with water from the Clinch River arm of Watts Bar Reservoir within 50 mi (0.67 percent).

(a) Per unit is the plant parameter envelope (PPE) bounding value for a single SMR unit taken from ER Table 3.5-2 (TVA 2017-TN4921) and is used throughout this section.

(b) Per site is the PPE bounding value for the CRN Site taken from ER Table 3.5-1 (TVA 2017-TN4921) and is included for multi-unit (site-wide) analysis throughout this section.

(c) Parameter is based on the LADTAP II default value.

(d) Based on a review of data available at the U.S. Environmental Protection Agencys (EPAs) Safe Drinking Water Information System (SDWIS), the number of persons within 50 river miles downstream of the CRN Site liquid effluent discharge point (CRM 15.5) whose source of drinking water was the Clinch or Tennessee Rivers (directly or influenced by) was 40,534 in 2017. Using the annual population growth rate of 0.72 percent reported in Section 2.5.1.4 of TVAs ER (TVA 2017-TN4921), a population of 40,534 in 2017 would grow to 58,024 by 2067. EPAs SDWIS was accessed April 26, 2017 at: https://www.epa.gov/ground-water-and-drinking-water/safe-drinking-water-information-system-sdwis-federal-reporting.

1 To calculate doses to the public from liquid effluents, the NRC staff used a personal computer 2 version of the LADTAP II code titled NRCDOSE, Version 2.3.13 (CNS 2006-TN102), obtained 3 through the Oak Ridge Radiation Safety Information Computational Center (RSICC), and 4 updates to the user interface obtained directly from Chesapeake Nuclear Services.

5 G.1.1.2 Input Parameters 6 Table G-1 provides a list of the major parameters used in calculating dose to the public from 7 liquid effluent releases during normal operation.

8 G.1.1.3 Comparison of Results 9 The results documented in the TVA Environmental Report (ER) (TVA 2017-TN4921) for doses 10 from liquid effluent releases are compared in Table G-2 with the results calculated by the NRC 11 staff. The doses calculated by the NRC staff are considerably lower than the doses calculated 12 by TVA, with one exception. Differences between the TVA and NRC staff parameter values are 13 described in Table G-1 and includes differences in the 50-mi population, average river flow rate, 14 some population-averaged activity and consumption rates, and the population obtaining drinking G-6

1 water from potentially contaminated sources. For calculating the population dose from liquid 2 effluents, TVA used the population distribution for the year 2067. However, Section 5.4.1 of the 3 NRCs Environmental Standard Review Plan (ESRP) (NRC 2000-TN614) uses a projected 4 population for 5 years from the time of the licensing action under consideration. Because the 5 population is assumed to increase, the use of the year 2067 is conservative (i.e., yielding a 6 higher calculated population dose). The NRC staff evaluated TVAs projected 2067 population 7 distribution and determined they were reasonable. The single exception where the TVA 8 estimate is less than the staff estimate is the liquid pathway population dose from the CRN Site 9 with more than one SMR. The TVA estimate, described in a footnote to ER Table 5.4-17, is a 10 multiple of 4 times the single-unit value. The staffs analysis and estimate are based on the 11 PPE source term from ER Table 3.5-1, so the estimate is slightly larger.

12 Based on TVAs conservative approach, the NRC staff are confident that the liquid effluent 13 doses from normal operations are bounding (i.e., actual doses are expected to be no higher 14 than those presented by TVA).

15 Table G-2. Comparison of Doses to the Public from Liquid Effluent Releases for a 16 New Nuclear Power Plant (Per Unit and Per Site)

Value from NRC Staff Percent Type of Dose TVA ER(a)(b) Calculation Difference Per Single Unit Total body (mrem/yr) 0.020 (adult) 0.015 -25 Organ dose (mrem/yr) 0.097 (adult GI-LLI) 0.044 -55 Thyroid (mrem/yr) 0.064 (child) 0.053 -17 Total body population dose from 2.43 1.37 -44 liquid pathway (person-rem/yr)

Per Site Total body (mrem/yr) 0.17 (adult) 0.12 -29 Organ dose (mrem/yr) 0.66 (child kidney) 0.44 -33 Thyroid (mrem/yr) 0.66 (child) 0.56 -15 Total body population dose from 9.6 14.6 +52 liquid pathway (person-rem/yr)

GI-LLI = gastrointestinal lining of lower intestine.

(a) Results per unit were taken from TVA ER Tables 5.4-8 and 5.4-12 (TVA 2017-TN4921).

(b) Results per site were taken from TVA ER Tables 5.4-9 and 5.4-17 (TVA 2017-TN4921).

17 G.1.2 Estimates of Dose to the Public from Normal Gaseous Effluents 18 The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109 19 (NRC 1977-TN90) and the XOQDOQ and GASPAR II computer codes (Sagendorf et al. 1982-20 TN280; Strenge et al. 1987-TN83) to estimate doses to the MEI and to the population within a 21 50-mi radius of the CRN Site from the gaseous effluent pathway. The NRC staff used the 22 projected per unit and per site radioactive gaseous effluents release values from the TVA ER 23 and ER supplemental information (TVA 2017-TN4921).

24 G.1.2.1 Scope 25 The NRC staff reviewed the input parameters and values used by TVA for appropriateness.

26 The MEI is assumed to be at 0.66 mi WNW of the CRN Site. The pathways considered 27 included plume, ground, inhalation, and ingestion of locally grown meat, milk, and vegetables.

28 Default values from Regulatory Guide 1.109 (NRC 1977-TN90) were used when site-specific G-7

1 input parameters were not available. Based on its review of available documents and 2 understanding gained during the site audit, the NRC staff concluded that the assumed exposure 3 pathways and input parameters were appropriate. These pathways and parameters were used 4 by the NRC staff in its independent calculations using GASPAR II.

5 Joint frequency distribution data of wind speed and wind direction by atmospheric stability class 6 for the CRN Site provided in ER Tables 2.7.5-2 to 2.7.5-8 (TVA 2017-TN4921) were used as 7 input to the XOQDOQ code (Sagendorf et al. 1982-TN280) to calculate the average 8 atmospheric dispersion factor (/Q, the annual average normalized air concentration value[s])

9 and deposition factor (D/Q, the annual normalized total surface concentration rate[s]) values for 10 routine releases. The NRC staff reviewed the XOQDOQ output files provided by TVA and 11 concluded they are appropriate for use in dose calculations for the gaseous effluents.

12 Population doses were calculated for all types of releases (i.e., noble gases, particulates, 13 iodines, H-3, and C-14) using the GASPAR II code for the following: plume immersion; direct 14 radiation from radionuclides deposited on the ground; inhalation; and ingestion of vegetables, 15 milk, and meat.

16 G.1.2.2 Resources Used 17 To calculate doses to the public from gaseous effluents, the NRC staff used a personal 18 computer version of the XOQDOQ and GASPAR II codes titled NRCDose Version 2.3.13 19 (CNS 2006-TN102) obtained through the Oak Ridge RSICC and updates to the user interface 20 obtained directly from Chesapeake Nuclear Services.

21 G.1.2.3 Input Parameters 22 Table G-3 provides a list of the major parameters used in calculating dose to the public from 23 gaseous effluent releases during normal operation.

24 Table G-3. Parameters Used in Calculating Dose to the Public from Gaseous Effluent 25 Releases Parameter NRC Staff Value Comments Nuclide Per Unit(a) Per Site(b)

New unit gaseous effluent source Ar-41 4.00 x 10+1 5.44 x 10+2 Values from Environmental term (Ci/yr)(a) Kr-83m 1.07 x 10-3 1.28 x 10-2 Report (ER) Tables 3.5-3 and Kr-85 1.21 x 10+2 7.20 x 10+2 3.5-4 (TVA 2017-TN4921).

Kr-85m 8.47 x 10+1 3.39 x 10+2 Kr-87 8.18 x 100 3.27 x 10+1 Kr-88 3.63 x 10+1 1.45 x 10+2 Kr-89 1.25 x 10-7 5.00 x 10-7 Xe-131m 2.75 x 10+2 1.67 x 10+3 Xe-133 5.61 x 10+2 2.24 x 10+3 Xe-133m 2.63 x 10+1 1.05 x 10+2 Xe-135 7.04 x 10+1 2.82 x 10+2 Xe-135m 3.19 x 100 1.28 x 10+1 Xe-137 7.50 x 10-1 3.00 x 100 Xe-138 2.86 x 100 1.14 x 10+1 I-129 6.68 x 10-12 8.02 x 10-11 I-131 7.70 x 10-2 2.31 x 10-1 I-132 3.38 x 10-1 1.35 x 100 I-133 2.63 x 10-1 1.05 x 100 26 G-8

Table G-3. (contd)

Parameter NRC Staff Value Comments Nuclide Per Unit(a) Per Site(b)

I-134 5.84 x 10-1 2.33 x 100 I-135 3.72 x 10-1 1.49 x 100 H-3 3.10 x 10+2 1.01 x 10+3 C-14 7.30 x 100 1.00 x 10+1 Na-24 6.25 x 10-4 2.50 x 10-3 P-32 1.24 x 10-4 5.68 x 10-4 Cr-51 5.42 x 10-3 2.17 x 10-2 Mn-54 8.35 x 10-4 5.22 x 10-3 Fe-55 1.00 x 10-3 4.01 x 10-3 Mn-56 5.24 x 10-4 2.17 x 10-3 Co-57 2.75 x 10-5 1.10 x 10-4 Co-58 2.30 x 10-2 6.90 x 10-2 Fe-59 1.25 x 10-4 9.55 x 10-4 Co-60 8.80 x 10-3 2.64 x 10-2 Ni-63 1.22 x 10-3 1.46 x 10-2 Cu-64 1.54 x 10-3 6.18 x 10-3 Zn-65 1.71 x 10-3 6.86 x 10-3 Br-84 1.07 x 10-6 1.28 x 10-5 Rb-88 8.17 x 10-7 9.80 x 10-6 Rb-89 6.67 x 10-6 2.67 x 10-5 Sr-89 3.00 x 10-3 9.00 x 10-3 Sr-90 1.20 x 10-3 3.60 x 10-3 Y-90 7.09 x 10-6 2.84 x 10-5 Sr-91 1.54 x 10-4 6.18 x 10-4 Y-91 3.72 x 10-5 1.49 x 10-4 Sr-92 1.21 x 10-4 4.84 x 10-4 Y-92 9.60 x 10-5 3.84 x 10-4 Y-93 1.71 x 10-4 6.86 x 10-4 Zr-95 1.00 x 10-3 3.00 x 10-3 Nb-95 2.50 x 10-3 7.50 x 10-3 Mo-99 9.19 x 10-3 3.68 x 10-2 Tc-99m 4.59 x 10-5 1.83 x 10-4 Ru-103 5.42 x 10-4 2.17 x 10-3 Rh-103m 1.23 x 10-9 1.48 x 10-8 Ru-106 7.80 x 10-5 2.34 x 10-4 Rh-106 3.81 x 10-12 4.57 x 10-11 Ag-110m 1.78 x 10-4 2.14 x 10-3 Sb-124 2.79 x 10-5 1.12 x 10-4 Sb-125 9.42 x 10-6 3.77 x 10-5 Te-129m 3.38 x 10-5 1.35 x 10-4 Te-131m 1.17 x 10-5 4.68 x 10-5 Te-132 5.94 x 10-6 7.13 x 10-5 Cs-134 2.30 x 10-3 6.90 x 10-3 Cs-136 9.19 x 10-5 3.68 x 10-4 Cs-137 8.14 x 10-3 3.26 x 10-2 Cs-138 2.63 x 10-5 1.05 x 10-4 Ba-140 4.17 x 10-3 1.67 x 10-2 La-140 2.79 x 10-4 1.12 x 10-3 Ce-141 1.42 x 10-3 5.68 x 10-3 Ce-143 9.63 x 10-9 1.16 x 10-7 Ce-144 2.92 x 10-6 1.17 x 10-5 Pr-144 2.92 x 10-6 1.17 x 10-5 W-187 2.92 x 10-5 1.17 x 10-4 Np-239 1.84 x 10-3 7.35 x 10-3 G-9

Table G-3. (contd)

Parameter NRC Staff Value Comments Population distribution From ER Table 5.4-5 (TVA 2017- Site-specific population TN4921) distribution within 50 miles of CRN Site projected to 2067 Maximum dispersion direction WNW from ER Table 5.4-4 Site-specific meteorological (TVA 2017-TN4921) data from June 1, 2011 through May 31, 2013 were used in the determination of maximum dispersion distance Atmospheric dispersion factors Based on site-specific (sec/m3) TVA ER Table 2.7.6-10 meteorological data from June (TVA 2017-TN4921) 1, 2011 through May 31, 2013 Ground deposition factors (m-2) TVA ER Section 2.7 per Table 5.4- Site-specific data provided by 4 (TVA 2017-TN4921) TVA in ER Table 2.7.6-10 8

Annual milk production within the 1.91 x 10 kg/yr From TVA ER Table 5.4-4 50-mi radius of the site where TVA provided a projected kg/yr value to the year 2067.

8 Annual meat production within the 1.63 x 10 kg/yr Site-specific data from ER 50-mi radius of the site Table 5.4-4 where TVA provided a projected value to the year 2067 (TVA 2017-TN4921)

Consumption factors for milk, Default values in GASPAR meat, leafy vegetables, and (Strenge et al. 1987-TN83) vegetables Vegetables Leafy Vegetables Milk Meat (kg/yr) (kg/yr) (L/yr) (kg/yr)

Average Adult 190 30 110 95 Average Teen 240 20 200 59 Average Child 200 10 170 37 Maximum Adult 520 64 310 110 Maximum Teen 630 42 400 65 Maximum Child 520 26 330 41 Maximum Infant 0 0 330 0 Receptor locations and Site boundary: 0.21 mi WNW Site-specific values from ER dispersion coefficients Nearest residence: 0.66 mi WNW Table 5.4-10 (TVA 2017-Nearest vegetable garden: 1.15 TN4921) mi WNW Nearest meat animal: 0.70 mi WNW Atmospheric Dispersion Coefficient /Q (s m-3)

No Decay/ 2.26-Day Half-Life/ 8-day Half-Life/

MEI Location Undepleted Undepleted Depleted D/Q (m-2)

-4 -4 -4 Nearest Site Boundary, 2.0 x 10 2.0 x 10 1.0 x 10 5.2 x 10-8 0.21 mi WNW MEI, 2.5 x 10-5 2.5 x 10-5 2.3 x 10-5 8.5 x 10-9 0.66 mi WNW 1

G-10

Table G-3. (contd)

Atmospheric Dispersion Coefficient /Q (s m-3)

No Decay/ 2.26-Day Half-Life/ 8-day Half-Life/

MEI Location Undepleted Undepleted Depleted D/Q (m-2)

Nearest Vegetable Garden, 1.0 x 10-5 9.9 x 10-6 8.7 x 10-6 3.3 x 10-9 1.15 mi WNW Nearest Meat Animal, 2.3 x 10-5 2.3 x 10-5 2.1 x 10-5 7.8 x 10-9 0.7 mi WNW Parameter NRC Staff Value Comments Fraction of year leafy vegetables 1.0 Bounding value that maximizes are grown the estimate of consequences Fraction of year milk cows are on 1.0 Bounding value that maximizes pasture the estimate of consequences Fraction of MEIs vegetable intake 0.76 Conservative value from own garden Fraction of year beef cattle on 1.0 Bounding value that maximizes pasture the estimate of consequences (a) Per unit is the plant parameter envelope (PPE) bounding value for a single SMR unit taken from ER Table 3.5-4 (TVA 2017-TN4921) and is used throughout this section.

(b) Per site is the PPE bounding value for the CRN Site taken from ER Table 3.5-3 (TVA 2017-TN4921) and is included for multi-unit (site-wide) analysis throughout this section.

1 The NRC staff compared the estimated population dose documented in the TVA ER (TVA 2017-2 TN4921) from normal gaseous effluents with the results calculated by the NRC staff. The doses 3 calculated by the NRC staff confirmed the doses calculated by TVA.

4 TVA calculated the MEI dose by summing the nearest residence (0.66 mi WNW) inhalation 5 dose and the dose from eating vegetables from the nearest garden and eating meat from the 6 nearest animal, even though the three locations are not geographically at the same place. This 7 approach maximized the estimated dose. The NRC staff compared its estimates of doses to the 8 MEI with the results documented by TVA (TVA 2017-TN4921). The doses calculated by the 9 NRC staff confirmed the doses calculated by TVA.

10 Table G-4 and Table G-5 provide doses to the MEI calculated by the NRC staff. Doses to the 11 MEI were calculated at the nearest residence, nearest garden, and the nearest meat animal.

12 The doses estimated by TVA and those calculated by the NRC staff were comparable to the 13 TVA estimates, but were slightly more conservative (i.e., larger).

G-11

1 Table G-4. Doses to the MEI from Normal Gaseous Effluent Releases for an SMR Unit Total Body Dose Skin Dose Max Organ Dose Location Pathway (mrem/yr)(a) (mrem/yr)(a) (mrem/yr)(a)

Nearest owner-controlled area Plume 6.20 x 10+0 1.40 x 10+1 6.31 x 10+0 (Lung) boundary, 0.21 mi WNW Nearest residence, 0.66 mi Ground 9.17 x 10-2 1.08 x 10-1 1.08 x 10-1 (Skin)

WNW Inhalation Adult 1.84 x 10-1 1.76 x 10-1 1.48 x 10+0 (Thyroid)

Teen 1.86 x 10-1 1.78 x 10-1 1.85 x 10+0 (Thyroid)

Child 1.64 x 10-1 1.57 x 10-1 2.18 x 10+0 (Thyroid)

Infant 9.51 x 10-2 9.05 x 10-2 1.93 x 10+0 (Thyroid)

Nearest garden, 1.15 mi WNW Vegetable Adult 5.58 x 10-1 5.47 x 10-1 2.21 x 10+0 (Bone)

Teen 8.36 x 10-1 8.25 x 10-1 3.56 x 10+0 (Bone)

Child 1.87 x 10+0 1.86 x 10+0 8.52 x 10+0 (Bone)

Nearest meat animal. 0.70 mi Meat WNW Adult 4.03 x 10-1 4.00 x 10-1 1.80 x 10+0 (Bone)

Teen 3.29 x 10-1 3.27 x 10-1 1.51 x 10+0 (Bone)

Child 6.01 x 10-1 5.99 x 10-1 2.58 x 10+0 (Bone)

(a) NRC staff confirmatory calculation results.

2 Table G-5. Doses to the MEI from Normal Gaseous Effluent Releases for the Site Total Body Dose Skin Dose Max Organ Dose Location Pathway (mrem/yr)(a) (mrem/yr)(a) (mrem/yr)(a)

Nearest owner-controlled area Plume 4.01 x 10+1 8.43 x 10+1 4.06 x 10+1 (Lung) boundary, 0.21 mi WNW Nearest residence, 0.66 mi Ground 3.07 x 10-1 3.60 x 10-1 3.60 x 10-1 (Skin)

WNW Inhalation Adult 6.04 x 10-1 5.75 x 10-1 5.07 x 10+0 (Thyroid)

Teen 6.10 x 10-1 5.80 x 10-1 6.41 x 10+0 (Thyroid)

Child 5.39 x 10-1 5.12 x 10-1 7.62 x 10+0 (Thyroid)

Infant 3.12 x 10-1 2.95 x 10-1 6.79 x 10+0 (Thyroid)

Nearest garden, 1.15 mi WNW Vegetable Adult 1.03 x 10-0 9.91 x 10-1 3.24 x 10+0 (Bone)

Teen 1.45 x 10-0 1.41 x 10+0 5.15 x 10+0 (Bone)

Child 3.03 x 10+0 2.98 x 10+0 1.23 x 10+1 (Bone)

Nearest meat animal. 0.70 mi Meat WNW Adult 6.38 x 10-1 8.58 x 10-1 2.48 x 10+0 (Bone)

Teen 5.01 x 10-1 1.41 x 10+0 2.09 x 10+0 (Bone)

Child 8.92 x 10-1 8.78 x 10-1 3.92 x 10+0 (Bone)

(a) NRC staff confirmatory calculation results.

3 Table G-6 and Table G-7 compare the TVA population dose estimates taken from Tables 5.4-13 4 (per SMR unit) and 5.4-17 (per CRN Site) of the ER (TVA 2017-TN4921) with the NRC staff 5 estimates. The NRC staffs independent calculation for population doses yielded results that 6 are comparable to the TVA estimates on a per unit basis, but are considerably lower (by about 7 50 percent) on a per site basis.

G-12

1 Table G-6. Comparison of Population Total Body Doses from Gaseous Effluent Releases 2 for an SMR Unit TVA ER NRC Staff Estimated Pathway (person-rem/yr)(a) Population (person-rem/yr)

Plume 8.0 x 10-1 8.04 x 10-1 Ground plane 5.7 x 10-1 5.71 x 10-1 Inhalation 1.4 x 10+0 1.44 x 10+0 Vegetable ingestion 7.7 x 10+0 7.67 x 10+0 Milk ingestion 1.8 x 10+0 1.80 x 10+0 Meat ingestion 2.6 x 10+0 2.61 x 10+0 Total 1.5 x 10+1 1.49 x 10+1 3 Table G-7. Comparison of Population Total Body Doses from Gaseous Effluent Releases 4 for the Site TVA ER NRC Staff Estimated Pathway (person-rem/yr)(a) Population (person-rem/yr)

Plume 3.63 x 10+0 Ground plane 1.91 x 10+0 Inhalation 4.73 x 10+0 Vegetable ingestion 1.32 x 10+1 Milk ingestion 3.03 x 10+0 Meat ingestion 4.05 x 10+0 Total 6.0 x 10+1 3.06 x 10+1 5 G.1.3 Cumulative and Population Dose Estimates 6 Based on parameters shown for the liquid and gaseous pathways, Table G-1 and Table G-3, 7 respectively, the NRC staff compared the results documented in the ER (TVA 2017-TN4921) for 8 all pathway dose estimates to the MEI with those calculated by the NRC staff. Cumulative dose 9 estimates include doses from all pathways (i.e., direct exposure, liquid effluents, and gaseous 10 effluents) for SMRs at the CRN Site, as well as the existing and reasonably foreseeable 11 radiological projects and facilities described in Section 7.8 of this EIS. Based on its 12 conservative approach to liquid effluent calculations and its further assumption of summing the 13 MEI doses for each of these individual facilities, TVA demonstrated the cumulative MEI dose 14 would not exceed the 100 mrem/yr dose limit in 10 CFR 20.1301 (TN283).

15 Based on TVAs conservative approach, the NRC staff are confident that the all-pathways dose 16 from normal operations at the CRN Site are bounding (i.e., actual doses are expected to be no 17 higher than those presented by TVA). Separately, a cumulative dose was estimated for 18 radioactive materials introduced into the general environment as the result of operations that are 19 part of a nuclear fuel cycle for comparison to the dose standards of 40 CFR Part 190 (TN739).

20 For this estimation, the NRC staff considered contributions from Oak Ridge National Laboratory-21 related facilities (2.4 mrem [Section 7.8 of this EIS]), Watts Bar Nuclear Power Plant (2.6 22 mrem/yr [TVA 2017-TN4921]), and the CRN Site (11 mrem/yr [TVA 2017-TN4921]) for a total of 23 16 mrem/yr, which does not exceed the 25-mrem/yr annual whole body dose equivalent 24 standard in 40 CFR Part 190 (TN739).

G-13

1 G.1.4 Estimates of Dose to Nonhuman Biota from Liquid and Gaseous Effluents 2 The NRC staff performed confirmatory calculations of the doses to nonhuman biota from liquid 3 and gaseous effluents using the LADTAP II (Strenge et al. 1986-TN82) and GASPAR II 4 (Strenge et al. 1987-TN83) codes. The NRC staff used a personal computer version of the 5 LADTAP II code and GASPAR II code titled NRCDose Version 2.3.13 (CNS 2006-TN102) 6 obtained through the Oak Ridge RSICC.

7 G.1.4.1 Liquid Effluent Pathways 8 The NRC estimated doses to nonhuman biota from liquid effluents using fish, invertebrates, and 9 algae as surrogate aquatic biota species. Muskrats, raccoons, herons, and ducks are used as 10 surrogate terrestrial biota species. The NRC staff recognizes the LADTAP II computer program 11 (Strenge et al. 1986-TN82) as an appropriate method for calculating dose to the aquatic biota 12 and for calculating the liquid pathway contribution to terrestrial biota. Most of the LADTAP II 13 input parameters are specified in Section G.1.1.3. The NRC staffs dose analysis confirmed that 14 the liquid pathway doses to biota estimated by TVA were bounding.

15 G.1.4.2 Gaseous Effluent Pathways 16 The NRC staff assessed doses to terrestrial nonhuman biota from the gaseous effluent pathway 17 based on the results of the GASPAR II calculations for human doses discussed in Section 18 G.1.2. Again, muskrats, raccoons, herons, and ducks were used as surrogate terrestrial biota 19 species. The NRC staff assessed the doses at the site boundary (0.21 mi WNW) to achieve a 20 reasonable estimate of the doses to terrestrial biota that might live on the CRN Site. It was 21 assumed that doses for raccoons and ducks were equivalent to adult human doses for 22 inhalation, vegetation ingestion, and the plume. The dose from ground exposure was doubled 23 for terrestrial biota. The doubling of doses from ground deposition reflects the closer proximity of 24 these organisms to the ground. Muskrats and herons do not consume terrestrial vegetation, so 25 that pathway was not included for those organisms. The NRC staffs dose assessment results 26 were slightly less than the gaseous pathway doses to biota estimated by TVA as shown in 27 Table 5-11 of this EIS, confirming the bounding nature of the TVA analysis.

28 G.2 Supporting Documentation for Radiological Dose Assessments of 29 Postulated Severe Accidents 30 The NRC staff reviewed the severe accident Melcor Accident Consequence Code System 31 (MACCS) input parameters and values applied by TVA. This included the MACCS ATMOS, 32 EARLY and CHRONIC files for the severe accident releases considered by TVA (TVA 2017-33 TN5093). The NRC staff also reviewed the site and meteorological input files provided by TVA.

34 The NRC staff varied MACCS input parameter values when appropriate.

35 In conducting their independent evaluations with the MACCS computer code, the NRC staff 36 evaluated impacts based on the three plume exposure pathway emergency planning zone 37 (EPZ) assumptions: 1) site boundary EPZ (at 0.21 mi) considered in Part 5A of the TVA ESP 38 application (TVA 2017-TN5443); 2) the 2-mi EPZ considered in Part 5B of the TVA ESP 39 application (TVA 2017-TN5442); and 3) a 10-mi EPZ, which is consistent with those assumed 40 for large light water reactors. Evaluations were performed for these three EPZ assumptions 41 pending a final determination of the EPZ exemption request included in Part 6 of the TVA ESP 42 application (TVA 2017-TN5444).

G-14

1 The NRC staff and the TVA results were directly compared for the 2-mi EPZ distance evaluation 2 and were found to be consistent with each other. The NRC staff computed a total population 3 dose of 6.03 x 10-3 person-rem/reactor-year compared to the TVA result of 7.71 x 10-3 person-4 rem/reactor-year. The NRC staffs economic cost estimate is $19.40/reactor-year, and the TVA 5 estimate is $29.30/reactor-year. Both of these estimates indicate a low economic risk.

6 The NRC staff and TVA total population dose and economic cost estimates for all three of the 7 EPZ distances do not differ significantly, as shown in Table G-8.

8 Table G-8. NRC Confirmatory Calculations TVA Calculation TVA NRC Calculation Total Population NRC Calculation EPZ Total Population Dose Dose Calculation Economic Cost Distances (person-rem/ (person-rem/ Economic Cost ($/reactor-(mi) reactor-year) reactor-year)a ($/reactor-year) year)a 0.21 6.19 x 10-3 NA 19.5 NA 2.0 6.03 x 10-3 7.71 x 10-3 19.4 29.3 10 5.97 x 10-3 NA 23.0 NA (a) TVA calculated population doses and economic costs for a 2-mi EPZ only.

9 The NRC staff conducted a sensitivity analysis by varying the evacuation speeds and relocation 10 times for the 10-mi EPZ assumption. The sensitivity analysis values were obtained from 11 NUREG-0498 (NRC 1978-TN5095) and NUREG/CR-7110 (Bixler et al. 2013-TN4592). The 12 results of the 10-mi EPZ baseline and sensitivity cases are presented in Table G-9. The results 13 reveal a negligible difference between the two cases.

14 Table G-9. Results of the NRC Staffs Sensitivity Analysis for 10-Mi EPZ Base and 15 Sensitivity Cases Total Population Dose Economic Cost Case (person-rem/reactor-year) ($/reactor-year)

Baseline 5.97 x 10-3 23.0 Sensitivity 6.04 x 10-3 23.0 16 Based on the Commissions ruling in CLI-16-07 regarding two MACCS decontamination input 17 parameter values (NRC 2016-TN4631), the staff determined that a sensitivity study would be 18 appropriate for the CRN Sites economic risk. For the sensitivity study, the NRC staff only varied 19 the decontamination costs for both decontamination levels set in the MACCS calculations. The 20 decontamination costs for low-level decontamination was set to $24,000 and to $100,000 for the 21 high-level decontamination. The baseline analysis already set the timeframe to conduct the 22 decontamination activities to the value specified in CLI-16-07, namely one year. The results of 23 the sensitivity study as compared to the NRC staffs 2-mi EPZ baseline case are presented in 24 Table G-10 where total population dose risk values are provided for additional context between 25 the two cases. The results of this sensitivity study also demonstrates no significant difference 26 between the two cases. As shown in Table G-8, there is no significant difference for the total 27 economic costs between the three EPZ distance assessments. Therefore, the same small 28 increase in economic cost as seen in this sensitivity analysis is expected for the site boundary 29 and 10-mi EPZ distance assessments.

G-15

1 Table G-10. Results of the NRC Staffs Decontamination Cost Sensitivity Analysis for 2 2-Mi EPZ Base and Sensitivity Cases Total Population Dose Economic Cost Case (person-rem/reactor-year) ($/reactor-year)

Baseline 6.03 x 10-3 19.4 Sensitivity 6.09 x 10-3 23.9 3 G.3 References 4 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 5 Protection Against Radiation." Washington, D.C. TN283.

6 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 7 Production and Utilization Facilities." Washington, D.C. TN249.

8 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 9 "Environmental Radiation Protection Standards for Nuclear Power Operations." Washington, 10 D.C. TN739.

11 Bixler, N., R. Gauntt, J. Jones, and M. Leonard. 2013. State-of-the-Art Reactor Consequence 12 Analyses Project Volume 1: Peach Bottom Integrated Analysis. NUREG/CR-7110, Volume 1, 13 Revision 1, Sandia National Laboratories, Albuquerque, New Mexico. Accession No.

14 ML13150A053. TN4592.

15 CNS (Chesapeake Nuclear Services, Inc.). 2006. NRCDose for Windows, Suite of NRCs 16 Dose Modeling Codes for Reactor Radioactive Effluents. Annapolis, Maryland. Available at 17 http://www.chesnuc.com/docs/NRCDose%20Datasheet.pdf. TN102.

18 NRC (U.S. Nuclear Regulatory Commission). 1977. Calculation of Annual Doses to Man from 19 Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 20 Part 50, Appendix I. Regulatory Guide 1.109, Revision 1, Washington, D.C. Accession No.

21 ML003740384. TN90.

22 NRC (U.S. Nuclear Regulatory Agency). 1978. Final Environmental Impact Statement Related 23 to the Operation of Watts Bar Nuclear Plant Units Nos. 1 and 2. NUREG-0498, Washington, 24 D.C. Accessed October 18, 2017, at 25 http://152.87.4.98/environment/reports/wattsbar2/related/dec_1978.pdf. TN5095 26 NRC (U.S. Nuclear Regulatory Commission). 2000. Environmental Standard Review Plan 27 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 28 Main Report and 2007 Revisions, Washington, D.C. Available at http://www.nrc.gov/reading-29 rm/doc-collections/nuregs/staff/sr1555/toc/. TN614.

30 NRC (U.S. Nuclear Regulatory Commission). 2000. Environmental Standard Review Plan 31 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 32 Main Report and 2007 Revisions, Washington, D.C. Available at http://www.nrc.gov/reading-33 rm/doc-collections/nuregs/staff/sr1555/toc/. TN614.

G-16

1 NRC (U.S. Nuclear Regulatory Commission). 2016. Memorandum and Order in the Matter of 2 Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3). CLI-16-07.

3 Washington, D.C. Accession No. ML16125A150. TN4631.

4 Sagendorf, J.F., J.T. Goll, and W.F. Sandusky. 1982. XOQDOQ: Computer Program for the 5 Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations.

6 NUREG/CR-2919, Pacific Northwest Laboratory, Richland, Washington. Accession No.

7 ML081360412. TN280.

8 Strenge, D.L., R.A. Peloquin, and G. Whelan. 1986. LADTAP IITechnical Reference and 9 User Guide. NUREG/CR-4013, Pacific Northwest Laboratory, Richland, Washington.

10 Accession No. ML14098A069. TN82.

11 Strenge, D.L., T.J. Bander, and J.K. Soldat. 1987. GASPAR IITechnical Reference and User 12 Guide. NUREG/CR-4653, Pacific Northwest Laboratory, Richland, Washington. Accession No.

13 ML14098A066. TN83.

14 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 15 Application, Part 03Environmental Report (Revision 1)." Chattanooga, Tennessee.

16 Accession No. ML18003A471. TN4921.

17 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 18 Application, Part 5AEmergency Plan (Site Boundary EPZ) (Revision 1)." Chattanooga, 19 Tennessee. Accession No. ML18003A475. TN5443.

20 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 21 Application, Part 5BEmergency Plan (2-Mile EPZ) (Revision 1)." Chattanooga, Tennessee.

22 Accession No. ML18003A480. TN5442.

23 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 24 Application, Part 06Exemptions and Departures (Revision 1)." Chattanooga, Tennessee.

25 Accession No. ML18003A487. TN5444.

26 TVA (Tennessee Valley Authority). 2017. Letter from J.W. Shea to NRC, dated March 1, 2017, 27 regarding "Submittal of Calculation Input and Output Files in Support of Early Site Permit 28 Application for Clinch River Nuclear Site." CNL-17-032, Chattanooga, Tennessee. Accession 29 No. ML17065A269. TN5093.

G-17

1 APPENDIX H 2 LIST OF AUTHORIZATIONS, PERMITS, AND CERTIFICATIONS 3 Table H-1 contains a list of the environmental-related authorizations, permits, and certifications 4 potentially required by Federal, State, regional, local, and affected Native American Tribal 5 agencies related to site preparation, construction, and operation of two or more small modular 6 reactors at the Clinch River Nuclear Site. Table H-1 was adapted from Table 1.2-2 of the 7 Tennessee Valley Authoritys (TVAs) August 1, 2017 submittal to the U.S. Nuclear Regulatory 8 Commission (NRC) (TVA 2017-TN4922), which was incorporated into Revision 1 of its 9 application (TVA 2017-TN4921).

10 H.1 References 11 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 12 Application, Part 03Environmental Report (Revision 1)." Chattanooga, Tennessee.

13 Accession No. ML18003A471. TN4921.

14 TVA (Tennessee Valley Authority). 2017. Letter from J.W. Shea to NRC, dated August 1, 15 2017, regarding "Submittal of Supplemental Information Related to the Environmental Audit in 16 Support of Early Site Permit Application for Clinch River Nuclear Site." CNL-17-097, 17 Chattanooga, Tennessee. Accession No. ML17234A003. TN4922.

18 H-1

1 Table H-1. Authorizations Required for Preconstruction, Construction, and Operation Activities Agency Authority Requirement Activity Covered NRC Atomic Energy and Energy Early site permit or combined Site licensing, including safety-Reorganization Acts 10 CFR license (COL) or Limited Work related construction activities and Part 52 Subpart C or 10 CFR Authorization, in addition to operation of a nuclear power 50.10(e)(1) applicable By-Product License facility Source Material Licenses, and Special Nuclear Material License Federal Aviation Administration Federal Aviation Act 49 U.S.C. Construction Notice Notice of erection of structures

§ 106; 14 CFR Part 77 more than 200 ft high that potentially may affect air navigation U.S. Department of Hazardous Material Certificate of Registration Transportation of hazardous Transportation (DOT) Transportation Act 49 CFR Part materials.

107 Subpart G Tennessee Department of TCA 54-5-302 Entrance Permits This includes ramps, driveways, H-2 Transportation (TDOT) and other access points. Requires traffic studies and engineering designs to show design and potential impacts of proposed changes.

TDOT TCA § 54-5-302 Right-of-way (ROW) Permit Required for installing utilities in highway ROWs U.S. Army Corps of Engineers Clean Water Act, 33 CFR Parts Section 404 Permit Disturbance, crossing, or filling-in (USACE) 323 and 330 of wetland areas or navigable waters from site Rivers and Harbors Act, Section 10 Permit Construction and maintenance of 33 U.S.C. § 403 et seq. intake, discharge, and barge structures in navigable waters of the United States U.S. Coast Guard Ports and Waterways Safety Private Aids to Navigation Permit Construction of discharge pipeline Act, 33 U.S.C. §§ 1221 et seq. in navigable waters 2

Table H-1. (contd)

Agency Authority Requirement Activity Covered U.S. Environmental Protection Resource Conservation and Acknowledgement of Notification of Hazardous Waste Generation Agency (EPA) and Tennessee Recovery Act, Section 3010 Hazardous Waste Activity Department of Environment and Conservation (TDEC)

EPA Facility Response Plan Facility Response Plan Approval Spill/Discharge Response Program (40 CFR Part 112), and the EPA Hazardous Waste Contingency Plan Spill Prevention, Control and SPCC/Integrated Pollution Spill/Discharge Prevention Plan Countermeasures (SPCC) rule Prevention (IPP) Plan (40 CFR Part 112), Appendix F, Sections 1.2.1 and 1.2.2 U.S. Fish and Wildlife Service Endangered Species Act Consultation/Biological Evaluation of effects on listed (FWS) Section 7 (16 U.S.C. § 1536) Assessment species H-3 FWS Migratory Bird Act/Executive Responsibility of Federal Agencies TVA is exempt from the Act Order 13186 to Protect Migratory Birds requirements, but complies voluntarily; TVA is subject to the Executive Order.

City of Oak Ridge Municipal Site Plan Approval Coordination with the Planning Board and/or Zoning Board of Adjustment for development of the site in compliance with city ordinances Flood Encroachment Compliance with City of Oak Ridge Permit/Floodplain Permit Zoning Article IX Special Districts 9.08 a, b, c Floodway Districts, Floodway Fringe Area; mostly covered in Stormwater Pollution Prevention Plan and grading permit

Table H-1. (contd)

Agency Authority Requirement Activity Covered Sanitary Sewer Connection Compliance with the City Industrial Pre-treatment Program if required, or connection to the City Wastewater Treatment System Potable Water A potable water line on the small modular reactor site would tap into the existing City of Oak Ridge water line on Bear Creek Road. If the existing waterline has to be extended for TVA, additional planning and approvals would be necessary by the city.

Construction Permits Construction of the new plant facilities in compliance with city H-4 ordinances TDEC Federal Clean Water Act Notice of Intent (NOI) for coverage Compliance with Federal and State (33 U.S.C. §§ 1251 et seq.) and under an Individual National water-quality standards, Tennessee Code Annotated Pollution Discharge Elimination discharges to waters of the state (TCA) § 69-3-108: Tennessee System (NPDES) Permit for due to construction of the new Water Quality Control Act of stormwater discharges associated plant, switchyards, and 1977 with construction activities. transmission lines (aboveground and underground).

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

construction activities construction support activities (e.g., concrete or asphalt batch

Table H-1. (contd)

Agency Authority Requirement Activity Covered plants, equipment staging yards, material storage areas, excavated material disposal areas, borrow areas) dewatering of work areas of collected stormwater and groundwater water used to wash vehicles water used to control dust routine building washdown uncontaminated groundwater unpolluted foundation or footing drains.

Appropriate dewatering controls include, but are not limited to, weir tank, dewatering tank, gravity bag H-5 filter, sand media particulate filter, pressurized bag filter, cartridge filter or other control units providing the level of treatment necessary to comply with permit requirements.

TDEC (continued) Federal Clean Water Act Stormwater Pollution Prevention Compliance with Federal and State (33 U.S.C. §§ 1251 et seq.) and Plan, to include Common Plan of water-quality standards, TCA § 69-3-108: Tennessee Development, Soil Erosion and discharges to waters of the state Water Quality Control Act of Sediment Control Plan (structural due to construction of the new 1977 (continued) control measures, engineering plant, switchyards, and design of sediment basin/controls transmission lines (aboveground for projects 10 ac or greater), etc. and underground)

Aquatic Resource Alteration Permit Clinch River arm of the Watts Bar required for alterations of a stream Reservoir water required for or wetland, including diversion of cooling purposes. Portions of the surface waters of the state. new plant site, proposed causeway, switchyards, and onsite

Table H-1. (contd)

Agency Authority Requirement Activity Covered and potential offsite transmission lines may be located in freshwater wetlands and transitional areas.

NPDES Industrial Stormwater Cooling water, service water, and General Permit for plant operation stormwater runoff discharge from activities; EPA Application Forms plant operations 2D (Application for Permit to Discharge Process Wastewater) and 2F (Application for Permit to Discharge Stormwater Discharges Associated with Industrial Activity)

NOI for NPDES General Permit of Point source discharges of Discharges from the Application of pesticides used for mosquito and Pesticides (TNP100000) other flying insect pest control, H-6 weed and algae control, animal pest control, and forest canopy pest control to waters of the state Sanitary Waste Water - Portable Must use licensed wastewater Facilities hauler Permanent Sanitary Waste Water Connect to Wastewater Treatment Plant Tennessee Water Resources Water Resources Notification; Surface-water or groundwater Information Act, Water Withdrawal Registration withdrawal of an average of TCA §§ 69-7-301 et seq. 10,000 gal/day Federal Clean Air Act, Title V Operating Permit; Discharge of air pollutants from 42 U.S.C. § 7401 et seq. Prevention of Significant cooling tower(s), emergency Deterioration Preconstruction generators, auxiliary boiler(s), and Permit ancillary equipment

Table H-1. (contd)

Agency Authority Requirement Activity Covered Texas Department of State 25 Texas Administrative Code Emergency Plan for the response Transportation of low-level Health Services, Radiation (TAC) § 289.252 Licensing of to an accident or incident involving radioactive waste (LLRW) to the Control Program, Radiation Radioactive Material shipments of radioactive waste. Texas Disposal Facility Safety Licensing Branch Proof of financial responsibility such as insurance that the carrier has in order to comply with DOT requirements.

25 TAC § 289.257 Packaging Provide a list of approved shipping Shipping of LLRW to the Texas and Transportation of containers along with their Disposal Facility Radioactive Material certificates of compliance or other certifying documentation. For shippers that manufacture their own containers they must submit their quality assurance procedures.

H-7 TDEC Division of Radiological TCA § 68-202-201 et seq. TDEC Obtain a License-for-Delivery from Transportation of radioactive waste Health (DRH) Rule 0400- 20-10-.32 the DRH (Form RHS 8-30). within the State of Tennessee to a Persons whose activities result in disposal/processing facility the generation of radioactive waste have the primary responsibility for assuring that a License-for-Delivery is obtained.

TN State Historic Preservation Section 106 of the National As a Federal agency, TVA is Protection of archaeological and Office (SHPO) Tribal Historic Historic Preservation Act required to comply with Section historical resources Preservation Officer (THPO) (NHPA) 106 of the NHPA, which includes SHPO/THPO, and identification of potentially affected resources, i.e.,

a site survey.

1

1 APPENDIX I 2 CLINCH RIVER NUCLEAR SITE CHARACTERISTICS AND PLANT 3 PARAMETER ENVELOPE VALUES 4 The specific early site permit (ESP) site characteristics and plant parameter envelope (PPE) 5 values used in this document are from Tables 3.1-1 and 3.1-2 of the Environmental Report 6 (TVA 2017-TN4921) and Table 2.0-1 of the Site Safety Analysis Report (TVA 2017-TN5387).

7 The review team used these characteristics and values, as appropriate, in its independent 8 evaluation of the environmental impacts of the proposed new units. Appendix J captures 9 additional representations and assumptions made by the review team when assessing the 10 environmental impacts associated with construction and operation of a new nuclear power plant.

11 The ESP site characteristics and PPE values used in the review teams evaluation are 12 presented in Tables I-1, I-2, and I-3, respectively. Any mention of figures or tables in Tables I-1, 13 I-2, or I-3 refer to figures or tables in the Environmental Report or Site Safety Analysis Report.

14 I.1 References 15 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 16 Application, Part 02Site Safety Analysis Report (Revision 1)." Chattanooga, Tennessee.

17 Accession No. ML18003A374. TN5387.

18 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 19 Application, Part 03Environmental Report (Revision 1)." Chattanooga, Tennessee.

20 Accession No. ML18003A471. TN4921.

I-1

1 Table I.1. Clinch River Nuclear Environmental Site Characteristics Parameter PPE Section(a) Definition Type PPE Value ER Section

9. Unit Vent/Airborne Effluent Release Point 9.1 Atmospheric Dispersion (X/Q) (Accident) 9.1.1 0-2 hr @ EAB The atmospheric dispersion coefficients used in the design Site 5.58E-04 s/m3 7.1 safety analysis to estimate dose consequences of accident airborne releases in the limiting two hour interval.

9.1.2 0-8 hr @ low population The atmospheric dispersion coefficients used in the design Site 4.27E-05s/m3 7.1 zone (LPZ) safety analysis to estimate dose consequences of accident airborne releases in the first eight hours.

9.1.3 8-24 hr @ LPZ The atmospheric dispersion coefficients used in the design Site 3.80E-05 s/m3 7.1 safety analysis to estimate dose consequences of accident airborne releases between hours 8 and 24 after the accident.

9.1.4 1-4 day @ LPZ The atmospheric dispersion coefficients used in the design Site 2.94E-05 s/m3 7.1 safety analysis to estimate dose consequences of accident airborne releases between the first day and the fourth day I-2 after the accident 9.1.5 4-30 day @ LPZ The atmospheric dispersion coefficients used in the design Site 2.04E-05 s/m3 7.1 safety analysis to estimate dose consequences of accident airborne releases between day four until the end of the first 30 days after the accident.

9.3 Calculated Dose Consequences 9.3.1 Normal The design radiological dose consequences due to airborne Site 10 CFR 20, 10 CFR 50 5.42, 7.22 releases from normal operation of the plant. Appendix I 9.3.2 Post-Accident The design radiological dose consequences due to airborne Site 10 CFR 52.17 (a)(1) (ix), 5.42, 7.22 releases from postulated accidents. 10 CFR 100.20 (a) The numbering of the PPE listing is not meant to be sequential, and was compiled from and is consistent with the list developed by industry and refined for this early site permit application.

2 3

1 Table I.2. Clinch River Nuclear Site-Related Design Parameters Parameter PPE Section(a) Definition Type PPE Value ER Section

1. Structure 1.1 Building Characteristics 1.1.1 Height (w/o Stack and The height from finished grade to the top of the tallest power Rx 160 ft 2.5.2, 3.1, 4.4, 5.8 Cooling Towers) block structure, excluding cooling towers (excludes stairway towers, elevator, etc.).

1.1.2 Foundation Embedment The depth from finished grade to the bottom of the basemat Rx 138 ft 3.1 or the most deeply embedded power block structure (excavation depth is the same elevation as embedment depth).

3. Normal Plant Heat Sink 3.1 Condenser 3.1.2 Condenser/Heat Design value for the waste heat rejected to the circulating Eng 5593 MBTU/hr for site 3.4 Exchanger Duty water system across the condensers.

3.2 Non-Safety Related Service Water Systems I-3 3.2.3 Miscellaneous Plant The maximum, and normal, water intake of the plant Eng Maximum: 5,100 gpm; 3.4 Water Uses Intake neglecting cooling-tower makeup, potable/sanitary water normal: 1,345 gpm users, and liquid radwaste treatment. See Figure 3.3-1 3.2.4 Miscellaneous Plant The maximum, and normal, water discharge of the plant Eng Maximum: 4,200 gpm; 3.4 Water Uses Discharge neglecting cooling-tower makeup, potable/sanitary water normal: 445 gpm users, and liquid radwaste treatment. See Figure 3.3-1 3.3 Mechanical Draft Cooling Towers 3.3.1 Acreage The land required for cooling towers, including support Eng See Figure 3.1-1 3.4, 5.3 facilities such as equipment sheds, basins, canals, or shoreline buffer areas.

3.3.3 Blowdown Constituents The maximum expected concentrations for anticipated Eng Table 3.6-1 (values for site) 3.6 and Concentrations constituents in the cooling-water systems blowdown to the receiving waterbody.

3.3.4 Blowdown Flow Rate The normal (and maximum) flow rate of the blowdown Eng Maximum: (2 COC) 12,800 3.4 stream from the cooling-water systems to the receiving gpm, waterbody for closed system designs. Expected: (4 COC) 4270 gpm See Figure 3.3-1 2

Table I.2. (contd)

Parameter PPE Section(a) Definition Type PPE Value ER Section 3.3.5 Blowdown The maximum expected blowdown temperature at the point of Eng 90 F 3.4 Temperature discharge to the receiving waterbody.

3.3.6 Cycles of The ratio of total dissolved solids in the cooling-water blowdown Eng Maximum: 4; minimum: 2 3.4, 5.3 Concentration streams to the total dissolved solids in the makeup water streams.

3.3.7 Evaporation Rate The expected (and maximum) rate at which water is lost by Eng 12,800 gpm (expected and maximum) 3.4 evaporation from the cooling-water systems. - values for site 3.3.8 Height The vertical height above finished grade of mechanical draft Eng 65 ft 3.4, 5.3, 5.8 cooling towers associated with the cooling-water systems.

3.3.9 Makeup Flow Rate The expected (and maximum) rate of removal of water from a Eng 3.4 17,078 gpm (expected), 25,608 gpm natural source to replace water losses from closed cooling-water (maximum) system.

3.3.10 Noise The maximum expected sound level produced by operation of Eng <70 dba 5.3, 5.8, 9.3 cooling towers, measured at 1,000 ft from the noise source.

3.3.11 Cooling Tower The temperature difference between the cooling water entering Eng 18 F 3.4 Temperature Range and leaving the towers.

I-4 3.3.12 Cooling Water Flow The total cooling-water flow rate through the condenser/heat Eng 755,000 gpm 3.4, 5.3 Rate exchangers.

3.3.14 Maximum Eng 12,808 gal 3.4 The expected maximum short-term consumptive use of water by Consumption of Raw the cooling-water systems (evaporation and drift losses).

Water 3.3.16 Stored Water The quantity of water stored in cooling-water system Eng 5 million gal 3.4 Volume impoundments, basins, tanks and/or ponds.

3.3.17 Drift Rate of water lost from the tower as liquid droplets entrained in Eng 8 gpm 3.4 the vapor exhaust air stream.

5. Potable Water/Sanitary Waste System 5.1 Discharge to Site Water Bodies 5.1.1 Flow Rate The expected (normal) effluent flow rate from the Rx 50 gpm 3.4, 3.6, 5.5 (Potable/Sanitary Normal) potable/sanitary system to the receiving waterbody.

5.1.2 Flow Rate Rx 100 gpm 3.4, 3.6, 5.5 The maximum effluent flow rate from the potable/sanitary the (Potable/Sanitary receiving waterbody.

Maximum) 9.5 Source Term 9.5.1 Gaseous (Normal) The expected annual activity, by radionuclide, contained in Rx Table 3.5-3 3.5 routine plant airborne effluent streams, excluding tritium.

Table I.2. (contd)

Parameter PPE Section(a) Definition Type PPE Value ER Section

10. Liquid Radwaste System 10.2 Release Point 10.2.1 Flow Rate The discharge (including minimum dilution flow, if any) flow rate Eng 900 gpm - expected normal and 3.4 of liquid potentially radioactive effluent streams from plant maximum -

systems to the receiving waterbody.

10.3 Source Term 10.3.1 Liquid The annual activity, by radionuclide, contained in routine plant Rx Table 3.5-1 ([value per site) 3.5 liquid effluent streams, excluding tritium.

11. Solid Radwaste System 11.2 Solid Radwaste 11.2.1 Activity The annual activity, by radionuclide, contained in solid Rx Table 3.5-5 (site value) 3.5 radioactive wastes generated during routine plant operations.

11.2.3 Volume The expected volume of solid radioactive wastes generated Rx 5,000 cubic ft/yr (site value) 3.5, 3.8, 5.7, during routine plant operations. 7.4 I-5 13. Auxiliary Boiler System 13.1 Exhaust Elevation The height above finished plant grade at which the flue gas Eng Plant Grade 3.6 effluents are released to the environment.

13.2 Flue Gas Effluents The expected combustion products and anticipated quantities Eng Table 3.6-2 3.6 released to the environment due to operation of the auxiliary boilers.

14. Standby Power System 14.1 Diesel 14.1.2 Diesel Exhaust The elevation above finished grade of the release point for Eng 25 ft 3.6 Elevation standby diesel exhaust releases.

14.1.3 Diesel Flue Gas The expected combustion products and anticipated quantities Eng Table 3.6-3 (value per site) 3.6 Effluents released to the environment due to operation of the emergency standby diesel generators.

14.2 Gas Turbine 14.2.2 Gas-Turbine The elevation above finished grade of the release point for Eng 50 ft 3.6 Exhaust Elevation standby gas turbine exhaust releases.

14.2.3 Gas-Turbine Flue The expected combustion products and anticipated quantities Eng Table 3.6-4 3.6 Gas Effluents released to the environment due to operation of the emergency standby gas-turbine generators.

Table I.2. (contd)

Parameter PPE Section(a) Definition Type PPE Value ER Section

15. Plant Layout Considerations 15.1 Access Routes 15.1.1 Heavy Haul Routes The land usage required for permanent heavy-haul routes to Eng 5 ac 3.9 support normal operations and refueling.

15.2 Acreage to Support The land area required to provide space for plant facilities. Eng See Figure 3.1-1 3.7 Plant Operations

16. Plant Operations Considerations 16.1 Megawatts Thermal The thermal power generated by one unit (may be the total of Rx 800 MW(t) (core) 805 MW(t) (core + 5.7, 7.4 several modules). Specify both core thermal power and reactor RCP), 2,420 MW(t) total for site coolant pump (RCP) thermal power (if there are RCPs in the design).

16.2 Plant Design Life The operational life for which the plant is designed. Rx 60 years 3.2 16.3 Plant Population 16.3.1 Operation The estimated number of total permanent staff to support Eng 500 (value per site) 3.10,5.8, 9.3 operations of the plant.

I-6 16.3.2 Refueling/Major The estimated additional number of temporary staff required to Eng 1,000 5.8, 9.3 Maintenance conduct refueling and major maintenance activities.

16.4 Station Capacity The percentage of time that a plant is capable of providing Eng 5.7, 7.4 Maximum: 98%; minimum: 90%

Factor power to the grid.

16.6 Megawatts Electrical Best estimate of MW(e) generator output. Eng 800 MW(e) (value for site) 3.2, 5.7, 5.9, (at 100% power with 85ºF 7.4, 9.4, circulating water) 10.1

17. Construction 17.2 Acreage 17.2.1 Laydown Areas The land area required to provide space for construction support Eng See Figure 3.1-1 3.7 facilities. Provide a list of what buildings and/or areas and the associated acreage for each.

17.3 Construction 17.3.1 Noise The maximum expected sound level due to construction Eng 101 dB at 50 ft 3.9 activities, measured at 50 ft from the noise source.

17.4 Plant Population 17.4.1 Construction Maximum number of people onsite during construction. Eng 2,200 (value per site) 3.10

18. Miscellaneous Items

Table I.2. (contd)

Parameter PPE Section(a) Definition Type PPE Value ER Section 18.0.1 Fuel Characteristics What is the form of the reactor fuel and the burnup (GWd/MTU)? Rx UO2, 51 GWD/MTU 5.7, 7.4 18.0.2 Fuel assemblies Provide the active length of the reactor fuel. Provide the number Rx Number of fuel assemblies: 96 weight 3.8, 5.7, 7.4 of fuel assemblies per core and the weight (in MTU) of each of each assembly: 0.304 MTU assembly.

18.0.4 Refueling Provide the refueling frequency, average number of assemblies Rx Frequency: 2 years, assemblies per 3.8, 5.7, 5.8 per refueling, fuel pool capacity (in years), and cooling time in refueling: 96, capacity: 6 years ,

pool.

18.0.5 Irradiation fuel Provide the weight of irradiated fuel per spent fuel shipping cask Rx 21.2 MTU 5.7 transportation (MTU).

18.1 Maximum Fuel Concentration (weight percent fraction) of U-235 in the fuel Rx <5% U-235 3.2, 5.7, 7.4 Enrichment uranium.

18.2 Maximum Average Maximum assembly average burnup at end of assembly life. Rx 51 GWD/MTU 3.2, 5.7, 7.4 Assembly Burnup 18.3 Peak fuel rod Peak fuel rod exposure at end of life. Rx 62 GWD/MTU 3.2 exposure at end of life I-7 18.7 Clad Material Fuel rod clad material. Rx Zirc Alloy (Zircaloy) 5.7 (a) The numbering of the PPE listing is not meant to be sequential, and was compiled from and is consistent with the list developed by industry and refined for this early site permit application.

Notes: RX = Reactor Parameter; Eng = Owner Engineered Parameter; COC = Cycles of Concentration.

1 2

1 Table I.3. Safety Site Characteristics SSAR Characteristic/Parameter Site-Specific Value(a) Description Section Geography and Demography Exclusion Area Boundary (EAB) Clinch River Property The area surrounding the reactors, in which the reactor licensee has the 2.1.1 Boundary authority to determine all activities, including exclusion or removal of personnel and property from the area.

Low Population Zone 1 mi from CRN Site center The area immediately surrounding the exclusion area, which contains 2.1.3.4 point residents, the total number and density of which are such that there is a reasonable probability that appropriate protective measures could be taken on their behalf in the event of a serious accident.

Population Center Distance 4.8 mi (southeast) The distance from the site center point to the nearest boundary of a densely 2.1.3.5 populated center containing more than about 25,000 residents.

Meteorology and Hydrology Winter Precipitation 100-yr Snowpack 12.2 psf The weight of the 100-year return period snowpack (to be used in 2.3.1.3.6.2 determining normal precipitations loads for roofs).

48-hour Probable Maximum Winter 23.5 in. Probable Maximum Precipitation (PMP) during the winter months (to be used 2.3.1.3.6.2 I-8 Precipitation (PWMP) in conjunction with the 100-year snowpack in determining normal precipitation loads for roofs).

Normal Winter Precipitation 21.9 psf The maximum of the 1) 100-year return snowpack (snow cover), 2) historical 2.3.1.3.6.2 Event snowpack (snow cover), 3) 100-year return snowfall event, or 4) historical maximum snowfall event.

Extreme Frozen Precipitation Event 21.9 psf The maximum of the 1) 100-year return snowfall event or 2) historical 2.3.1.3.6.2 maximum snowfall event.

Extreme Liquid Winter Precipitation Equivalent to the 48-hour The extreme winter precipitation event is defined as the theoretically greatest 2.3.1.3.6.2 Event PWMP depth of precipitation (inches of water) for a 48-hour period that is physically possible over a 25.9 square kilometer (10 square mile) area at a particular geographical location during those months with the historically highest snowpacks.

Potential for Frazil Ice in Ultimate N/A Potential for accumulated ice formation in the UHS Water Storage Facility in 2.4.7 Heat Sink (UHS) Water Storage a turbulent flow condition.

Facility Maximum Rainfall Rate 18.8 in./hr PMP for 1-hour and for 5-minute durations at the site estimated from Hydro- 2.3.1.3.3 6 in./5-minutes Meteorological Report HMR-52.

2

Table I.3. (contd)

SSAR Characteristic/Parameter Site-Specific Value(a) Description Section Maximum Flood (or Tsunami) 799.9 ft NGVD29 (799.5 ft Predicted maximum flood level (including wave run-up) from external events, 2.4.2, 2.4.3, NAVD88) not including local PMP. and 2.4.10

-Still water 6.1 ft (wind-wave) 806.0 ft NGVD29 (805.6 ft NAVD88)

-Combined Maximum Ground Water 816.1 ft NAVD88 Maximum groundwater level under deep foundation structures in power-block 2.4.12 area.

Basic Wind Speed 96.3 mph for a 3-second Wind velocity at 33 ft above ground for Exposure Category C associated with 2.3.1.3.2 gust a 100-year return period in the site area.

Historical Maximum Wind Speed 87 mph for a 3-second gust Wind velocity at 33 ft above ground associated with the most severe 2.3.1.3.2 73 mph fastest mile hurricane wind that has been historically observed in the site region.

Design-Basis Hurricane Windspeed 130 mph for a 3-second gust The resulting windspeed for nominal 3-second peak-gust values at a height 2.3.1.3.5 of 33 ft in flat open terrain.

Tornado I-9 Maximum Pressure Drop 1.2 psi Decrease in ambient pressure from normal atmospheric pressure at the site 2.3.1.3.4 due to passage of a tornado having a probability of occurrence of 10-7 per year.

Maximum Rotational Speed 184 mph Rotation component of maximum wind speed at the site due to passage of a 2.3.1.3.4 tornado having a probability of occurrence of 10-7 per year.

Maximum Translational 46 mph Translation component of maximum wind speed at the site due to the 2.3.1.3.4 Speed movement across the ground of a tornado having a probability of occurrence of 10-7 per year.

Maximum Wind Speed 230 mph Sum of the maximum rotational and translational wind speed components at 2.3.1.3.4 the site due to passage of a tornado having a probability of occurrence of 10-7 per year.

Radius of Maximum Rotational 150 ft Distance from the center of the tornado at which the maximum rotational wind 2.3.1.3.4 Speed speed occurs at site due to passage of a tornado having a probability of occurrence of 10-7 per year.

Rate of Pressure Drop 0.5 psi/s Maximum rate of pressure drop at site due to passage of a tornado having a 2.3.1.3.4 probability of occurrence of 10-7 per year.

Table I.3. (contd)

SSAR Characteristic/Parameter Site-Specific Value(a) Description Section Site Characteristic Ambient Air Temperatures Site characteristic wet bulb and dry bulb temperatures associated with the 2.3.1.4 listed exceedance values and the 100-year return period.

Maximum Dry Bulb Temperature with Maximum Wet Bulb Temperature 2% Annual Exceedance 90°F Dry Bulb 73.7°F Coincident Wet Bulb 1% Annual Exceedance 92°F Dry Bulb 74.2°F Coincident Wet Bulb 0.4% Annual Exceedance 95°F Dry Bulb 74.9°F Coincident Wet Bulb 0% Annual Exceedance 105°F Dry Bulb 74.6°F Coincident Wet Bulb 100-Year Return Period 107°F Dry Bulb 73.1°F Coincident Wet Bulb I-10 Maximum Non-Coincident Wet Bulb Temperature 2% Annual Exceedance 75.7°F 1% Annual Exceedance 76.7°F 0.4% Annual Exceedance 77.6°F 0% Annual Exceedance 81.7°F 100-Year Return Period 83.6°F Minimum Dry Bulb Temperature 2% Annual Exceedance 25°F 1% Annual Exceedance 21°F 0.4% Annual Exceedance 16°F 0% Annual Exceedance -9°F 100-Year Return Period -9.9°F

Table I.3. (contd)

SSAR Characteristic/Parameter Site-Specific Value(a) Description Section Atmospheric Dispersion (X/Q) Atmospheric dispersion coefficients used in the design safety analyses to 2.3.4 (Accident) estimate dose consequences of accident airborne releases.

0-2 hr @ EAB 4.96 x 10-3 s/m3 0-8 hr @ LPZ 3.10 x 10-4 s/m3 8-24 hr @ LPZ 2.26 x 10-4 s/m3 1-4 day @ LPZ 1.14 x 10-4 s/m3 4-30 day @ LPZ 4.30 x 10-5 s/m3 Atmospheric Dispersion (X/Q) Refer to Table 2.3.5-10 Atmospheric dispersion coefficient used in the safety analysis for the dose 2.3.5 (Annual Average) consequences of normal airborne releases.

Gaseous Releases Does Consequences Normal 10 CFR Part 20, App. B Estimated design radiological dose consequences due to gaseous releases 11.3.3 10 CFR Part 50, App. I from normal operation of the plant.

Post-Accident 10 CFR 52.17(a)(1)(ix) Estimated design radiological dose consequences due to gaseous releases 15 from postulated accidents.

I-11 Minimum Distance from Release 1,100 ft Minimum lateral distance from the effluent release boundary to the EAB. 2.1.1.2 and Point to EAB 2.3.4 Liquid Releases Dose Consequences Normal 10 CFR Part 20, App. B Estimated design radiological dose consequences due to liquid effluent 11.2.3 10 CFR Part 50, App. I releases from normal operation of the plant.

Post-Accident 10 CFR Part 20, App. B Estimated design radiological dose consequences due to liquid effluent 2.4.13 DC/COL-ISG-013 releases from postulated accidents.

Geology, Seismology, and Geotechnical Engineering Ground Motion Response Spectra Figure 2.5.2-78 The design response spectra used to establish a plants seismic design. 2.5.2 Capable Tectonic Structures or None The assumption made in a plant design about the presence of capable faults 2.5.3 Sources or earthquake sources in the vicinity of the plant site (e.g., no fault displacement potential within the investigative area).

Soil Properties Liquefaction None Liquefaction potential at the site. 2.5.4 Minimum Bearing Capacity 110 ksf Allowable load-bearing capacity of layer supporting plant structures. 2.5.4 (Static)

Table I.3. (contd)

SSAR Characteristic/Parameter Site-Specific Value(a) Description Section Minimum Shear Wave 4,650 fps Propagation velocity of shear waves through foundation materials. 2.5.4 Velocity Dynamic Bearing Capacity 110 ksf Capacity of the foundation soil/rock to resist loads imposed by the structures 2.5.4 in the event of an earthquake.

Minimum Soil Angle of 36° Minimum value of the internal friction angle of foundation soils, fill soils, or 2.5.4 Internal Friction excavation slopes that would provide a safe design of the plant through soil structure interaction analyses including sliding along the base.

(a) Values shown are for a single unit, but would be the same value for each additional unit.

1 I-12

1 APPENDIX J 2 REPRESENTATIONS AND ASSUMPTIONS 3 If an early site permit (ESP) for the Tennessee Valley Authoritys (TVAs) Clinch River Nuclear 4 (CRN) Site is issued and an applicant references that ESP in a subsequent application for a 5 construction permit (CP) or a combined construction permit and operating license (combined 6 license or COL), the applicant would have to demonstrate that the design selected for the site 7 falls within the bounds of the U.S. Nuclear Regulatory Commissions (NRCs) ESP analysis in 8 this environmental impact statement (EIS). With regard to the environmental impacts 9 associated with construction and operation of a new nuclear power plant at the CRN Site, TVA 10 made a number of representations in its application. As listed in this appendix, the staff used 11 these representations and staff-developed assumptions when assessing the environmental 12 impacts associated with construction and operation of a new nuclear power plant. As such, 13 fulfillment of these representations and assumptions provides part of the basis for the final EIS.

14 If a CP or COL applicant references the ESP, and the NRC staff ultimately determines that a 15 representation or assumption has not been satisfied at the CP/COL stage, that information 16 would be considered new and potentially significant, and the affected impact area could be 17 subject to re-examination.

18 Table J-1 references TVAs representations and the NRC staffs assumptions in this EIS about 19 plant design (Appendix I); authorizations, permits, and certifications (Appendix H); and 20 mitigation (Sections 4.11 and 5.12). Table J-2 contains references to representations and 21 assumptions organized by technical area, without repeating the information in Table J-1.

22 Within the Environmental Report (ER) (TVA 2017-TN4921), TVA provides:

23 representations to address certain issues in the design, construction, and operation of the 24 facility; 25 representations of planned compliance with current laws, regulations, and requirements; 26 representations of future activities and actions that it would take if it receives an ESP and 27 decides to apply for a COL for the Clinch River Site; and 28 representations of TVAs estimates of future activities and actions of others and the likely 29 environmental impacts of those activities and actions that would be expected if TVA decides 30 to apply for a CP or COL.

31 The following tables are meant to aid the staff and the applicant in the event this EIS is 32 referenced in a CP or COL application. The tables are not meant to replace the analyses in the 33 EIS.

34 J-1

1 Table J-1. Appendix I, Appendix H, Section 4.11, and Section 5.12 Assumptions and Commitments Area Representation/Assumption Site characteristics An applicant referencing this EIS will demonstrate its application is bounded by the site characteristics contained in Tables I-1 and I-3.

Plant parameter envelope (PPE) values An applicant referencing this EIS will demonstrate its application is bounded by the PPE values contained and referenced in Table I-2.

Authorizations and permits An applicant referencing this EIS will provide the status of the authorizations and permits specified in Appendix H.

Mitigation of construction impacts An applicant referencing this EIS will address whether its application contains the mitigation measures contained in Section 4.11.

Mitigation of operational impacts An applicant referencing this EIS will address whether its application contains the mitigation measures contained in Section 5.12.

New and significant information An applicant referencing this EIS will provide, in its application, in accordance with Title 10 of the Code of Federal Regulations (CFR) 51.50(c)(1) (TN250), any new information that could affect the technical basis or conclusions for determination of an impact level in the EIS.

J-2

1 Table J-2. Assumptions by Technical Area Not Covered in Table J-1 Technical Area Representations/Assumptions Source Land Use The CRN Site construction footprint is shown in Figure 3.1-2 in the ER. ER Figure 3.1-2(a)

The CRN Site would total 935 ac. The barge/traffic area (BTA) would total 203 ac. ER Table 2.2-1(a)

An estimated 494 ac of the existing 935-ac CRN Site would be affected by the construction of a ER Figure 3.1-2(a) new nuclear power plant.

Permanent facilities and structures (primarily the power-block area, cooling-tower area, and intake ER Table 4.1-1(a) structures and their associated pipelines) for new small modular reactor (SMR) units would occupy approximately 327 ac and temporary facilities would occupy approximately 167 ac.

In the BTA, 30 ac would be permanently disturbed with new roadways and barge-landing ER Table 4.1-1(a) improvements and 15 ac would be temporarily disturbed for the installation of the new roadways.

Building activities, including barge slip reconditioning activities, would not require dredging. ER Section 4.1.1(a)

No prime farmland impacts exceeding U.S. Department of Agriculture thresholds would result from ER Section 4.1.1 (a)

J-3 the proposed. project Heritage Rail Offload Area would be refurbished and stabilized for deliveries. The U.S. ER Section 4.1.1 (a)

Department of Energy (DOE) former K-25 Barge-Loading Area between State Route (SR) 58 and the CRN Site entrance would also be refurbished for deliveries. Alternatively, a new barge slip may be constructed.

Salt drift from any cooling-tower design would be localized with some areas of drift during summer ER Section 5.3.3.3.1(a) exceeding NRC guidance thresholds (EIS Figure 5-2). Exceedance areas would be located in early successional habitat within the CRBRP footprint that mostly would be occupied by facilities and to a lesser extent in forested habitat that would be cleared during preconstruction. No fogging or icing impacts are expected on transportation areas around the CRN Site.

A new switchyard would be constructed for use with new SMR units at the CRN Site. ER Section 3.7.1(a)

The extent of land required for borrow pits would not exceed designated capacities. ER Section 4.1.1(a);

Table J-2. (contd)

Technical Area Representations/Assumptions Source Potential areas for the temporary storage of earthwork and excavation spoils have been identified on ER Section 4.1.1 and the site. The total amount of spoils and the extent of land required have not been determined but are Figure 4.3-1 (a) assumed to not extend beyond the construction footprint identified in Figure 4.3-1 in the ER. The excavated material would be managed with the appropriate erosion and sediment control measures, and best management practices (BMPs) would be used as necessary for these storage areas.

A minor intrusion to the Clinch River 100-year floodplain would be disturbed by clearing and grading CNL-17-097 (TVA 2017-activities necessary to building the proposed intake and blowdown structures, and installing the TN4922), Attachment 7 makeup and blowdown lines. Most impacts would be temporary, except for building and operating the CRN plant intake and discharge structures.

The hypothesized offsite transmission lines with assumed modifications to affected rights-of-way are ER Figure 3.7-7(a) based on injecting 800 MW(e) to the grid at the CRN Site.

Hypothesized offsite transmission corridor impacts included a 12.7-mi segment where lines will be ER Section 3.7(a) rebuilt, including potential excavation work. These impacts would be confined to established right-of-J-4 ways.

Hypothesized transmission line upgrades would affect currently unspecified areas within existing right- TVA 2017-TN4922; of-ways of a total of 439 mi or 5,327 ac of offsite transmission line corridors. ER Figure 3.7-7(a)

Water Use and Quality Stormwater runoff from the CRN Site would be controlled via engineered structures, collected in ER Section 4.2(a) engineered retention ponds, and infiltrated to the ground, or released to the Clinch River in a controlled manner according to the terms of the National Pollutant Discharge Elimination System (NPDES) permit. This permit would be obtained prior to any building activities at the site.

No dredging during building would occur. ER Section 4.2(a)

Underwater excavation for construction of the intake and discharge structures would use BMPs to limit ER Section 4.2(a) disturbance of sediments according to applicable regulations, including procedures of the Watts Bar Interagency Agreement Working Group.

Underwater excavation material would be sampled and characterized for contamination, and disposed ER Section 4.2(a) of according to applicable regulations.

Engineering control measures (e.g., grouting of fractures) would be used during construction to limit ER Section 4.2(a) the rate of excavation dewatering required.

Table J-2. (contd)

Technical Area Representations/Assumptions Source Excavation dewatering required would be similar to the Clinch River Breeder Reactor Project ER Section 4.2(a)

(CRBRP) experience: the rate would be low. Monitoring would be carried out to evaluate the effect of dewatering on the surrounding groundwater and any nearby surface waterbodies, including wetlands.

Dewatering flows would be routed to one of the stormwater retention ponds. ER Section 4.2(a)

Construction of a Melton Hill Dam bypass capable of providing 400 cfs of continuous discharge from ER Section 4.2(a) the dam would be constructed prior to operations at the site. Construction of the bypass would be conducted with appropriate engineering controls to avoid water-quality impacts.

Installation of the underground 69-kV transmission line would be conducted with minor localized and EIS Section 4.2 temporary effects on streams traversed.

Construction water would be obtained from the City of Oak Ridge and would not exceed 231,660 gpd. ER Section 4.2(a)

Any upgrades to existing infrastructure would conform to applicable local, State, and Federal permits.

Surface water would be obtained directly from the Clinch River for dust suppression and other building ER Section 4.2(a)

J-5 purposes and would not exceed 5,000 gpd.

No groundwater would be used during construction. ER Section 4.2(a)

Potable and sanitary water services during operations would be obtained from the City of Oak Ridge. ER Section 5.2(a)

Makeup water for a new plants circulating-water system would be obtained from the Clinch River arm ER Section 5.2(a) of the Watts Bar Reservoir.

TVA would continue to follow current reservoir operating policy so that average and drought flows in EIS Section 5.2 the Clinch River arm of the Watts Bar Reservoir during operations would be similar to those during the period 2004-2013.

Net water demand in the Clinch River basin, including consumptive water use of a plant at the ER Section 5.2(a)

CRN Site would not exceed the demand projections used in the development of the current reservoir operations policy.

No groundwater would be used during operations. ER Section 5.2(a)

No dredging during operation would occur. ER Section 5.2(a)

The Melton Hill Dam bypass would operate continuously during plant operations. ER Section 5.2(a)

Plant discharge would be in compliance with terms and conditions of the NPDES permit. ER Section 5.2(a)

Table J-2. (contd)

Technical Area Representations/Assumptions Source CRBRP wells were either destroyed or removed and would not provide pathways of preferential EIS Section 5.2 transport of contaminants to groundwater.

Design and construction of the holding pond would preclude groundwater contamination during site EIS Section 5.2 operations.

Terrestrial Ecology - Clinch River Site, Barge/Traffic Area, 69-kV Buried Transmission Line The CRN Site would total 935 ac. The BTA would total 203 ac. ER Table 2.2-1(a)

An estimated 494 ac of the existing 935-ac CRN Site and an estimated 45 ac of the existing ER Figures 3.1-2 and 203-ac BTA would be affected by the construction of two or more SMRs. 4.3.1(a)

The CRN Site and BTA construction footprint would generally be as shown in Figure 4.3.1 in the ER ER Figure 4.3.1(a)

Permanent disturbance would occur on approximately 327 ac, and temporary disturbance would occur ER Table 4.3-1(a) on approximately 167 ac on the CRN Site.

J-6 Permanent disturbance would occur on approximately 30 ac, and temporary disturbance would occur ER Table 4.1-1(a);

on approximately 15 ac on the BTA. Section 4.3.1.1 Disturbance for the buried 69-kV transmission line, extending from the CRN Site to the Bethel Valley ER Section 4.3.1.1(a)

Substation would occur only within the corridor of an existing 500-kV transmission line.

Disturbance of wetland habitat would total an estimated 1.8 ac on the CRN Site and BTA. ER Section 4.3.1.2(a)

Mechanical draft cooling towers approximately 65 ft in height or less would be used to cool the SMRs. ER Table 3.1-2 The design would call for use of mechanical draft cooling towers with input parameters to the ER Section 5.3.3.2 and Seasonal and Annual Cooling Tower Impact (SACTI) prediction code modeling (EPRI 2015-TN4864) Table 5.3-5(a) expected to generally result in salt drift equivalent to or lower than that predicted by the modeling discussed in Section 5.3.1.

TVA would propose use only of those borrow pits (without expansion) that were presented in the ESP ER Section 2.2.3, 2.9, application. 4.1.1(a)

TVA would comply with all required wetland mitigation measures determined for jurisdictional wetlands that could be affected by the building and operating at the CRN Site.

TVA would follow the State of Tennessee BMPs and TVA BMPs and when working in wetlands.

Table J-2. (contd)

Technical Area Representations/Assumptions Source Temporarily affected areas would be revegetated or otherwise restored after construction using native ER Section 4.3.1(a) or noninvasive plant species.

The potential impacts on Federally listed threatened and endangered terrestrial species and designated critical habitats would be documented in the Biological Assessment in Appendix M.

TVA would support NRC as necessary to comply with terms or conditions of any Biological Opinion and Incidental Take Statement issued by the U.S. Fish and Wildlife Service (FWS) as part of the ESP licensing review.

Any offsite transmission line upgrades proposed by TVA would be limited to the existing rights-of-way ER Figure 3.7-7(a) ;

of the transmission lines presented in the ESP application. TVA 2016-TN5145)

Any ground disturbance from the offsite transmission line upgrades would not encroach into land ER Section 4.3.1.6; outside of the existing right-of-ways. TVA 2016-TN5145 TVA would prevent or minimize to the extent practicable impacts to forests, wetlands, or sensitive ER Section 4.3.1.6; biota due to ground disturbance resulting from the offsite transmission line upgrades by using TVA 2016-TN5145 J-7 established BMPs.

Aquatic Ecology Onsite and offsite descriptions of aquatic resources for the CRN Site, consistent with NUREG-1555 EIS Sections 2.4.2.1 and (NRC 2000-TN614), would be as provided in Sections 2.4.2.1 and 2.4.2.2, respectively. 2.4.2.2 Important aquatic species are would be as discussed in Section 2.4.2.3 of the EIS. EIS Section 2.4.2.3 The potential impacts on Federally listed threatened and endangered aquatic species and designated EIS Appendix M critical habitats would be documented in the Biological Assessment in Appendix M and would comply with terms or conditions of any Biological Opinion and Incidental Take Statement issued by the FWS as part of the ESP licensing review.

Table J-2. (contd)

Technical Area Representations/Assumptions Source Building activities that could directly affect onsite and offsite aquatic ecosystems would include site EIS Section 4.3.2 preparation for installation of plant structures and the barge slip in the barge transport area; installing the cooling-water system intake and discharge structures; and burying a 69-kV underground transmission line in the existing 500-kV transmission line corridor where it crosses streams or creeks.

This includes the use of BMPs including silt-curtains and cofferdams as appropriate. Shoreline installation and site preparation activities would require a stormwater pollution prevention plan, developed as part of the Tennessee Department of Environment and Conservation (TDEC) stormwater permit, which would describe BMPs to control sedimentation and erosion and provide stormwater management. In-water building activities (e.g., pile driving, excavation) would comply with the terms and conditions (e.g., dredging methodology, seasonal restrictions, and dredged material disposal requirements) included in the Department of the Army permit issued by the U.S. Army Corps of Engineers (USACE) and the TDEC NPDES permit.

TVA would comply with all required mitigation measures determined for jurisdictional streams that could be affected by building and operating at the CRN Site.

J-8 The location, design, construction, and capacity of the cooling-water intake structure would reflect the EIS Section 5.3.2.1 best technology available for minimizing environmental impacts and would be compliant with U.S.

environmental protection Agency 316(b) Phase I requirements (40 CFR Part 125-TN254).

Any ground disturbance from the transmission line upgrades would not encroach into streams or other EIS Section 5.3.2.1 and aquatic habitats and would not affect any known locations of protected or sensitive biota. 5.3.2.2 The Melton Hill Dam bypass would be installed and functioning before the plant operations are started. EIS 5.3.2.1 Socioeconomics Construction materials would be shipped to the CRN Site and construction debris and associated ER Section 4.1.1(a) waste not placed in the onsite disposal pit would be removed from the site via road, rail, and/or barge.

A portion of Bear Creek Road and access to the Rail Offload Area would be modified to handle heavy-haul traffic. The CRN Site Access Road would also be modified to handle heavy-haul traffic into the CRN Site. River Road would be improved to handle regular patrol traffic.

Definition of the affected demographic and economic regions would be those suggested in the ER. EIS Section 2.5.1 The review team relied upon American Community Survey 2011-2015 5-year data for most demographic statistics and for the analyses of potential impacts. Populations projections would be based on information from the State of Tennessee.

Table J-2. (contd)

Technical Area Representations/Assumptions Source Site preparation and construction activities would continue for approximately 6 years and would ER Sections 3.10.1.2 employ as many as 3,300 construction workers. TVA would employ up to 500 operations and 1,000 and 3.10.3(a) outage workers.

The in-migrating building and operations workforce would be distributed geographically in a manner ER Sections 4.4.2.2 and similar to the existing Oak Ridge Reservation workforce. 5.4.2(a); EIS Sections 4.4.2 and 5.4.2 Traffic impacts would be based on the AECOM Technical Services Inc. traffic impact analysis ER Section 4.4.2.3(a)

(AECOM 2015-TN5000).

The household size for in-migrating workers is would be 2.53 persons EIS Sections 4.4.2 and 5.4.2 TVA would construct two or more SMRs with the combined capacity listed in the plant parameter EIS Sections 4.4.3.1 and envelope (PPE) (800 MW(e)). The cost of reactors is would be $5,183--7,256 per kW(e) in 2016 5.4.3.1 dollars. (Used the Bureau of Economic Analysis Regional Input-Output Modeling System II multipliers J-9 for indirect workforce.)

Construction worker annual income would be $42,300 and operations worker income would be EIS Sections 4.4.3.2 and

$65,520. 5.4.3.2 Aesthetic impacts would include 160-ft-tall mechanical draft cooling towers and associated plumes. EIS Sections 4.4.1.6 and 5.4.1.6 Water and wastewater services would be 145 and 75 gpd, respectively. EIS Sections 4.4.4.4 and 5.4.4.4 All construction and operations noise would be sufficiently attenuated by TVAs identified mitigation EIS Section 4.8.2 and and the physical properties (i.e., topography, foliage, etc.) of the area to reduce the overall noise 5.8.2 levels to below the NRC threshold for minor impacts (65 dBA).

Environmental Justice American Community Survey 2011-2015 5-year data were used as the baseline for the analyses of EIS Section 2.6 potential impacts. Minority and low-income populations would continue to exist in the same proportions and locations as populations increase.

Table J-2. (contd)

Technical Area Representations/Assumptions Source Field reconnaissance did not reveal evidence of any special populations or subsistence activities in EIS Section 2.6 close proximity to the CRN Site. Assume these populations cannot be identified for environmental justice analysis.

Historic and Cultural Resources TVA has executed a Programmatic Agreement (PA) in accordance with 36 CFR Part 800 (TN513) that EIS Section 4.6 outlines how TVA would avoid, minimize, or mitigate impacts on historic and cultural resources from preconstruction and construction activities within the onsite and offsite direct- and indirect-effects areas of potential effect (APE). The PA also outlines a process for TVA to amend the APE as project plans are finalized for the COL application. Included in this process are the steps TVA would take to identify, evaluate, and mitigate newly identified significant historic and cultural resources as well as inadvertent discoveries. Notification and consultation with Tennessee Historical Commission (THC) and American Indian Tribes are also stipulated for these steps. TVA has committed to keeping the NRC informed of updates concerning its National Historic Preservation Act (NHPA) Section 106 consultation (TVA 2017-TN4922).

J-10 It is expected that the USACE would be a cooperating agency on the COL EIS. The USACE would EIS Section 4.6 defer its Section 106 NHPA consultation until the COL stage of the application process and would define its permit area at that time.

To avoid and minimize unintentional impacts on historic and cultural resources from operation and EIS Section 4.6 maintenance activities, TVA would follow appropriate Federal historic and cultural resource protection requirements (i.e., NHPA; 54 U.S.C. § 300101 et seq.-TN4157), Archaeological Resources Protection Act (16 U.S.C. § 470aa et seq.-TN1687), Native American Graves Protection and Repatriation Act (25 U.S.C. § 3001 et seq.-TN1686), and Archeological and Historic Preservation Act (54 U.S.C. § 312501 et seq.-TN4844), American Indian Religious Freedom Act (42 U.S.C. § 1996 et seq.-TN5281),

Executive Order (EO) 13007 Indian Sacred Sites (TN5250), and EO 13175 Consultation and Coordination with Indian Tribal Governments (TN4846). These laws also require TVA to notify the THC and American Indian Tribes in the event of inadvertent discovery of human remains or historic and cultural resources. These requirements would also apply to the COL application.

Meteorology and Air Quality Temporary emissions, including fugitive dust and construction equipment engine exhaust, would be ER Section 4.4.1.2(a) minimized with a preconstruction and construction-related mitigation plan. These mitigation measures ER Section 4.6(a) could include any or all of the measures identified in Section 4.4.1.2 of this EIS. ER Section 4.7.5.1.1(a)

Table J-2. (contd)

Technical Area Representations/Assumptions Source Meteorological data for the CRN Site are presented in the Environmental Report (ER). The data from ER Section 2.7(a) 2011 to 2013 are assumed to be representative. ER Section 6.4(a)

Air emissions from the CRN Site would be bounded by those listed in EIS Sections 4.7, 5.7, 6.1.3, 6.3, Various and 7.6. Greenhouse gas emissions would be bounded by those in Appendix K over the life cycle of the facility Auxiliary boilers and diesel generators and/or gas turbines are assumed to be required for a new EIS Section 5.8(a) nuclear power plant, and these devices would release permitted pollutants to the air. The ER describes the annual estimated emissions, and these emissions have been considered in EIS Table 5-14.

The normal heat sink that would be used to dissipate heat from the turbine cycle for a new nuclear ER Section 3.4.1.1(a) power plant would use cooling towers to reject that heat directly into the atmosphere.

Cooling towers would have drift eliminators comparable in effectiveness to the drift eliminators in ER Section 5.3.3.1(a) current-generation cooling towers.

J-11 The maximum salt deposition rate from the two linear mechanical draft cooling towers was estimated ER Section 5.3.3.2.1(a) to be 6,276 kg/km2 per month and would occur at a distance of 100 m west of the towers.

A meteorological monitoring program would be re-established for the operational phase of the project. ER Section 6.4(a)

The monitoring program would be a similar to the meteorological monitoring program for the site preparation monitoring.

Nonradiological Human Health - CRN Site The nearest sensitive receptor (residence) would be approximately 0.36 mi (1,900 ft) from the planned EIS Section 4.8.2 cooling-tower location.

Nighttime construction activities would not exceed 65 dBA at the site boundary. ER Section 4.3.1.4 The peak noise level would be 102 dBA measured from 50 ft from the source during construction. ER Table 3.9-2; ER Peak noise levels during operations would be 70 dBA 1,000 ft from the source, and would be primarily Table 3.1-2 from cooling-tower operation.

All construction and operations noise would be sufficiently attenuated by TVAs identified mitigation EIS Section 4.8.2 and and the physical properties (i.e., topography, foliage, etc.) to levels below the NRC threshold for minor 5.8.2; ER Sections impacts (65 dBA) at the site boundary. 4.3.1.4 and 4.4.1.1

Table J-2. (contd)

Technical Area Representations/Assumptions Source Noise levels associated with blasting activities during construction are infrequent, temporary, and ER Section 3.9.6, EIS limited to daytime hours. Although this noise-producing activity is discussed in the Terrestrial Ecology Section 4.3.1.1.3 sections of this EIS, it is not appropriate for analysis with respect to human health.

Nonradioactive Waste Water and wastewater services would be 100 gpd and 75 gpd, respectively. EIS Sections 4.4.4.4 and 5.4.4.4(a)

Radiological Human Health Radioactive waste management systems would be designed to minimize releases from reactor ER Section 3.5(a) operations to values as low as is reasonably achievable. These systems would be designed and maintained to meet the requirements of 10 CFR Part 20 (TN283) and Appendix I in 10 CFR Part 50 (TN249).

The expected single unit annual activities by isotope contained in the airborne effluent, liquid effluent, ER Sections 3.5.1 to and solid radioactive waste streams generated during routine plant operations are based on the PPE 3.5.5(a)

J-12 approach, where bounding direct radiation and liquid and gaseous radiological effluents were used in the evaluation.

The exposure pathways considered and the analytical methods used to estimate doses to the ER Sections 5.4.1 to maximally exposed individual and to the population surrounding a new nuclear power plant are based 5.4.3(a) on NRC Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I (Rev.1, October 1977 [TN249]) (RG 1.109, NRC 1977-TN90), and NRC Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors (Revision 1, July 1977) (RG 1.111, NRC 1977-TN91).

ER Table 5.4-15 estimates the total body and organ doses to the maximally exposed individual from ER Section 5.4.3(a) liquid effluents and gaseous releases per unit based on the PPE approach for analytical endpoints prescribed in 10 CFR Part 50, Appendix I (TN249).

The estimated annual doses from all pathways for the CRN Site are summarized in ER Table 5.4-16. ER Section 5.4.3(a)

ER Table 5.4-16 compares these doses to the public dose criteria in 40 CFR Part 190 (TN739). TVA states that by demonstrating compliance with the requirements of 40 CFR Part 190 (TN739), it in turn demonstrates compliance with the requirements of 10 CFR 20.1301 (TN283).

Table J-2. (contd)

Technical Area Representations/Assumptions Source Because a specific reactor design has not been selected, the calculated construction worker direct ER Sections 4.5.3.1 and doses are based on data available for the Westinghouse Advanced Passive 1000 (AP1000) 4.5.4.4(a) pressurized water reactor (PWR). Although thought to be bounding, it is possible that these dose rates would increase in the future as site conditions change. However, the site would be monitored continually during the construction period, and appropriate actions would be taken as necessary to ensure that the construction workers are protected from radiation.

The new nuclear power plant would release liquid effluents to the Clinch River arm of the Watts Bar ER Sections 3.5.1 and Reservoir via the cooling-water discharge stream. 5.4.1.1(a);

EIS Sections 5.9.1 and G.2.1 Transportation Overall, the generating output of the SMRs at the CRN Site or alternative sites would be 800 MW(e) ER Section 7.4(a), EIS and the station capacity factor would be 90 percent. Section 6.2 J-13 Unirradiated fuel assemblies would be shipped to the CRN Site by truck only shortly before they would ER Section 5.7.2(a),

be needed. EIS Section 6.2.1 Radioactive waste and spent fuel would be shipped from the CRN Site by truck only. The number of ER Section 5.7.2(a),

radioactive waste shipments was based on 2.34 m3/shipment. The number of spent fuel shipments EIS Section 6.2.2 and was based on 0.5 MTU/shipment. 6.2.3 The radionuclide inventory used in the transportation accident analysis was based on AP1000 reactor ER Section 7.4(a), EIS fuel. Section 6.2.2 The new nuclear power plant would have storage capacity exceeding that needed to accommodate 5- ER Section 5.7.2(a),

year cooling of irradiated fuel before transport offsite. EIS Section 6.2.2 The transportation impact analysis for the surrogate SMR spent fuel shipments assumed the radiation EIS Section 6.2.2 dose rate emitted from the shipments would be the maximum allowed by Federal regulations.

It was assumed that shipping casks for the surrogate SMR spent fuel would provide equivalent EIS Section 6.2.2 mechanical and thermal protection of the spent fuel cargo (relative to the current light water reactor

[LWR] spent fuel shipping cask designs).

Table J-2. (contd)

Technical Area Representations/Assumptions Source For this assessment, release fractions for current-generation LWR fuels were used to approximate the EIS Section 6.2.2 impacts from advanced reactor spent fuel shipments. This essentially assumes that the behavior of fuel materials and containment systems (e.g., cladding and fuel coatings) is similar to that of the current-generation LWR fuel under applied mechanical and thermal conditions.

The proposed geologic repository at Yucca Mountain was used as a surrogate destination for spent ER Sections 5.7.2 and fuel shipments. 7.4(a), EIS Section 6.2.2 It was assumed that no shipments of unirradiated fuel, irradiated fuel, or radioactive waste would be ER Sections 5.7.2 and made by barge or rail. 7.4(a), EIS Section 6.2 It was assumed that shipments of spent nuclear fuel would be shipped directly to a geologic ER Sections 5.7.2 and repository. Shipment of spent nuclear fuel to an interim storage facility followed by shipment to a 7.4(a), EIS Section 6.2 geologic repository was not analyzed.

Decommissioning Impacts from decommissioning new reactor unit(s) designs are considered to be bounded by those in EIS Section 6.3 J-14 NUREG-0586, Supplement 1 (NRC 2002-TN665).

Nuclear Fuel Cycle and Fuel Storage All of the SMR technologies considered have a design storage capacity for spent fuel pools of a ER Section 3.8.2(a) minimum of 6 years, a period sufficient to accommodate a 5-year cooling period, as required in 10 CFR Part 961, Appendix E (TN300).

After a sufficient decay period of at least 5 years, the fuel would be removed from the pool and ER Section 3.8.2(a) packaged in spent fuel shipping/storage casks either for storage onsite at an independent spent fuel storage installation (ISFSI) or for transportation offsite. Onsite storage would be licensed in accordance with 10 CFR Part 72 (TN4884), Licensing Requirements for the Independent Storage of Spent Nuclear Fuel and High-Level Waste, and Reactor-Related Greater than Class C Waste, and transferred either to an ISFSI facility onsite or an offsite disposal facility. Offsite transportation would be conducted in accordance with 49 CFR Part 173 (TN298), 49 CFR Part 178 (TN5160), and 10 CFR Part 71 (TN301).

Accidents The exclusion area boundary (EAB) is greater than 0.21 mi (1,100 ft or 335 m) in all directions from ER Section 2.7.5-,

the footprint of the new nuclear power plant. No major roads, public buildings, or residences are EIS Section 5.11.1 located within the exclusion area.

Table J-2. (contd)

Technical Area Representations/Assumptions Source Because TVAs ESP application does not rely on information based on an approved SMR design ER Section 7.1.1(a),

certification, the design basis accident (DBA) analysis is based on a surrogate SMR and only applying EIS Section 5.11.1 a loss of coolant accident (LOCA) source term as a bounding calculation.

The LOCA source term is based on the vendor design of the four SMR designs under consideration ER Section 7.1.2(a),

that resulted in the highest doses at both the EAB and the low-population zone boundary. The source EIS Section 5.11.1 term is based on uranium fuel enriched to no more than 5 percent, which is representative of the SMR designs under consideration, a maximum single unit power level of 800 megawatts thermal (MW(t)),

and a maximum average burnup of 51 gigawatt days per metric tons of uranium (GWD/MTU), while the maximum average burnup for the remaining SMR designs is less than 41 GWD/MTU.

In accordance with RG 1.183 (NRC 2000-TN517), the DBA dose for the EAB is from the 2-hour period ER Section 7.1(a),

that yields the maximum dose. EIS Section 5.11.1 Population growth in the vicinity of the CRN Site would not alter the population distribution in the ER Section 2.5.1(a),

region. EIS Section 2.5.1 J-15 The severe accident source term was based on a ratio of the maximum PPE thermal power rating of ER Section 7.2.1(a),

800 MW(t) to that of a large PWR previously analyzed. EIS Section 5.11.2 The severe accident risks are based on the assumption that 99.5 percent of the population evacuates ER Section 7.2.3(a),

within the 2 mi and 10 mi emergency planning zones (EPZs) and the other 0.5 percent of the EIS Section 5.11.2 population does not evacuate. No evacuation is assumed to occur for the site boundary EPZ analysis.

The core damage frequencies are based on the largest SMR considered for the CRN Site based on ER Section 7.2.1(a),

proprietary vendor information provided to TVA. EIS Section 5.11.2 To assess health risks from a severe accident, the projected population that resides within a 50-mi ER Section 7.2.2(a),

radius of the CRN Site in 2067 was assumed. EIS Section 5.11.2 The spent fuel pool would be constructed at or below grade level. The spent fuel pools have a design ER Section 3.8.2(a), EIS storage capacity of a minimum of 6 years, a period sufficient to accommodate a 5-year cooling period, Section 5.11.2 as required in 10 CFR Part 961, Appendix E (TN300). The spent fuel assemblies would remain in the pool for at least 5 years, after which they would be transferred to onsite dry storage at an independent spent fuel storage installation (ISFSI).

Table J-2. (contd)

Technical Area Representations/Assumptions Source An appropriately sized ISFSI would be constructed and operational within 6 years from the ER Section 3.8.2(a) commencement of operations. After a sufficient decay period of at least 5 years, the fuel would be removed from the pool and packaged in spent fuel shipping/storage casks either for storage onsite at an (ISFSI or for transportation offsite.

System Design Alternatives Water-treatment alternatives for the circulating-water system were not described in the ER and not EIS Section 9.4 evaluated in the ESP EIS. Therefore, this issue is not resolved.

Cumulative Impacts The proposed nearby projects and activities that could have a cumulative effect on the construction or EIS Section 2.12 and 7.0 operation of a new nuclear power plant at the CRN Site are those identified in EIS Sections 2.12 and 7.0 (a) TVA 2017-TN4921 1

J-16

1 J.1 References 2 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 3 Protection Against Radiation." Washington, D.C. TN283.

4 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 5 Production and Utilization Facilities." Washington, D.C. TN249.

6 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 7 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

8 Washington, D.C. TN250.

9 10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, "Packaging and 10 Transportation of Radioactive Material." Washington, D.C. TN301.

11 10 CFR Part 72. Code of Federal Regulations, Title 10, Energy, Part 72, "Licensing 12 Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive 13 Waste, and Reactor-Related Greater than Class C Waste." Washington, D.C. TN4884.

14 10 CFR Part 961. Code of Federal Regulations, Title 10, Energy, Part 961, "Standard Contract 15 for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste." Washington, D.C.

16 TN300.

17 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 18 Part 800, "Protection of Historic Properties." Washington, D.C. TN513.

19 40 CFR Part 125. Code of Federal Regulations, Title 40, Protection of Environment, Part 125, 20 "Criteria and Standards for the National Pollutant Discharge Elimination System." Washington, 21 D.C. TN254.

22 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 23 "Environmental Radiation Protection Standards for Nuclear Power Operations." Washington, 24 D.C. TN739.

25 49 CFR Part 173. Code of Federal Regulations, Title 49, Transportation, Part 173, "Shippers 26 General Requirements for Shipments and Packagings." Washington, D.C. TN298.

27 49 CFR Part 178. Code of Federal Regulations, Title 49, Transportation, Part 178, 28 "Specifications for Packagings." Washington, D.C. TN5160.

29 16 U.S.C. § 470aa et seq. Archaeological Resources Protection Act of 1979, as amended.

30 TN1687.

31 25 U.S.C. § 3001 et seq. Native American Graves Protection and Repatriation Act. TN1686.

32 42 U.S.C. § 1996 et seq. American Indian Religious Freedom Act, as amended. TN5281.

33 54 U.S.C. § 300101 et seq. National Historic Preservation Act. TN4157.

34 54 U.S.C. § 312501 et seq. Archeological and Historic Preservation Act of 1974, as amended.

35 TN4844.

J-17

1 AECOM (AECOM Technical Services, Inc.). 2015. Clinch River Site Traffic Assessment. Final 2 Technical Report, L98 160208 008, Greenville, South Carolina. Accession No. ML17334A043.

3 TN5000.

4 EO 13007. May 24, 1996. Executive Order 13007Indian Sacred Sites. Office of the 5 President, Washington, D.C. TN5250.

6 EO 13175. November 6, 2000. Executive Order 13175Consultation and Coordination with 7 Indian Tribal Governments. Office of the President, Washington, D.C. TN4846.

8 EPRI (Electric Power Research Institute). 2015. "Seasonal/Annual Cooling Tower Impacts 9 (SACTI) Version 2.0 with Source Code." Palo Alto, California. Available at 10 http://www.epri.com/abstracts/Pages/ProductAbstract.aspx?ProductId=000000003002006350.

11 TN4864.

12 NRC (U.S. Nuclear Regulatory Commission). 1977. Calculation of Annual Doses to Man from 13 Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 14 Part 50, Appendix I. Regulatory Guide 1.109, Revision 1, Washington, D.C. Accession No.

15 ML003740384. TN90.

16 NRC (U.S. Nuclear Regulatory Commission). 1977. Methods for Estimating Atmospheric 17 Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled 18 Reactors. Regulatory Guide 1.111, Revision 1, Washington, D.C. Accession No.

19 ML003740354. TN91.

20 NRC (U.S. Nuclear Regulatory Commission). 2000. Alternative Radiological Source Terms for 21 Evaluating Design Basis Accidents at Nuclear Power Reactors. Regulatory Guide 1.183, 22 Washington, D.C. Accession No. ML003716792. TN517.

23 NRC (U.S. Nuclear Regulatory Commission). 2000. Environmental Standard Review Plan 24 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, 25 Main Report and 2007 Revisions, Washington, D.C. Available at http://www.nrc.gov/reading-26 rm/doc-collections/nuregs/staff/sr1555/toc/. TN614.

27 NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 28 Statement of Decommissioning of Nuclear Facilities: Regarding the Decommissioning of 29 Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, D.C.

30 Accession Nos. ML023470327, ML023500228. TN665.

31 TVA (Tennessee Valley Authority). 2016. Letter from J.W. Shea to NRC, dated December 13, 32 2016, regarding "Submittal of Supplemental Information Regarding Terrestrial Ecology in 33 Support of Early Site Permit Application for Clinch River Nuclear Site." CNL-16-200, 34 Chattanooga, Tennessee. Accession No. ML16348A552. TN5145.

35 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 36 Application, Part 03Environmental Report (Revision 1)." Chattanooga, Tennessee.

37 Accession No. ML18003A471. TN4921.

38 TVA (Tennessee Valley Authority). 2017. Letter from J.W. Shea to NRC, dated August 1, 39 2017, regarding "Submittal of Supplemental Information Related to the Environmental Audit in J-18

1 Support of Early Site Permit Application for Clinch River Nuclear Site." CNL-17-097, 2 Chattanooga, Tennessee. Accession No. ML17234A003. TN4922.

J-19

1 APPENDIX K 2 GREENHOUSE GAS FOOTPRINT ESTIMATES FOR A REFERENCE 3 1,000-MW(E) LIGHT WATER REACTOR (LWR) 4 The review team estimated the greenhouse gas (GHG) footprint of various activities associated 5 with nuclear power plants. These activities include building, operating, and decommissioning a 6 nuclear power plant. The GHG emission estimates include direct emissions from the nuclear 7 facility and indirect emissions from workforce transportation and the uranium fuel cycle.

8 Preconstruction/construction equipment estimates listed in Table K-1 are based on hours of 9 equipment use estimated for a single nuclear power plant at a site requiring a moderate amount 10 of terrain modification (UniStar 2007-TN1564). Preconstruction/construction equipment carbon 11 monoxide (CO) emission estimates were derived from the hours of equipment use, and carbon 12 dioxide (CO2) emissions were then estimated from the CO emissions using a scaling factor of 13 172 tons of CO2 per ton of CO (Chapman et al. 2012-TN2644). The scaling factor is based on 14 the ratio of CO2 to CO emission factors for diesel fuel industrial engines as reported in Table 15 3.3-1 of AP-42 Compilation of Air Pollutant Emission Factors (EPA 2012-TN2647). A CO2 to 16 total GHG equivalency factor of 0.991 is used to account for the emissions from other GHGs, 17 such as methane (CH4) and nitrous oxide (N2O) (Chapman et al. 2012-TN2644). The 18 equivalency factor is based on non-road/construction equipment in accordance with relevant 19 guidance (NRC 2014-TN3768; Chapman et al. 2012-TN2644). Equipment emissions estimates 20 for decommissioning are assumed to be one-half of those for preconstruction/construction.

21 Data on equipment emissions for decommissioning are not available; the one-half factor is 22 based on the assumption that decommissioning would involve less earthmoving and hauling of 23 material, as well as fewer labor hours, when compared with preconstruction/construction 24 (Chapman et al. 2012-TN2644).

25 Table K-1. GHG Emissions from Equipment Used in Preconstruction/Construction 26 and Decommissioning (MT CO2e)

Preconstruction/Construction Decommissioning Equipment Total(a) Total(b)

Earthwork and Dewatering 12,000 6,000 Batch Plant Operations 3,400 1,700 Concrete 5,400 2,700 Lifting and Rigging 5,600 2,800 Shop Fabrication 1,000 500 Warehouse Operations 1,400 700 Equipment Maintenance 10,000 5,000 Total(c) 39,000 19,000 (a) Based on hours of equipment usage over a 7-year period.

(b) Based on equipment usage over a 10-year period.

(c) Results are rounded to the nearest 1,000 MT CO2e.

27 Table K-2 lists the review teams estimates of the CO2 equivalent (CO2e) emissions associated 28 with workforce transportation. Workforce estimates for new plant preconstruction/construction 29 are conservatively based on estimates in various combined license (COL) applications 30 (Chapman et al. 2012-TN2644), and the operational and decommissioning workforce estimates 31 are based on Supplement 1 to NUREG-0586 (NRC 2002-TN665). The table lists the K-1

1 assumptions used to estimate total miles traveled by each workforce and the factors used to 2 convert total miles to metric tons (MT) of CO2e. The workers are assumed to travel in gasoline-3 powered passenger vehicles (cars, trucks, vans, and sport utility vehicles) that get an average 4 of 21.6 mi/gal of gasoline (FHWA 2012-TN2645). Conversion from gallons of gasoline burned 5 to CO2e is based on U.S. Environmental Protection (EPA) emission factors (EPA 2012-6 TN2643).

7 Table K-2. Workforce GHG Footprint Estimates Preconstruction/

Construction Operational Decommissioning SAFSTOR Workforce Workforce Workforce Workforce Commuting Trips 1,000 550 200 40 (round trips per day)

Commute Distance 40 40 40 40 (miles per round trip)

Commuting Days 365 365 250 365 (days per year)

Duration 7 40 10 40 (years)

Total Distance Traveled 102,000,000 321,000,000 20,000,000 23,000,000 (miles)(a)

Average Vehicle Fuel 21.6 21.6 21.6 21.6 Efficiency(b)

(miles per gallon)

Total Fuel Burned(a) 4,700,000 14,900,000 900,000 1,100,000 (gallons)

CO2 Emitted Per Gallon(c) 0.00892 0.00892 0.00892 0.00892 (MT CO2)

Total CO2 Emitted(a) 42,000 133,000 8,000 10,000 (MT CO2)

CO2 Equivalency Factor(c) 0.977 0.977 0.977 0.977 (MT CO2/MT CO2e)

Total GHG Emitted(a) 43,000 136,000 8,000 10,000 (MT CO2e)

(a) Results are rounded.

(b) Source: FHWA 2012-TN2645.

(c) Source: EPA 2012-TN2643.

8 10 CFR 51.51(a) (TN250) states that every Environmental Report prepared for the COL stage of 9 a light-water-cooled nuclear power reactor shall take Table S-3, Table of Uranium Fuel Cycle 10 Environmental Data, from 10 CFR 51.51(b) (TN250) as the basis for evaluating the contribution 11 of the environmental effects of uranium fuel cycle activities to the environmental costs of 12 licensing the nuclear power reactor. 10 CFR 51.51(a) (TN250) further states that Table S-3 13 shall be included in the Environmental Report and may be supplemented by a discussion of the 14 environmental significance of the data set forth in the table as weighted in the analysis for the 15 proposed facility.

16 Table S-3 of 10 CFR 51.51(b) does not provide an estimate of GHG emissions associated with 17 the uranium fuel cycle; it only addresses pollutants that were of concern when the table was 18 promulgated in the 1980s. However, Table S-3 states that 323,000 MWh is the assumed K-2

1 annual electric energy use for the reference 1,000 MW(e) nuclear power plant and that this 2 323,000 MWh of annual electric energy is assumed to be generated by a 45 MW(e) coal-fired 3 power plant burning 118,000 MT of coal. Table S-3 also assumes that approximately 4 135,000,000 standard cubic feet (scf) of natural gas is required per year to generate process 5 heat for certain portions of the uranium fuel cycle. The review team estimates that burning 6 118,000 MT of coal and 135,000,000 scf of natural gas per year results in approximately 7 253,000 MT of CO2e being emitted into the atmosphere per year because of the uranium fuel 8 cycle (Harvey 2013-TN2646).

9 The review team estimated GHG emissions related to plant operations from a typical usage of 10 various onsite diesel generators (UniStar 2007-TN1564). CO emission estimates were derived 11 assuming an average of 600 hours0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months of emergency diesel generator operation per year (four 12 generators, each operating 150 hr/yr) and 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months of station blackout diesel generator 13 operation per year (two generators, each operating 100 hr/yr) (Chapman et al. 2012-TN2644).

14 A scaling factor of 172 was then applied to convert the CO emissions to CO2 emissions, and a 15 CO2 to total GHG equivalency factor of 0.991 was used to account for the emissions from other 16 GHGs such CH4 and N2O (Chapman et al. 2012-TN2644).

17 Given the various sources of GHG emissions discussed above, the review team estimated the 18 total life-cycle GHG footprint for a reference 1,000 MW(e) nuclear power plant with an 19 80 percent capacity factor to be about 10,500,000 MT, with a 7-year preconstruction and 20 construction phase, 40 years of operation, and 10 years of decommissioning (Chapman et 21 al. 2012-TN2644). The components of the GHG emissions footprint are summarized in 22 Table K-3. The uranium fuel-cycle component of the footprint is a significant portion of the 23 overall estimated GHG emissions. This emissions estimate for the uranium fuel cycle is directly 24 related to the assumed power generated by the plant. As a result, it is reasonable to use 25 reactor power to scale the overall GHG footprint to reactors with different power generation 26 capacities.

27 Table K-3. Nuclear Power Plant Lifetime GHG Footprint Activity Total Emissions Source Duration (yr) (MT CO2e)

Preconstruction/Construction Equipment 7 39,000 Preconstruction/Construction Workforce 7 43,000 Plant Operations 40 181,000 Operations Workforce 40 136,000 Uranium Fuel Cycle 40 10,100,000 Decommissioning Equipment 10 19,000 Decommissioning Workforce 10 8,000 SAFSTOR Workforce 40 10,000 TOTAL(a) 10,500,000 (a) Results are rounded to the nearest 1,000 MT CO2e 28 The Intergovernmental Panel on Climate Change (IPCC) released a special report on 29 renewable energy sources and climate change mitigation in 2012 (IPCC 2012-TN2648).

30 Annex II of the IPCC report includes an assessment of previously published works on life-cycle 31 GHG emissions from various electric generation technologies, including nuclear energy. The 32 IPCC report included only reference material that passes certain screening criteria for quality 33 and relevance in its assessment. The IPCC screening yielded 125 estimates of nuclear energy K-3

1 life-cycle GHG emissions from 32 separate references. The IPCC-screened estimates of the 2 life-cycle GHG emissions associated with nuclear energy, as shown in Table A.II.4 of the IPCC 3 report, ranged more than two orders of magnitude, from 1 to 220 grams (g) of CO2e per kWh, 4 with 25th percentile, 50th percentile, and 75th percentile values of 8 g CO2e/kWh, 16 g 5 CO2e/kWh, and 45 g CO2e/kWh, respectively. The range of the IPCC estimates is due, in part, 6 to assumptions regarding the type of enrichment technology employed, how the electricity used 7 for enrichment is generated, the grade of mined uranium ore, the degree of processing and 8 enrichment required, and the assumed operating lifetime of a nuclear power plant. The review 9 teams life-cycle GHG estimate of approximately 10,500,000 MT CO2e for the reference 1,000 10 MW(e) nuclear plant is equal to about 37.5 g CO2e/kWh, which places the review team estimate 11 between the 50th and 75th percentile values of the IPCC estimates in Table A.II.4 of the IPCC 12 report.

13 In closing, the review team considers the footprint estimated in Table K-3 to be appropriately 14 conservative. The GHG emissions estimates for the dominant component (uranium fuel cycle) 15 are based on 30-year-old enrichment technology, assuming that the energy required for 16 enrichment is provided by coal-fired generation. As can be seen in Table K-3, only the scaling 17 of the uranium fuel-cycle emissions estimate makes a significant difference in the total carbon 18 footprint of the project. Other reasonable assumptions related to the source of energy used for 19 enrichment or the enrichment technology could lead to a significantly reduced footprint estimate.

20 Emissions estimates presented in this environmental impact statement use values presented in 21 this appendix, which the review team considers conservative for the proposed project. Plant 22 operations emissions are adjusted to represent the number of large GHG emissions sources 23 (diesel generators, boilers, etc.) associated with the proposed project. The workforce emissions 24 estimates are scaled to account for differences in workforce numbers and commuting distance.

25 Finally, equipment emissions estimates are scaled by estimated equipment usage.

26 References 27 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 28 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

29 Washington, D.C. TN250.

30 Chapman, E.G., J.P. Rishel, J.M. Niemeyer, K.A. Cort, and S.E. Gulley. 2012. Assumptions, 31 Calculations, and Recommendations Related to a Proposed Guidance Update on Greenhouse 32 Gases and Climate Change. PNNL-21494, Pacific Northwest National Laboratory, Richland, 33 Washington. Accession No. ML12310A212. TN2644.

34 EPA (U.S. Environmental Protection Agency). 2012. "Clean Energy: Calculations and 35 References." Accession No. ML12292A648. TN2643.

36 EPA (U.S. Environmental Protection Agency). 2012. "Stationary Internal Combustion Sources."

37 Chapter 3 in Technology Transfer Network Clearinghouse for Inventories & Emissions Factors:

38 AP-42. Compilation of Air Emission Factors. Fifth Edition, Research Triangle Park, North 39 Carolina. Accession No. ML12292A637. TN2647.

K-4

1 FHWA (Federal Highway Administration). 2012. "Highway Statistics 2010 (Table VM-1)."

2 Office of Highway Policy Information, Washington, D.C. Accession No. ML12292A645.

3 TN2645.

4 Harvey, B. 2013. "Greenhouse Emissions for the Fossil Fuel Sources Identified in Table S-3."

5 Office of New Reactors, U.S. Nuclear Regulatory Commission, Washington, D.C. Accession No.

6 ML12299A401. TN2646.

7 IPCC (Intergovernmental Panel on Climate Change). 2012. Renewable Energy Sources and 8 Climate Change MitigationSpecial Report of the Intergovernmental Panel on Climate Change.

9 Cambridge University Press, Cambridge, United Kingdom. TN2648.

10 NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 11 Statement of Decommissioning of Nuclear Facilities: Regarding the Decommissioning of 12 Nuclear Power Reactors. NUREG-0586, Supplement 1, Volumes 1 and 2, Washington, D.C.

13 Accession Nos. ML023470327, ML023500228. TN665.

14 NRC (U.S. Nuclear Regulatory Commission). 2014. Attachment 1: Staff Guidance for 15 Greenhouse Gas and Climate Change Impacts for New Reactor Environmental Impact 16 Statements, COL/ESP-ISG-026. Washington, D.C. Accession No. ML14100A157. TN3768.

17 UniStar (UniStar Nuclear Energy, LLC). 2007. Technical Report in Support of Application of 18 UniStar Nuclear Energy, LLC and UniStar Nuclear Operating Services, LLC for Certificate of 19 Public Convenience and Necessity Before the Maryland Public Service Commission for 20 Authorization to Construct Unit 3 at Calvert Cliffs Nuclear Power Plant and Associated 21 Transmission Lines. Public Service Commission of Maryland, Baltimore, Maryland. Accession 22 No. ML090680053. TN1564.

K-5

1 APPENDIX L 2 THE EFFECT OF CLIMATE CHANGE ON THE 3 EVALUATION OF ENVIRONMENTAL IMPACTS 4 The review team has determined that it is reasonably foreseeable that climate change may 5 substantially alter the affected environment described in Chapter 2 of this environmental impact 6 statement (EIS). Climate change is a global phenomenon that the construction and operation of 7 two or more small modular reactors (SMRs) at the Clinch River Nuclear (CRN) Site will not 8 appreciably alter. However, climate change will provide a new environment that may result in 9 changed impacts from the proposed project.

10 The objective of this appendix is to document the review teams consideration of the potential 11 changes in impacts that may occur as a result of a new future environment. This appendix is 12 not intended to be a comprehensive climate change assessment for the affected region. It 13 documents the review teams qualitative determination of the likely shifts in the impacts 14 described in this EIS, if the environment is altered in a manner consistent with the predictions in 15 current climate change literature.

16 The U.S. Nuclear Regulatory Commission (NRC) staff documents the review of the safety of the 17 site in the Site Safety Analysis Report. The staffs overall safety review process includes 18 periodic reconfirmation of natural hazards, such as flooding as discussed in SECY-15-0137 19 (NRC 2015-TN4731).

20 This appendix documents the review teams assessment of the potential effects of climate 21 change on its evaluation of the environmental impacts of the proposed action. The results of 22 this assessment are presented below in three sections: (1) description of the assessment 23 process, (2) potential climate change impacts in the region, and (3) assessment summary.

24 L.1 Description of the Assessment Process 25 The NRC staff developed a process to ensure that the potential effects of climate change are 26 adequately considered for all resource areas in a new reactor licensing National Environmental 27 Policy Act (42 U.S.C. § 4321 et seq.-TN661) review. This EIS does not include an exhaustive 28 discussion of climate change alterations to the existing environment. Throughout this Appendix, 29 the review team references the comprehensive evaluation completed by the U.S. Global 30 Change Research Program (GCRP) (GCRP 2014-TN3472). The interagency GCRP was 31 established under the Global Change Research Act of 1990 (P.L. 101-606) (15 U.S.C. § 2921 et 32 seq.-TN3330) to understand, assess, predict, and respond to human-induced and natural 33 processes of global change and is the authoritative U.S. government source on likely climate 34 change impacts in the United States.

35 In the first step of the process, the review team created a master table identifying plausible 36 connections between nuclear power station resource area concerns and likely climate change-37 caused alterations to the existing environment as identified in the most recent climate change 38 impacts report issued by the GCRP. The review team used the master table to identify whether 39 GCRP-identified climate change impacts were likely to increase, decrease, or leave unchanged 40 the assessed impact of a proposed facility on the environment, and to identify areas where 41 scientific uncertainty precludes a definitive assessment. The comprehensive master table can 42 be found in the NRCs Agencywide Documents Access and Management System (ADAMS),

43 L-1

1 which is accessible from the NRC website at www.nrc.gov/reading-rm/adams.html (the Public 2 Electronic Reading Room) under ADAMS accession number ML18022A104 (NRC 2018-3 TN5405).

4 The review team generated a resource table specific to the CRN Site by removing irrelevant 5 GCRP climate impacts and NRC resource area issues from the master table, and by using 6 specific Southeast regional predictions identified by the GCRP. For example, the review team 7 determined GCRP-identified direct impacts related to sea-level rise were not relevant to the 8 CRN project environment and therefore did not include this information in the site-specific 9 resource table. The review team used the site-specific resource table (NRC 2018-TN5406) in 10 its assessment of the potential effects of climate change on relevant resource areas as 11 discussed in Section L.3 of this appendix.

12 While general scientific consensus is that climate change is occurring and will continue to occur 13 for the foreseeable future, significant uncertainty remains about the magnitude of the changes 14 for specific regions and the precise magnitude and form of the alterations to the environment as 15 a result of climate change (GCRP 2014-TN3472). The review team acknowledges these 16 circumstances and explicitly notes in this appendix where uncertainty in future climate 17 predictions and uncertainty in resulting impacts may make it impossible at this time to conclude 18 qualitatively what the influence of climate change may be on a specific resource area or issue.

19 L.2 Potential Climate Change Impacts in the Region 20 The recent compilation of the state of knowledge in this areaGCRPs climate change impacts 21 report (GCRP 2014-TN3472)was considered in the preparation of this EIS. Most GCRP 22 projections are expressed as a change expected for the later part of the 21st century 23 (20712099) relative to average conditions existing in the later part of the 20th century 24 (19701999). Projected changes in the GCRP report are dependent on future emissions of 25 heat-trapping gases. The GCRPs climate change impacts report includes projections for wide-26 ranging scenarios in which such emissions are rapidly reduced and where they continue to 27 increase.

28 An early site permit (ESP) is valid only for a particular site; it is not an authorization to build or 29 operate a nuclear power plant. An ESP is valid for up to 20 years and may be renewed for an 30 additional 10 to 20 years (10 Code of Federal Regulations [CFR] 52.26, 10 CFR 52.33) 31 (TN251); a combined construction permit and operating license (COL) is valid for 40 years 32 (10 CFR 52.103-TN251). The Tennessee Valley Authority (TVA) has indicated that it expects to 33 apply for a COL for two or more SMRs at the CRN Site in the future. The timeline provided in 34 TVAs ESP application indicates that once a COL is obtained, site preparation for and 35 construction of two or more SMRs at the CRN Site would take approximately 6 years before the 36 last unit commences operation. TVAs environmental analysis assumed that site preparation 37 would start in mid-2020, and the last unit would commence operation in mid-2027. The Atomic 38 Energy Act (42 U.S.C. § 2011 et seq.-TN663) and NRC regulations (10 CFR 52.103-TN251) 39 limit commercial power reactor licenses to an initial 40 years but also permit such licenses to be 40 renewed. If granted, under TVAs anticipated schedule the COL(s) would be valid until 2067.

41 Because a COL could be issued at any time during the period an ESP is valid, changes in 42 TVAs anticipated schedule could extend this date beyond 2067. Therefore, the review team 43 considered GCRP impacts report projections for the 20712099 period to be bounding for 44 assessing the effects of climate change on the resource area impacts presented in this EIS.

L-2

1 As discussed above, projected changes used in this section are taken from the GCRP impacts 2 report (GCRP 2014-TN3472). Unless indicated otherwise, the review team refers to changes 3 for the 2041-2070 and 20712099 periods relative to the 19701999 period under a continued 4 increasing emissions scenario in this section.

5 Projected changes in the climate for eastern Tennessee include an increase in average surface 6 air temperature of 8°F to 9°F (GCRP 2014-TN3472). The hottest and coldest days expected in 7 a 20-year period at the end of this century (20812100) are projected to be 10°F to 15°F 8 warmer than those experienced at the turn of the last century (19862005) (GCRP 2014-9 TN3472). Eastern Tennessee is projected to experience 16 to 20 fewer days with temperatures 10 below 32°F during the 20412070 period relative to 19712000 (GCRP 2014-TN3472); the 11 frost-free season would increase by 30 to 40 days in the 2070-2099 period relative to 12 19712000 (GCRP 2014-TN3472).

13 Projected precipitation changes in eastern Tennessee vary seasonally, but are generally within 14 the range of natural variability. For the Southeast in general, GCRP (2014-TN3472) notes that 15 while change in projected precipitation for this region has high uncertainty, there is still a 16 reasonable expectation that there will be reduced water availability due to the increased 17 evaporative losses resulting from rising temperature alone. In eastern Tennessee, annual 18 water yield (availability) is projected to decrease 2.5 percent to 5 percent per decade for the 19 period 2010-2060, relative to 2010 (GCRP 2014-TN3472). Without consideration of the 20 impacts of climate change, water demand in eastern Tennessee is projected to increase by 10 21 to 25 percent by 2060, relative to 2005, based on combined changes in population and 22 socioeconomic conditions. Accounting for climate change, water demand in eastern Tennessee 23 is projected to increase by 25 to 50 percent by 2060, relative to 2005 (GCRP 2014-TN3472).

24 The Southeast region currently contains existing power plant capacity to produce 32 percent 25 of the nations electricity, but also currently consumes 27 percent of the nations total capacity, 26 more than any other GCRP-defined region. Higher temperatures caused by climate change and 27 the resulting increased use of air conditioning are projected to increase regional energy 28 demand, potentially stress[ing] electricity generating capacity, distribution infrastructure, and 29 energy costs (GCRP 2014-TN3472).

30 Other climate change impacts in the Southeast region identified in the GCRP report and 31 relevant to the CRN project area include effects on fisheries and fishery habitats due to wetland 32 loss; spread of non-native plants; decreased crop production and livestock yield; increased 33 formation of allergens and air pollutants, including ozone; and increases in harmful algal blooms 34 and other surface-waterborne disease-causing agents.

35 L.3 Assessment Summary 36 This section summarizes the review teams assessment of the effects of climate change on 37 relevant resource areas using the process outlined in Section L.1.

38 L.3.1 Land Use 39 L.3.1.1 Land-Use Summary 40 Climatological changes are not likely to influence, or lead to, any changes in plant-related 41 impacts on local/regional land-use classifications or economic development plans. Climate 42 change could lead to changes in the distribution of land use in eastern Tennessee. However, L-3

1 once the operational workforce is housed in the initial years of operation, operation of a reactor 2 is not expected to alter land use. Therefore, there is little potential for interaction between land-3 use changes resulting from climate change and land-use changes caused by later operation of 4 the reactor.

5 L.3.1.2 Land-Use Conclusion 6 Climatological changes are not expected to affect the land-use impacts assigned in the EIS.

7 L.3.2 Hydrology 8 L.3.2.1 Summary 9 Reduced water availability in the Clinch River basin would increase the fraction of the mean 10 annual flow consumptively used by the proposed project. Even with the maximum projected 11 decrease in annual water yield of 5 percent per decade, however, consumptive use of the 12 proposed project would be less than 1 percent of the projected mean annual flow in the Clinch 13 River arm of Watts Bar Reservoir during the period that corresponds to the final years of TVAs 14 projected COL schedule (2060-2070). As a result of reduced water availability in the region, 15 there would be an increase in the occurrence of periods of low flow in the Clinch River. Under 16 TVAs current reservoir operation policy (TVA 2004-TN4913), the minimum daily average 17 release from Melton Hill Dam would remain unchanged, so that the maximum fraction of Clinch 18 River flows withdrawn and consumptively used by a nuclear power plant at the CRN Site would 19 remain bounded by the values described in Section 5.2.2 of this EIS. However, the fraction of 20 time during which the plant is using Clinch River water during low-flow periods would increase.

21 Increased temperatures in the region would result in an increase in Clinch River water 22 temperatures at the CRN Site. However, the incremental increases in water temperatures 23 resulting from plant discharges would remain similar. As a result, the review team expects that 24 there could be minor changes in the extent of the anticipated thermal plume resulting from the 25 plant discharge, but these would not be noticeable at downstream withdrawal locations.

26 L.3.2.2 Conclusion 27 The review team determined that the water-use impacts caused by the proposed project could 28 increase due to a reasonably foreseeable alteration in the environmental baseline associated 29 with climate change. Under the current reservoir operations policy, however, climatological 30 changes are unlikely to shift the water-use impact determination discussed in the EIS. The 31 review team identified no shift in the potential water-quality impacts caused by the proposed 32 project due to a reasonably foreseeable alteration in the environmental baseline associated with 33 climate change.

34 L.3.3 Terrestrial and Wetland Ecology 35 L.3.3.1 Summary 36 Climate change may affect baseline environmental conditions for terrestrial and wetland habitats 37 and wildlife. Potential effects depend upon the responses of many species to changed 38 conditions, based on their capacity for resilience and adaptation. Increased temperatures are 39 generally expected to result in somewhat lesser water yield due to increased forest uptake of 40 water and evapotranspiration. The timing of water availability may shift to earlier in the growing L-4

1 season with earlier onset of summer dry periods, and increased drought frequency, duration, 2 and intensity, resulting in decreased stream baseflows and groundwater recharge. Habitat in 3 the vicinity of the CRN Site is expected to range from slightly resilient to slightly vulnerable to 4 such effects (Glick et al. 2015-TN5314). Oak-hickory forest in the vicinity is expected to persist, 5 albeit with perhaps some minor changes in plant species composition, including some possible 6 encroachment from pines (Glick et al. 2015-TN5314) and invasive species adapted to drier 7 conditions. Wetland size and persistence may decrease, resulting in a loss of habitat for 8 wetland-dependent wildlife and plant species. Any such changes would take place slowly over 9 the passage of decades. The frequency and severity of wildfires is also anticipated to change, 10 with longer fire seasons and larger burns. Insect outbreaks may also increase. Dramatic 11 events such as fires and insect outbreaks would result in a sudden resetting of mature forest to 12 an earlier stage of forest succession and somewhat greater prevalence of such areas on the 13 landscape and associated early successional and edge wildlife.

14 Wildlife response to climate change is expected to be species-specific. Most mammal 15 (including the Federally listed Indiana bat [Myotis sodalis], northern long-eared bat [Myotis 16 septentrionalis], and gray bat [Myotis grisescens]), bird, and reptile species are considered 17 stable or likely to increase in response to the above effects of climate change, primarily because 18 of their dispersal ability (Glick et al. 2015-TN5314) and ability to adapt to spatial shifts in suitable 19 habitat (e.g., increased temperature making bat hibernacula unsuitable). Some amphibians 20 (e.g., gray tree frog [Hyla versicolor], American toad [Anaxyrus americanus]) are considered 21 moderately vulnerable to the effects of climate change due to their reliance on ephemeral pools 22 for reproduction, which may become fewer or decrease in quality, and because of their limited 23 dispersal ability. Many other amphibians (e.g., eastern box turtle [Terrapene carolina carolina])

24 are considered stable (equally vulnerable and resilient/adaptive). Some plant species are 25 considered moderately to extremely vulnerable to the effects of climate change in the region 26 (due to restricted habitat range, dispersal barriers, and sensitivity to temperature and moisture),

27 while many others are considered stable or likely to increase (e.g., ginseng [Panax 28 quinquefolius]) (Glick et al. 2015-TN5314).

29 L.3.3.2 Conclusion 30 Climate change would place additional stress on the habitats and wildlife affected by the 31 proposed project. However, habitats and most wildlife and plants are generally anticipated to be 32 resilient or to adapt to such changes. Thus, it is anticipated that changes in the environmental 33 baseline due to climate change would not cause an appreciable change (increase or decrease) 34 in the impacts on terrestrial resources discussed in the EIS.

35 L.3.4 Aquatic Ecology 36 L.3.4.1 Summary 37 Projected changes such as the higher temperatures and increases in the occurrence of periods 38 of low flow in the Clinch River will affect the baseline conditions in the habitat of aquatic biota 39 (Glick et al. 2015-TN5314). Higher water temperatures may detrimentally alter low dissolved 40 oxygen conditions in the Clinch River arm of the Watts Bar Reservoir and could put coldwater 41 fish species closer to their thermal tolerance levels. As a result, the resilience and adaptive 42 ability of specific species may be diminished. Fish are the taxonomic group found to be most 43 vulnerable to climate change in Tennessee (Glick et al. 2015-TN5314). Species discussed in 44 Chapter 2 of this EIS that are among the most vulnerable include the Lake Sturgeon (Acipenser L-5

1 vulvescens), considered extremely vulnerable, and the hellbender (Cryptobranchus 2 alleganiensis), considered highly vulnerable.

3 Changes in water temperature can also create more favorable conditions for invasive species 4 that are better able to tolerate the warmer water (Glick et al. 2015-TN5314). The increase in 5 invasive species may create an additional source of stress to the native species from 6 competition or in some cases due to the parasitic behavior of the invasive species.

7 As mentioned previously, incremental increases in water temperatures resulting from nuclear 8 power plant discharges would remain similar. However, minor changes in the extent of the 9 thermal plume are possible, causing the plume to extend farther downstream or increasing the 10 width of the plume at the discharge point or slightly upstream in worst-case weather and flow 11 conditions. Although the extent of these changes is not known, it is likely that the thermal plume 12 would remain small enough that the free passage of fish would be retained for all conditions.

13 Climate change is not expected to noticeably affect the ability of agencies to coordinate on the 14 protection of aquatic species. The importance of close coordination would, however, be greater.

15 L.3.4.2 Conclusion 16 The review team did not identify a shift in the assigned impacts on aquatic ecology caused by 17 the proposed project when accounting for the reasonably foreseeable alteration of baseline 18 conditions associated with climate change.

19 L.3.5 Socioeconomics 20 L.3.5.1 Summary 21 The review team expects that any physical change in the environment from global climate 22 change would proceed too gradually to induce substantial adaptation by residents to the new 23 conditions or cause individuals to move out of the area. Thus no changes to baseline conditions 24 would be expected to be directly attributable to climate change. Consequently, the impact of 25 global climate change on demographics and housing in the economic region would not change 26 due to plant operations. Similarly for local services and resources including public schools, 27 recreational resources, and first-responder agencies, the effects described in Section L.2 are 28 likely to progress too gradually to cause changes in impacts related to plant 29 operations. Consequently, the review team determined the global climate change impacts on 30 community services would not change due to plant operations.

31 The review team expects that for traffic related to the operational workforce, deliveries, and 32 similar activities, climatological changes are not likely to alter the impacts of plant activities on 33 local transportation infrastructure. The pace of climate change is not likely to be rapid enough 34 to affect noticeable changes in plant operations, and therefore would not result in any noticeable 35 change in transportation related impacts.

36 The review team expects that, like traffic, the gradual effects of climate change would not 37 significantly change the aesthetic appeal of local recreation areas and the publics access to 38 local recreation areas. Therefore, the project-related impacts to local recreation areas would 39 remain unchanged. There may be linkage between the hypothesized reduction in days below 40 freezing identified in Section L.2 and steam plume visibility during winter. If these conditions L-6

1 occur, the visual intrusion of steam plumes during winter months may be reduced, but the size 2 and frequency of visible steam plumes under climate change is not known.

3 The review team expects that because the plant would continue to operate in accordance with 4 all permits and regulations during its license period, impacts of plant activities on local 5 employment, wage and salary income, economic output, and tax revenues would not be 6 affected by climate change.

7 L.3.5.2 Conclusion 8 As indicated in the EIS, the review team did not identify any significant shifts in socioeconomic 9 impacts as a result of possible climatological changes in the environmental baseline. Potential 10 impacts on socioeconomics including infrastructure, community services, and local economics 11 as a result of climate change effects on plant operations would be gradual and would be 12 addressed through regional and local governmental strategic adaptive plans.

13 L.3.6 Environmental Justice 14 L.3.6.1 Summary 15 Climate change could present challenges to minority and low-income communities, which the 16 GCRP climate change impacts report refers to as socially vulnerable populations, within the 17 demographic region of the proposed project. The potential impacts for such populations include 18 challenges associated with the ability to cope with climate change effects (e.g., water 19 temperature increases, changing weather patterns), the capacity to adapt, and the ability to 20 relocate. The review team believes it is not unreasonable to expect decision makers in the area 21 to incrementally adapt to the climate change effects by implementing strategic adaptation plans 22 and mitigating measures that would inform and assist minority and low-income communities.

23 Therefore, the conclusions in the EIS regarding environmental justice would remain unchanged.

24 L.3.6.2 Conclusion 25 Overall, the impacts assigned to environmental justice in the EIS would not change as a result 26 of possible climatological changes in the environmental baseline. Potential impacts on 27 environmental justice communities as a result of climate change would continue to be 28 addressed through regional and local governmental strategic adaptive plans.

29 L.3.7 Historic and Cultural Resources 30 L.3.7.1 Summary 31 Significant historic and cultural resources could be impacted by construction, operation, or 32 maintenance of the proposed project. The majority of these resources are located close to the 33 Clinch River, including the Melton Hill Dam National Register of Historic Places-eligible historic 34 district. Because TVA regulates flows and water levels in the Clinch River via the operation of 35 their dams (as described in Section 2.3.1 of this EIS), the review team determined that there 36 would be no shift in the impacts on historic and cultural resources caused by the proposed 37 project due to a reasonably foreseeable alteration in the environmental baseline associated with 38 climate change.

L-7

1 L.3.7.2 Conclusion 2 The climatological changes would not alter the historic and cultural impacts because the Clinch 3 River is already a highly regulated system.

4 L.3.8 Meteorology and Air Quality 5 L.3.8.1 Summary 6 The expected climatological changes would largely be unlikely to affect cooling system impacts 7 from the proposed project on local weather. Projected temperature increases due to climate 8 change may lead to a decrease in fogging from the cooling tower.

9 Climatological changes may affect the sources, types, and estimates of annual air emissions 10 from the proposed project and transmission lines. For example, changes in climate such as 11 increases in the temperature of both the hottest and coldest days may lead to an increase in air 12 pollutant formation due to elevated temperatures. Because of expected increases in 13 temperature over the period of operation, the health impacts of operational air emissions may 14 increase. In a higher temperature environment, the formation of ozone due to emissions of 15 nitrogen oxides from the diesel generators and other equipment is likely to increase, thereby 16 leading to an increase in health impacts.

17 It is unclear whether additional emergency equipment would actually be needed in a changing 18 climate, or whether testing of that equipment would increase, causing an increase in air 19 emissions. Any additional equipment would be subject to Clean Air Act (42 U.S.C. § 7401 et 20 seq.-TN1141) Title V permitting requirements.

21 L.3.8.2 Conclusion 22 Impacts from the cooling system on local weather, discussed in EIS Section 5.7.2, should not 23 change as a result of reasonably foreseeable climate changes.

24 Estimates of air emissions are likely to remain the same, with a possible increase in health 25 impacts due to increased ozone formation from emergency equipment nitrogen oxides 26 emissions in a higher temperature environment. Given the intermittency of the operation of 27 emergency equipment, and the expected emissions rate, air-quality impacts, discussed in EIS 28 Section 5.7.1, should not change significantly as a result of reasonably foreseeable climate 29 changes.

30 L.3.9 Nonradiological Health 31 L.3.9.1 Summary 32 It is not known how changes in climate will affect the presence of etiological agents associated 33 with the proposed project (e.g., receiving waters and cooling tower operations). However, it is 34 reasonable to expect that currently existing laws and regulations protecting workers and 35 members of the public would continue, or would be adjusted as necessary, to be as protective 36 as they are under current climate conditions.

L-8

1 Climatological changes are not likely to have an effect on noise produced by the proposed 2 project; therefore, there would be no change in the health impacts from noise discussed in the 3 EIS.

4 It is not likely that climatological changes would affect potential health impacts from 5 electromagnetic fields associated with plant operations because regulations protecting workers 6 and members of the public from electromagnetic fields would likely be adjusted to avoid 7 impacts.

8 It is not likely that climatological changes would affect occupational health risks for operational 9 plants because regulations protecting workers would be adjusted to avoid impacts on workers.

10 As discussed in EIS Section L.3.5.1, the long-term effects of global climate change are not 11 expected to have a deleterious impact on the current level of infrastructure in the area. The 12 review team expects that any physical changes would occur slowly enough that adaptive 13 measures would limit potential health impacts from traffic-related accidents.

14 L.3.9.2 Conclusion 15 Overall, the expected climatological changes would not change the nonradiological health 16 resource impacts assigned in the EIS. Potential impacts from noise, etiological agents, 17 exposure to electromagnetic fields, and occupational injuries are and would continue to be 18 regulated to be protective of human health. Although there is some uncertainty surrounding 19 predicted climatological changes, it is likely that regulations governing occupational and public 20 health would be adjusted accordingly if needed.

21 L.3.10 Radiological Impacts 22 L.3.10.1 Summary 23 The review team determined that the expected climatological changes over the time period 24 considered by the review team would affect the possibility of exposure to radiation from the 25 operating facility as follows:

26 Existing low population exposures of humans to radiation from the proposed project would 27 remain low because the level of effluent releases and regulatory requirements should not 28 significantly change.

29 Existing low nonhuman biota exposures to radiation from the proposed project should not 30 change because the level of effluent releases and regulatory requirements should not 31 significantly change.

32 The level of effluent releases, regulatory requirements (including those for occupational 33 doses), and existing low exposures should not significantly change. The level of the 34 expected normal radioactive gaseous effluent releases would remain the same. Normal 35 radioactive liquid effluent releases should remain unchanged.

36 L.3.10.2 Conclusion 37 The level of effluent releases, regulatory requirements, and existing low population exposures 38 should not significantly change over the time period considered by the review team. Therefore, 39 review team identified no shift in the radiological impacts caused by the operation of the L-9

1 proposed project due to reasonably foreseeable environmental alterations associated with 2 climate change.

3 L.3.11 Nonradioactive Waste 4 L.3.11.1 Summary 5 Changes in land-use decisions may lead to changes in disposal options for nonradioactive 6 waste and mixed wastes. However, solid, liquid, gaseous, hazardous, and mixed wastes 7 generated during operation of the proposed project would still have to be handled, transported, 8 stored, and disposed of according to county, State, and Federal regulations. It is reasonable to 9 expect that currently existing laws and regulations related to nonradioactive and mixed waste 10 would continue, or would be adjusted as necessary to address changing conditions.

11 L.3.11.2 Conclusion 12 Because nonradioactive and mixed wastes would still be subject to applicable Federal, State, 13 and local requirements, climatological changes are unlikely to shift the impact determination 14 discussed in the EIS.

15 L.3.12 Accidents 16 L.3.12.1 Summary 17 Climatological changes are expected to affect the site-specific, 50th percentile atmospheric 18 dilution factor (i.e., /Q) used to evaluate dose consequences from postulated design basis 19 accidents. The /Q around the site is dependent on local meteorological conditions (wind 20 speed, direction, and stability class). The expected variations for these parameters as a result 21 of climate change may increase, likely leading to less stability, which could increase dispersion 22 and decrease the corresponding radiological effects. However, if predominant wind direction 23 changes, such that higher /Qs shift along the site boundary, low-population zone, and beyond 24 to areas with higher population densities, the impact would increase. Therefore, the overall 25 impact is unknown.

26 Climatological changes might affect the average environmental risks of severe accidents 27 because of changes in either severe accident probabilities due to an increase in the rate of 28 severe natural phenomena and/or associated consequences due to altered patterns of 29 atmospheric dispersion. While the potential severity of storms and other natural phenomena 30 might increase, nuclear power plants must be designed to withstand all credible natural events 31 at the site of concern.

32 The NRC would require any licensee to monitor and review the impacts of climate change on 33 plant operation, severe accident mitigation, and availability of nearby structures required for 34 plant operation and safety. If the NRC determines additional safety enhancements are 35 necessary, it can require that they will be implemented in a timely manner to assure adequate 36 protection of the public through the current NRC regulatory process. Possible increases in the 37 severity of natural phenomena would be examined to ensure the plant licensing basis is 38 appropriately reviewed and updated. It is generally expected that the low core damage 39 frequencies (CDFs) for the SMR designs are not likely to change appreciably because of 40 climate change. Therefore, even if consequences of severe accidents slightly change as a L-10

1 result of climate change, severe accident risk is likely to remain SMALL because CDFs are 2 expected to be low.

3 L.3.12.2 Conclusion 4 The impacts assigned in this EIS should remain unchanged due to reasonably foreseeable 5 environmental alterations associated with climate change. The overall risks for severe 6 accidents are significantly lower than the current generation of nuclear power plants and any 7 climate change effect would have to change the risks by several orders of magnitude to result in 8 a change in the impacts assigned in this EIS.

9 L.3.13 Transportation of Radiological Materials 10 L.3.13.1 Summary 11 The number and type of radioactive material shipments, regulatory requirements, and existing 12 low maximally exposed individual and population exposures and risks from accidents for these 13 types of shipments should not significantly change over the time period considered by the 14 review team for climate change. Radiological doses are strong functions of the radiation dose 15 rate emitted from the shipment, exposure distance, and exposure duration. None of these 16 parameters would be directly or disproportionately influenced by the impacts of climate change.

17 Transportation accident risks are a function of weather conditions. Climate change may 18 increase or decrease dispersion conditions depending on changes in the frequency of storms 19 and severe weather. As a result, the changes in transportation impacts potentially caused by 20 climate change are not expected to be significant, but there are substantial uncertainties about 21 impacts on weather conditions in specific areas and demographic changes that could affect 22 transportation impacts.

23 L.3.13.2 Conclusion 24 Impacts are not expected to change as a result of the effects of climate change, but significant 25 uncertainties are associated with the impacts of climate change on local weather conditions and 26 demographics along the transportation route(s).

27 L.4 References 28 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 29 Production and Utilization Facilities." Washington, D.C. TN249.

30 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, "Licenses, 31 Certifications, and Approvals for Nuclear Power Plants." Washington, D.C. TN251.

32 15 U.S.C. § 2921 et seq. Global Change Research Act of 1990. TN3330.

33 42 U.S.C. § 2011 et seq. Atomic Energy Act of 1954. TN663.

34 42 U.S.C. § 4321 et seq. National Environmental Policy Act (NEPA) of 1969, as amended.

35 TN661.

36 42 U.S.C. § 7401 et seq. Clean Air Act. TN1141.

L-11

1 GCRP (U.S. Global Change Research Program). 2014. Climate Change Impacts in the United 2 States: The Third National Climate Assessment. J.M. Melillo, T.C. Richmond, and G.W. Yohe 3 (eds.). U.S. Government Printing Office, Washington, D.C. Accession No. ML14129A233.

4 TN3472.

5 Glick, P., S.R. Palmer, and J.P. Wisby. 2015. Climate Change Vulnerability Assessment for 6 Tennessee Wildlife and Habitats. National Wildlife Federation and The Nature Conservancy 7 Tennessee for the Tennessee Wildlife Resources Agency, Nashville, Tennessee. Accession 8 No. ML18023A185. TN5314.

9 NRC (U.S. Nuclear Regulatory Commission). 2015. Proposed Plans for Resolving Open 10 Fukushima Tier 2 and 3 Recommendations. SECY-15-0137, Washington, D.C. Accession No.

11 ML15254A006. TN4731.

12 NRC (U.S. Nuclear Regulatory Commission). 2018. "Climate Change Master Table."

13 Washington, D.C. Accession No. ML18022A104. TN5405.

14 NRC (U.S. Nuclear Regulatory Commission). 2018. "Climate Change Table Specific to Clinch 15 River Nuclear Site." Washington, D.C. Accession No. ML18022A108. TN5406.

16 TVA (Tennessee Valley Authority). 2004. Programmatic Environmental Impact Statement, 17 Tennessee Valley Authority Reservoir Operations Study Record of Decision. Knoxville, 18 Tennessee. Accession No. ML17334A041. TN4913.

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1 APPENDIX M 2 BIOLOGICAL ASSESSMENT FOR THE U.S. FISH AND WILDLIFE 3 SERVICE REGARDING THE CLINCH RIVER SMALL MODULAR 4 REACTOR EARLY SITE PERMIT APPLICATION 5

M-1

1 Biological Assessment 2

3 U.S. Fish and Wildlife Service 4

5 6 Clinch River Small Modular Reactor 7 Early Site Permit Application 8

9 10 11 U.S. Nuclear Regulatory Commission Early Site Permit Application 12 Docket No.52-047 13 14 15 16 Roane County, Tennessee 17 18 19 20 February 2018 21 22 23 24 25 U.S. Nuclear Regulatory Commission 26 Rockville, Maryland 27 M-2

1 CONTENTS 2 ABBREVIATIONS/ACRONYMS ............................................................................................... M-8 3 M.1 Proposed Action ............................................................................................................ M-10 4 M.2 Consultation History ...................................................................................................... M-13 5 M.3 Clinch River Nuclear Site and Possible Future Facilities Description ............................ M-14 6 M.3.1 CRN Site and Vicinity ...................................................................................... M-18 7 M.3.1.1 Upland Habitats ............................................................................. M-18 8 M.3.1.2 Wetland Habitats ........................................................................... M-21 9 M.3.1.3 Aquatic Habitats ............................................................................. M-23 10 M.3.2 Offsite Transmission Line Upgrades ............................................................... M-27 11 M.3.3 Possible Future CRN Facilities ........................................................................ M-27 12 M.3.3.1 Power Block ................................................................................... M-27 13 M.3.3.2 Cooling-Water System ................................................................... M-28 14 M.3.3.3 Barge-Unloading Facility ................................................................ M-29 15 M.3.3.4 Melton Hill Dam Bypass ................................................................. M-29 16 M.3.3.5 Onsite Transmission System ......................................................... M-29 17 M.3.3.6 Support and Laydown Areas ......................................................... M-29 18 M.3.3.7 Other Facilities ............................................................................... M-29 19 M.3.3.8 Offsite Transmission Line Upgrades .............................................. M-29 20 M.4 Building Impacts ............................................................................................................ M-32 21 M.4.1 CRN Site and Vicinity ...................................................................................... M-32 22 M.4.1.1 Upland Habitats ............................................................................. M-33 23 M.4.1.2 Wetland Habitats ........................................................................... M-37 24 M.4.1.3 Aquatic Habitats ............................................................................. M-38 25 M.4.1.4 Noise Impacts during Building Activities ........................................ M-40 26 M.4.1.5 Wildlife Collisions with Tall Structures ........................................... M-42 27 M.4.1.6 Herbicide Use ................................................................................ M-43 28 M.4.2 Offsite Transmission Line Upgrades ............................................................... M-43 29 M.5 Operation Impacts ......................................................................................................... M-44 30 M.5.1 CRN Site and Vicinity ...................................................................................... M-44 31 M.5.1.1 Cooling-Tower Impacts on Vegetation ........................................... M-44 32 M.5.1.2 Collisions with Cooling Towers ...................................................... M-45 33 M.5.1.3 Cooling-Tower Noise ..................................................................... M-45 34 M.5.1.4 Transmission Line Corridor Maintenance ...................................... M-47 35 M.5.1.5 Water Withdrawal and Consumption ............................................. M-47 M-3

1 M.5.1.6 Discharge Analysis ........................................................................ M-48 2 M.5.2 Offsite Transmission Line Upgrades ............................................................... M-49 3 M.5.2.1 Terrestrial Resources .................................................................... M-49 4 M.5.2.2 Aquatic Resources ......................................................................... M-49 5 M.6 Species and Critical Habitat Identification ..................................................................... M-49 6 M.6.1 CRN Site and Vicinity ...................................................................................... M-50 7 M.6.1.1 Gray Bat ......................................................................................... M-50 8 M.6.1.2 Indiana Bat..................................................................................... M-53 9 M.6.1.3 Northern Long-Eared Bat ............................................................... M-56 10 M.6.1.4 Tri-Colored Bat .............................................................................. M-58 11 M.6.1.5 Little Brown Bat .............................................................................. M-60 12 M.6.1.6 Freshwater Mussels - Pink Mucket (Lampsilis abrupta) and 13 Sheepnose Mussel (Plethobasus cyphyus) ................................... M-61 14 M.6.1.7 Spotfin Chub (Erimonax monachus) .............................................. M-64 15 M.6.1.8 Hellbender ..................................................................................... M-65 16 M.6.2 Offsite Transmission Lines .............................................................................. M-66 17 M.7 Potential Effects on Species and Habitats ..................................................................... M-97 18 M.7.1 Bat Species ..................................................................................................... M-98 19 M.7.1.1 CRN Site and Vicinity .................................................................... M-98 20 M.7.1.2 Activity Vegetation Clearing (Forest and Non-Forest) ................ M-98 21 M.7.1.3 Activity Wetland and Waterbody Removal................................ M-100 22 M.7.1.4 Activity - Noise Generation (Building and Operation) ................. M-101 23 M.7.1.5 Activity - Collision with Tall Structures ........................................ M-103 24 M.7.1.6 Activity - Changes in Surface-Water Quality ............................... M-103 25 M.7.1.7 Activity - Transmission Line Corridor Maintenance ..................... M-103 26 M.7.2 Gray Bat ........................................................................................................ M-104 27 M.7.2.1 Indirect Adverse Effects ............................................................... M-104 28 M.7.2.2 Summary ..................................................................................... M-105 29 M.7.3 Indiana Bat .................................................................................................... M-105 30 M.7.3.1 Direct Adverse Effects ................................................................. M-105 31 M.7.3.2 Indirect Adverse Effects ............................................................... M-106 32 M.7.3.3 Summary ..................................................................................... M-107 33 M.7.4 Northern Long-Eared Bat .............................................................................. M-107 34 M.7.4.1 Direct Adverse Effects ................................................................. M-107 35 M.7.4.2 Indirect Adverse Effects ............................................................... M-108 36 M.7.4.3 Summary ..................................................................................... M-108 37 M.7.5 Tri-Colored Bat .............................................................................................. M-108 M-4

1 M.7.6 Little Brown Bat ............................................................................................. M-109 2 M.7.7 Aquatic Species ............................................................................................. M-109 3 M.7.7.1 CRN Site and Vicinity .................................................................. M-110 4 M.7.7.2 Freshwater Mussels ..................................................................... M-110 5 M.7.7.3 Spotfin Chub ................................................................................ M-110 6 M.7.7.4 Hellbender ................................................................................... M-111 7 M.7.7.5 Summary of Effects ..................................................................... M-111 8 M.7.8 Transmission Line Upgrades ......................................................................... M-111 9 M.8 Cumulative Effects....................................................................................................... M-113 10 M.9 Conclusions ................................................................................................................. M-114 11 M.9.1 CRN Site, BTA, and Vicinity Including the Affected 69 kV Transmission 12 Line Corridor ................................................................................................ M-115 13 M.9.2 Offsite Transmission Line Upgrades ............................................................. M-116 14 M.10 References .................................................................................................................. M-116 15 M.11 List of Contributors ...................................................................................................... M-127 16 17 M-5

1 FIGURES 2 Figure M-1 Location of the CRN Site and Areas within a 50-Mi Radius.............................. M-11 3 Figure M-2 Area Surrounding the CRN Site ........................................................................ M-12 4 Figure M-3 CRN Site, BTA, and Proposed New Facilities and Plant Layout ...................... M-15 5 Figure M-4 Affected Offsite TVA Transmission Corridors .................................................. M-17 6 Figure M-5 Plant Communities and Habitat Types across the CRN Site and BTA ............. M-20 7 Figure M-6 Aquatic Features Documented within the Clinch River Site and 8 Barge/Traffic Area ............................................................................................ M-24 9 Figure M-7 CRN Site and BTA Development Footprint Overlaid on Terrestrial Habitat 10 Types ................................................................................................................ M-34 11 Figure M-8 Land Cover within the 6-Mi Vicinity of the Clinch River Site ............................. M-36 12 Figure M-9 Salt-Deposition Rates that Exceed 1,000 kg/km2/mo within Depicted 13 Distances, Overlaid on Terrestrial Vegetation and the Development 14 Footprint on the CRN Site ................................................................................. M-46 15 Figure M-10 Location of Norris Dam Cave along the Clinch River within Transmission 16 Line Corridor L5125 in Campbell County, Tennessee ...................................... M-87 17 Figure M-11 Occurrence of Virginia Spiraea near Piney Creek and bluemask darter in 18 Caney Creek, as well as critical habitat for the laurel dace and slabside 19 pearlymussel along Transmission Line Corridor L5173 in Tennessee ............. M-89 20 Figure M-12 Occurrence of blackside dace in Sandlick Branch along Transmission Line 21 Corridor L5125 in Tennessee ........................................................................... M-90 22 Figure M-13 Occurrence of gray bat near Rowland Creek on Arnold Airforce Base 23 along Transmission Line Corridor L5702 in Tennessee ................................... M-91 24 Figure M-14 Critical habitats for the purple bean and spotfin chub along Transmission 25 Corridors L5204 and L5205 in Tennessee........................................................ M-92 26 Figure M-15 Critical habitats for various aquatic species along Transmission Corridor 27 L5624 in Tennessee ......................................................................................... M-93 28 Figure M-16 Critical habitat for the fluted kidneyshell along Transmission Corridor 29 L5186 in Tennessee. ........................................................................................ M-94 30 Figure M-17 Critical habitats for various aquatic species along Transmission Corridor 31 L5882 in Tennessee ......................................................................................... M-95 32 Figure M-18 Critical habitat for the fluted kidneyshell along Transmission Corridor 33 L5957 in Tennessee ......................................................................................... M-96 34 Figure M-19 Occurrences of blackside dace and location of critical habitat for the 35 Cumberland elktoe along Transmission Corridor L5125 in Kentucky ............... M-97 36 M-6

1 TABLES 2 Table M-1 Extent of Habitat Types on the CRN Site and in the BTA ................................. M-19 3 Table M-2 Type, Condition, and Size of Wetlands on the CRN Site and in the BTA ......... M-22 4 Table M-3 Offsite Transmission Lines where Upgrades Would Occur and Related 5 Information Based on TVA-Provided GIS Files................................................. M-30 6 Table M-4 Habitat Types and Land-Cover Types that Would Be Disturbed by 7 Developing the CRN Site and BTA ................................................................... M-33 8 Table M-5 Affected Wetlands on the CRN Site ................................................................. M-37 9 Table M-6 Species and Critical Habitats Considered in this BA for the CRN Site and 10 Vicinity in Roane County, Tennessee ............................................................... M-50 11 Table M-7 Number of Acoustic Recordings by Species and Year ..................................... M-53 12 Table M-8 Federally Listed Species in the Counties where Upgrades of Offsite 13 Transmission Lines May Occur......................................................................... M-67 14 Table M-9 Tennessee Natural Heritage Program Locations of Federally Listed 15 Species within 0.125 Mi of the Transmission Line Segments Identified for 16 Upgrade in Tennessee .................................................................................... M-72 17 Table M-10 Habitat Preferences for the Species Known to Occur in the Counties 18 Containing the Transmission Lines Identified by TVA for Possible Upgrade .... M-74 19 Table M-11 Effect Determinations for Federally Listed Species and FWS Requested 20 Species from Building and Operating the Proposed SMRs at the CRN Site .. M-115 21 M-7

1 ABBREVIATIONS/ACRONYMS 2 7Q10 7-day average flow that occurs every 10 years 3 ac acre(s) 4 BA biological assessment 5 BMP best management practice 6 BTA barge/traffic area 7 CFR Code of Federal Regulations 8 cfs cubic feet per second 9 COL combined construction permit and operating license 10 CP Construction Permit 11 CRBR Clinch River Breeder Reactor 12 CRM Clinch River mile 13 CRN Clinch River Nuclear 14 CWA Clean Water Act 15 CWS cooling-water system 16 17 dB decibel(s) 18 dBA A-weighted decibel(s) 19 DBH diameter at breast height 20 DOE U.S. Department of Energy 21 EIS environmental impact statement 22 EPA U.S. Environmental Protection Agency 23 ER environmental report 24 ESA Endangered Species Act of 1973, as amended 25 ESP Early Site Permit 26 ESWEMS Essential Service Water Emergency Makeup System 27 ESWS Essential Service Water System 28 FR Federal Register 29 ft foot/feet 30 fps feet per second 31 FWS U.S. Fish and Wildlife Service 32 GEIS generic environmental impact statement 33 GIS geographic information system 34 ha hectare(s) 35 36 IBCF Indiana Bat Conservation Fund 37 in. inch(es) 38 IPaC Information for Planning and Consultation M-8

1 JPA joint permit application 2 kg kilogram(s) 3 kV kilovolt(s) 4 Mgd million gallons a day 5 mi mile(s) 6 mo month(s) 7 NLEB northern long-eared bat 8 NRC U.S. Nuclear Regulatory Commission 9

10 OL Operating License 11 ORNL Oak Ridge National Laboratory 12 ORR Oak Ridge Reservation 13 14 PEM palustrine emergent 15 PEP protection and enhancement plan 16 PFO palustrine forested 17 PNNL Pacific Northwest National Laboratory 18 PPE plant parameter envelope 19 PRT potential roost tree(s) 20 PSS palustrine shrub-scrub 21 22 SMR small modular reactor 23 SMZ streamside management zones 24 SWPP storm water pollution prevention plan 25 26 TDEC Tennessee Department of Environment and Conservation 27 TDS total dissolved solids 28 TVA Tennessee Valley Authority 29 USACE U.S. Army Corps of Engineers 30 U.S.C. United States Code 31 32 WNS white nose syndrome 33 WSDOT Washington State Department of Transportation 34 yr year(s) 35 M-9

1 M.1 Proposed Action 2 On May 12, 2016, the U.S. Nuclear Regulatory Commission (NRC) received an application, 3 pursuant to Title 10 of the Code of Federal Regulations (CFR) Part 52 (TN251), from the 4 Tennessee Valley Authority (TVA), for an early site permit (ESP) for a site in Oak Ridge, Roane 5 County, Tennessee. TVA anticipates using the site to build and operate two or more small 6 modular reactors (SMRs) that have a maximum total electrical output of 800 megawatts electric 7 (MW(e)) to demonstrate SMR technology (TVA 2016-TN5002). An ESP makes it possible to 8 evaluate and resolve safety and environmental issues related to siting prior to seeking a 9 combined construction permit and operating license (COL) to construct and operate a reactor 10 under 10 CFR Part 52 or a construction permit (CP) and operating license (OL) under 10 CFR 11 Part 50 (TN249). Construction activities are a specific subset of building activities and are 12 defined by the NRC in their regulations in 10 CFR 51.4. The ESP and COL (or CP and OL) are 13 separate major Federal actions. If an ESP is approved, TVA can bank the Clinch River 14 Nuclear (CRN) Site for up to 20 years for future reactor siting. An ESP does not, however, 15 authorize construction and operation of a nuclear power plant. TVA may eventually seek to 16 obtain the necessary authorization to construct and operate two or more SMRs that have a 17 maximum total electrical output of 800 MW(e) to demonstrate the capability of SMR technology.

18 The proposed NRC action related to the TVA application is the issuance of an ESP for the CRN 19 Site as suitable for the future demonstration of the construction and operation of two or more 20 SMR units with characteristics that fit within the plant parameter envelope (PPE) that is 21 described in the ESP application. TVAs application is based on a PPE that encompasses four 22 light water SMRs under development in the United States at the time the application was 23 prepared (BWX Technologies, Holtec, NuScale Power, and Westinghouse [TVA 2016-24 TN5002]). The PPE provides bounding parameters and characteristics of the reactors and the 25 associated facilities so that an assessment of site suitability can be made.

26 The NRC is currently preparing an environmental impact statement (EIS) as a basis for 27 assessing site suitability and its decision about whether to issue an ESP. The Nashville District, 28 Regulatory Division of the U.S. Army Corps of Engineers (USACE) is a cooperating agency with 29 the NRC in preparing the EIS. The USACE plans to rely on the EIS to support its decision 30 about whether to issue Department of the Army permits (Section 10 and Section 404), if TVA 31 submits a Department of the Army permit application at a future date.

32 A regional map depicting the CRN Site is provided in Figure M-1. The CRN Site is located 33 adjacent to the U.S. Department of Energy (DOE) Oak Ridge Reservation (ORR) on property 34 owned by TVA in Roane County, Tennessee (Figure M-1 and Figure M-2).

M-10

1 2 Figure M-1. Location of the CRN Site and Areas within a 50-Mi Radius M-11

1 2 Figure M-2. Area Surrounding the CRN Site M-12

1 The NRC and the USACE have prepared this biological assessment (BA) to support a joint 2 consultation with the U.S. Fish and Wildlife Service (FWS) in accordance with Section 7 of the 3 Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. § 1531 et seq.-TN1010). The 4 BA is organized as follows.

5 Section M.1 Introduction. Provides background information regarding the reason for 6 producing the BA.

7 Section M.2 Consultation. Outlines the history of communications between the NRC and 8 USACE staffs and the FWS.

9 Section M.3 CRN Site and Possible Future Facilities Description. Describes the collective 10 environmental baseline for potentially affected terrestrial and aquatic resources. Also briefly 11 describes the facilities that may be built if TVA pursues a COL or CP and OL.

12 Sections M.4 and M.5 Building Impacts and Operation Impacts. Evaluates the possible 13 collective impacts on terrestrial and aquatic biota from building and operating facilities at the 14 CRN Site.

15 Section M.6 - Species Description/Environmental Baseline. Provides life history information 16 and describes baseline conditions for each potentially occurring listed species and critical 17 habitat.

18 Section M.7 Potential Effects on Species and Habitats. Evaluates the potential effects 19 from building and operating SMRs and related facilities on individual species within relevant 20 Action Areas and critical habitats regulated under the ESA.

21 Section M.8 Cumulative Effects. Evaluates potential cumulative impacts on listed species 22 and critical habitats.

23 Section M.9 Conclusions. Summarizes the conclusions drawn by the NRC and USACE 24 staff regarding potential effects on each listed species and critical habitat addressed in the 25 BA.

26 Section M.10 References. Provides a list of references cited in the BA.

27 Section M.11 Contributors. Provides a list of contributors to the BA.

28 M.2 Consultation History 29 In a letter dated April 20, 2017, the NRC requested that the FWS Field Office in Cookeville, 30 Tennessee, provide information regarding Federally listed, proposed, and candidate species 31 and critical habitat that may occur in areas potentially affected by building and operating SMRs 32 at the CRN Site and associated offsite facilities (NRC 2017-TN5089). The FWS provided a 33 response on May 5, 2017 (FWS 2017-TN5090), and an updated response on July 20, 2017 34 (FWS 2017-TN5091). The updated FWS letter contains recommended lists of species and 35 critical habitats to be considered in this BA. A representative of the FWS attended a site audit in 36 May 2017 at which a team of interdisciplinary staff from the NRC and the USACE met with 37 interdisciplinary TVA staff at the CRN Site to tour the site and ask technical questions about 38 possible environmental impacts (NRC 2018-TN5386).

M-13

1 The FWS contacted Pacific Northwest National Laboratory (PNNL) (NRCs environmental 2 contractor for review of the ESP application) by telephone on October 23, 2017, to outline topics 3 for an upcoming conference call. On October 24, 2017, the conference call was convened 4 between representatives of NRC, FWS, and PNNL to coordinate initiation of the BA. Topics 5 discussed included Action Areas, the CRN project design, species and habitats, offsite 6 transmission lines, blasting and demolition, nearby caves, and use of Natural Heritage Program 7 data to augment information in the FWS July 20, 2017 letter (FWS 2017-TN5091). On 8 November 2, 2017, PNNL representatives informed FWS by telephone of its intent to use 9 geographic information system (GIS) data as the basis for evaluating a series of possible 10 upgrades to existing offsite overhead transmission lines in TVAs service territory. The FWS 11 indicated that they preferred that PNNL use this approach.

12 Pursuant to Section 7(c) of the ESA (16 U.S.C. § 1531 et seq.-TN1010), this BA examines 13 whether the considered species and critical habitats may be affected by building and operating 14 a nuclear plant at the CRN Site and any associated offsite facilities. The review team, 15 comprising terrestrial and aquatic biologists, preparing this BA plans to continue to 16 communicate frequently and regularly with the FWS staff as FWS reviews the BA and 17 completes the Section 7 consultation process. This BA is prepared based on a conceptual 18 design of future SMR nuclear plants at the CRN Site that TVA describes in the ESP application 19 it submitted to the NRC. The NRC and USACE expect that they will eventually prepare a 20 subsequent BA if and when TVA decides to apply for a COL or CP that would authorize TVA to 21 construct and operate the reactors at the CRN Site.

22 M.3 Clinch River Nuclear Site and Possible Future Facilities 23 Description 24 The CRN Site is located in the southwestern part of the City of Oak Ridge, Tennessee, on a 25 tract of undeveloped property owned by TVA in Roane County, Tennessee. The TVA Oak 26 Ridge property comprises approximately 1,200 ac situated just south and west of the ORR on a 27 peninsula in the Clinch River arm of Watts Bar Reservoir (Figure M-3). The property includes 28 the 935-ac CRN Site as well as the 265-ac Grassy Creek Habitat Protection Area, which is not 29 planned for development and hence is not included within the CRN Site (Figure M-3) 30 (TVA 2017-TN4921).

31 Possible future CRN activities consist of the following components:

32 Building and operating SMRs with characteristics that fit within the PPE and associated 33 facilities and infrastructure on the CRN Site (Figure M-3). Building activities at the CRN Site 34 would permanently disturb approximately 326 ac and temporarily disturb approximately 35 167 ac on the site. It would also include the installation and operation of an intake and a 36 discharge structure.

37 Refurbishing and operating an inactive barge terminal and building and operating road 38 facilities on undeveloped ORR lands, termed the barge/traffic area (BTA), situated 39 immediately north of the CRN Site (Figure M-3). Building activities would permanently 40 disturb approximately 30 ac and temporarily disturb approximately 15 ac in the BTA.

M-14

1 2 Figure M-3. CRN Site, BTA, and Proposed New Facilities and Plant Layout M-15

1 Installing an underground 69-kv transmission line from the CRN Site east to the Bethel 2 Valley Substation on the ORR (Figure M-2). Building the underground transmission line 3 would temporarily disturb approximately 210 ac of land off of the CRN Site, situated entirely 4 within an existing right-of-way for an existing 500-kV overhead transmission line.

5 Upgrading (rebuilding, uprating, or reconductoring) multiple existing offsite overhead 6 transmission line segments within TVAs service territory (Figure M-4) to prepare the TVA 7 transmission line grid to receive power generated at the CRN Site.

8 In this BA, the NRC and the USACE review team evaluates the potential effects from 9 (1) building and operating SMRs at the CRN Site, (2) transportation improvements in the BTA, 10 (3) building and operating the 69-kV underground transmission line, and (4) the offsite overhead 11 transmission line upgrades. The review team discusses potential direct and indirect effects on 12 species and habitats in Section M.7 of this BA. Section M.7 also identifies specific action areas 13 where effects on terrestrial and aquatic species may occur.

14 Figure M-3 depicts a plan view of the possible future CRN facilities on the CRN Site and in the 15 BTA. The inactive barge terminal is situated on the ORR at CRM 14.1, near the entrance to the 16 northwest corner of CRN Site and Bear Creek Road. TVA anticipates refurbishing the barge 17 terminal by improving the existing retaining wall and installing bollards or mooring cells to 18 secure barges at the terminal. TVA plans to use the barge terminal to offload materials or 19 equipment for overland transport across the BTA to the CRN Site.

20 TVA expects to dig an open trench to install the 69-kV underground transmission line and to 21 subsequently backfill the trench, but it plans to explore the possibility of boring the trench 22 beneath streams and wetlands traversed by the route if possible to avoid disturbance of those 23 features (TVA 2017-TN4921).

24 Most of the offsite overhead transmission line right-of-way segments subject to upgrading are 25 situated in Tennessee, but some are situated in southern Kentucky or northern Georgia 26 (Figure M-4).

27 Section M.3.1 describes terrestrial and aquatic habitats potentially affected by activities at the 28 CRN Site, BTA, and vicinity. Section M.3.2 describes habitats potentially affected by upgrading 29 the offsite transmission lines. Section M.3.3 describes the possible future CRN facilities.

30 M-16

M-17 1

2 Figure M-4. Affected Offsite TVA Transmission Corridors (Source: TVA 2017-TN4921)

1 M.3.1 CRN Site and Vicinity 2 The sections below describe baseline terrestrial and aquatic resources on the CRN Site, in the 3 BTA, and in the vicinity.

4 M.3.1.1 Upland Habitats 5 The CRN Site lies in the Ridge and Valley Ecoregion, which extends from the Saint Lawrence 6 Valley in southeastern New York southwest through the Gulf Coastal Plain in Alabama. The 7 ecoregion is about 40 mi wide in eastern Tennessee and is characterized by alternating forested 8 ridges and agricultural valleys that have a variety of geologic materials containing numerous 9 springs and caves (EPA 2013-TN5033; Tucci 1992-TN5034; USGS 2016-TN5035; Woods et al.

10 1999-TN1805; Woods et al. 2003-TN1806). The CRN Site spans two subdivisions of the Ridge 11 and Valley Ecoregion: (1) Southern Limestone/Dolomite Valleys and Low Rolling Hills and 12 (2) Southern Dissected Ridges and Knobs (USGS 1998-TN5159). The latter subdivision covers 13 only the southeastern corner of the CRN Site (EPA 2004-TN5158). The former subdivision 14 covers the remainder of the CRN Site (EPA 2004-TN5158). Three land-cover types dominate 15 the ecoregion: (1) forest (56 percent), (2) agriculture (about 30 percent), and (3) developed 16 areas (about 9 percent) (USGS 2016-TN5035).

17 The CRN Site topography includes a series of roughly parallel ridges with elevations ranging 18 from about 860 to 940 ft above mean sea level (MSL). Several small drainages extend from the 19 ridges to the Clinch River. The southeastern portion of the peninsula is relatively flat, with a few 20 small hills, and an elevation of around 780 ft MSL. The northeastern portion of the CRN Site 21 consists of interspersed hills and valleys with elevations ranging from approximately 780 MSL to 22 940 MSL (TVA 2017-TN4921).

23 The CRN Site history has influenced the current terrestrial resource baseline on the site. Some 24 of the low elevation areas between the ridges onsite appear in aerial photography to have been 25 farmed prior to 1939 (TVA 2017-TN4920). The ORR was established in 1942 and then included 26 what is now the 1,200-ac TVA Clinch River property, after which farming was discontinued 27 throughout the ORR, including what is now the CRN Site (DOE 2017-TN5081). The 1,200-ac 28 Clinch River property, including the CRN Site, was transferred to TVA in the late 1970s for the 29 purpose of building and operating the Clinch River Breeder Reactor (CRBR) (TVA 2017-30 TN4921; BRC 1985-TN5245). Aerial photography from 1983 (TVA 2017-TN4920) indicates the 31 southern portion of the CRN Site was substantially altered by initial construction of the CRBR, 32 starting with site preparation and excavation in 1982, when about 240 ac were cleared and 33 grubbed (TVA 2017-TN4920) and about 1.5 million cubic yards of rock were removed and used 34 as structural fill or spoil. The 240 ac comprise part of the permanently cleared area shown in 35 Figure M-3. Construction of the CRBR ceased in 1983 prior to completion (TVA 2017-TN4921; 36 BRC 1985-TN5245). Redress for future industrial use was implemented (DOE et al. 1984-37 TN5221) and consisted of (1) reconfiguring rock to make the site self-draining and directing 38 runoff from compacted soils to five onsite treatment ponds and (2) stabilizing soil and spoils via 39 reseeding disturbed areas with herbaceous species. Some areas were replanted with pine 40 seedlings (DOE 1984-TN5282). The CRBR footprint is currently in a state of early old-field 41 succession. The CRN Site is also traversed by two existing overhead transmission lines 42 (Figure M-3).

M-18

1 TVA surveyed and mapped plant communities on the CRN Site in 2011 and 2013 (Cox et 2 al. 2015-TN5193). TVA surveyed plant communities in the BTA in May 2015 but did not field 3 map them (Cox et al. 2015-TN5193). The surveys covered all lands included in the expected 4 land-clearing footprint. TVA identified 178 plant species in the field surveys (Cox et al. 2015-5 TN5193). Table M-1 lists plant communities across the CRN Site based on land-use/land-cover 6 data modified by field mapping, and across the BTA based on land-use/land-cover data 7 (NASS 2017-TN5144). Forest cover on the CRN Site and in the BTA consists mostly of 8 deciduous forest (Table M-1) (TNC 2003-TN5036). Figure M-5 depicts the distribution of plant 9 communities across the CRN Site and BTA.

10 Table M-1. Extent of Habitat Types on the CRN Site and in the BTA Habitat Type CRN Site (ac)(a) BTA (ac)(b)

Mixed Evergreen-Deciduous Forest 389 3 Deciduous Forest 279 117 Scrub-Shrub/Herbaceous 202 --

Evergreen Forest 32 6 Wetlands 16 8 Grass/Pasture -- 14 Roads/Developed Areas 14 42 Ponds/Open Water 3 12 Shrubland -- 1 Barren -- 1 Total 935 204 (a) Habitat types and acreages on the CRN Site are based on the interpretation of aerial imagery, in conjunction with the descriptions of vegetation communities, wetlands, and waterbodies provided by field surveys (TVA 2017-TN5226).

(b) Habitat types and acreages in the BTA are based on 2016 land-use/land-cover data (NASS 2017-TN5144).

11 Following are descriptions of specific upland plant communities/habitat types on the CRN Site.

12 Where such occur in the BTA (Table M-1), they are similar to those on the CRN Site. Note that 13 the grass/pasture habitat category listed in Table M-1 for the BTA is similar to the shrub-14 scrub/herbaceous community listed for the CRN Site and described below.

15 M.3.1.1.1 Mixed Evergreen-Deciduous Forest 16 Mixed evergreen-deciduous forest is dominated by oaks (black [Quercus velutina], chestnut 17 [Q. montana], northern red [Q. rubra], southern red [Q. falcata], and white [Q. alba]); hickories 18 (mockernut [Carya tomentosa], pignut [C. glabra], and shagbark [C. ovata]); and Virginia pine 19 (Pinus virginianus), with sparse eastern red cedar (Juniperus virginiana). Blackgum (Nyssa 20 sylvatica), muscle wood (Carpinus caroliniana), and sourwood (Oxydendrum arboreum) are 21 common species found in the understory, which also is home to a variety of herbaceous species 22 listed by Cox et al. (2015-TN5193).

M-19

1 2 Figure M-5. Plant Communities and Habitat Types across the CRN Site and BTA. CRN 3 Site data are based on aerial imagery modified by descriptions of vegetation 4 communities, wetlands, and waterbodies provided by field surveys 5 (TVA 2017-TN5226). BTA data based on 2016 land-use/land-cover data 6 (NASS 2017-TN5144).

M-20

1 M.3.1.1.2 Deciduous Forest 2 Deciduous forest is dominated by tulip poplar (Liriodendron tulipifera) and includes American 3 beech (Fagus grandifolia), white oak, and yellow buckeye (Aesculus flava). The understory is 4 varied and includes a variety of shrub and herbaceous species (Cox et al. 2015-TN5193). A 5 subtype of deciduous forest, calcareous forest, occurs in areas underlain by limestone, mostly in 6 the Grassy Creek Habitat Protection Area (situated on TVA property immediately north of the 7 CRN Site) and a few mesic slopes adjacent to the Clinch River. Additional woody species in 8 this subtype include bladdernut (Staphylea trifolia), eastern red cedar, and eastern redbud 9 (Cercis canadensis) and a variety of herbaceous species (Cox et al. 2015-TN5193).

10 M.3.1.1.3 Evergreen Forest 11 Evergreen forest consists of remnant loblolly pine (Pinus taeda) and white pine (Pinus strobus) 12 plantations (Cox et al. 2015-TN5193). This forest likely comprises remnant pine seedlings 13 planted when the CRBR footprint was redressed (noted above).

14 M.3.1.1.4 Scrub-Shrub/Herbaceous 15 The scrub-shrub/herbaceous community comprises approximately 240 ac previously cleared of 16 forest for the CRBR (part of the herbaceous community on the CRN Site depicted in Figure M-5) 17 (Cox et al. 2015-TN5193). Some of this land was revegetated with non-native herbaceous 18 species such as sericea lespedeza (Lespedeza cuneata) and tall fescue (Schedonorus 19 arundinaceus). These areas likely lack natural topsoil and soil horizons because of prior 20 disturbance for the CRBR and are thus still slowly undergoing early forest succession and still 21 support a number of old-field species and eastern red cedar seedlings and saplings (Cox et 22 al. 2015-TN5193).

23 Habitat within the existing 500-kV overhead transmission line right-of-way where the 69-kV line 24 would be buried consists entirely of scrub-shrub/herbaceous vegetation similar to that described 25 above for the CRN Site and BTA (TVA 2017-TN4921, TVA 2016-TN5145). It is typical of 26 maintained transmission line right-of-ways in the region. Habitat adjacent to the existing Bethel 27 Valley Substation (Figure M-2) where the buried 69-kV line would tie in (TVA 2017-TN4921, 28 TVA 2016-TN5145) consists of similar scrub-shrub/herbaceous vegetation.

29 M.3.1.2 Wetland Habitats 30 TVA delineated wetlands using routine USACE procedures (USACE 1987-TN2066, 31 USACE 2010-TN5325). TVA used its Rapid Assessment Method to assess wetland indicator 32 functions (Mack 2001-TN5289) that differentiate wetlands based on three condition categories 33 (Pilarski-Hall and Lees 2015-TN5299). Category 1 wetlands are limited quality waters 34 because they are degraded, have limited potential for restoration, and have relatively low 35 functionality. Category 2 includes wetlands of moderate quality that are degraded but exhibit 36 reasonable potential for restoration. Category 3 generally includes wetlands of very high quality 37 or of concern regionally and/or statewide, such as wetlands that provide habitat for threatened 38 or endangered species (Pilarski-Hall and Lees 2015-TN5299).

M-21

1 TVA delineated 12 wetlands on the CRN Site between January and May 2011 (Pilarski-Hall and 2 Lees 2015-TN5299) (Figure M-5 and Table M-2). The USACE verified this wetland delineation 3 in September 2013 (Pilarski-Hall and Lees 2015-TN5299). TVA delineated five wetlands in the 4 BTA in April 2015 (Figure M-5 and Table M-2) (Pilarski-Hall and Kennon 2015-TN5290). Most 5 wetland acreage on the CRN Site is forested (Table M-2). Most forested wetlands occur along 6 the reservoir shoreline and in the riparian areas of tributaries. Most wetland acreage in the BTA 7 supports scrub-shrub vegetation, situated as narrow strips along streams within pronounced 8 valleys and swales.

9 Table M-2. Type, Condition, and Size of Wetlands on the CRN Site and in the BTA.

10 Adapted from TVA (Pilarski-Hall and Lees 2015-TN5299; Pilarski-Hall and 11 Kennon 2015-TN5290).

Wetland TVA Condition Number Wetland Type(a) Category(b) Size (ac)

CRN Site W001 PF01E 2 0.67 W002 PEM1E 1 0.13 W003 PF01E 2 0.18 W004 PF01E 2 0.24 W005 PF01E 2 0.36 W006 PEM1E/PSS1E 2 0.11 W007 PSS1E/PF01E 2 0.17 W008 PF01E 2 0.23 W009 PEM1E/PSS1E/PFO1E 3 5.66 W010 PEM1E/PSS1E/PFO1E 2 1.79 W011 PF01E 3 5.87 W012 PEM1E 1 0.13 Total 15.54 BTA W013 PSS1E/PEM1E 2 3.73 W014 PSS1E/PEM1E 2 3.05 W015 PF01E 2 1.95 W016 PEM1E 2 0.11 W017 PSSHh 3 1.33 Total 10.17 (a) Classification codes as defined in Cowardin et al. 1979-TN5186: PEM1E = Palustrine emergent, persistent vegetation, seasonally flooded/saturated; PFO1E = Palustrine forested, broad-leaved deciduous vegetation, seasonally flooded/saturated; PSS1E =

Palustrine scrub-shrub, broad-leaved deciduous vegetation, seasonally flooded/saturated; PSSHh = Palustrine scrub-shrub, broad-leaved deciduous vegetation, permanently flooded, diked/impounded.

Category 1 = degraded; Category 2 = moderate quality; Category 3 = high quality 12 Following are brief descriptions of wetland plant communities on the CRN Site. Where such 13 occur in the BTA, they are similar to those on the CRN Site.

14 Forested wetland vegetation is generally dominated by tree species such as American 15 sycamore (Platanus occidentalis), silver maple (Acer saccharinum), green ash (Fraxinus 16 pennsylvanica), red maple (Acer rubrum), sweetgum (Liquidambar styraciflua), box elder M-22

1 (Acer negundo), and black willow (Salix nigra) that are common along the reservoir.

2 Forested wetland vegetation also includes a variety of shrub and herb species (Cox et 3 al. 2015-TN5193).

4 Scrub-shrub wetland vegetation is dominated by saplings of tree species such as green ash, 5 American sycamore, black willow, and red maple, and also includes a variety of shrub and 6 herb species (Pilarski-Hall and Kennon 2015-TN5290).

7 Emergent wetlands are dominated by squarestem spikerush (Eleocharis quadrangulata),

8 broad-leaf cattail (Typha latifolia), softstem bulrush (Schoenoplectus tabernaemontana), tall 9 fescue, and rushes (Juncus spp.), with small black willow amid the emergent vegetation 10 (Pilarski-Hall and Lees 2015-TN5299).

11 Most of the wetlands are small and of moderate quality (Pilarski-Hall and Lees 2015-TN5299).

12 M.3.1.3 Aquatic Habitats 13 Aquatic habitats in the project area of the CRN Site and vicinity include streams and ponds on 14 the CRN Site and in the BTA (TVA 2017-TN4921). They also include the streams crossed by 15 the proposed route for the 69-kV underground transmission line and the Clinch River arm of the 16 Watts Bar Reservoir from above the location of the intake at approximately CRM 17.9, on the 17 east side of the CRN Site to approximately CRM 14 just downstream of the barge-unloading 18 facility and approximately 1.5 mi downstream of the discharge (located at approximately 19 CRM 15.5 on the west side of the CRN Site).

20 TVA surveyed and mapped the locations of the waterbodies within the CRN Site using global 21 positioning system units in April and May of 2011 and October of 2013 and 2014. TVA 22 conducted additional surveys during October 2014 in the BTA (TVA 2017-TN4921). Howard 23 et al. (2015-TN5049) describe the waterbodies on the CRN Site and in the BTA, which are 24 depicted in Figure M-6. Each pond on the CRN Site is manmade, and all but one were 25 developed to serve as stormwater retention ponds for the CRBR (Howard et al. 2015-TN5049).

26 Two additional ponds were identified on the southeast edge of the BTA in the area that could be 27 affected by building activities. One is characterized as a large pond and the other as a small 28 pond connected to the backwater of the reservoir (TVA 2017-TN4921).

29 The streams on the CRN Site and BTA are classified as:

30 Perennial - 5 streams on the CRN Site and 2 in the BTA 31 Intermittent - 1 on the CRN Site and 4 in the BTA 32 Ephemeral - 19 on the CRN Site and 15 in the BTA.

33 During March 2015, TVA conducted biological surveys on four perennial and three intermittent 34 streams focusing on pools, riffles, and runs appearing likely to support communities of aquatic 35 biota. Surveys were conducted with a seine and a backpack electrofishing unit. Three of the 36 streams (S01, S05, and S06) were located in the CRN Site, and four (S07, S08, S09, and S12) 37 were in the BTA. An eighth stream, Grassy Creek, which is located close to the site but not 38 within the boundaries of the project, also was sampled. None of the surveys of onsite streams 39 or ponds identified any Federally protected species (TVA 2017-TN4921).

M-23

1 2 Figure M-6. Aquatic Features Documented within the Clinch River Site and Barge/Traffic 3 Area (Map from Howard et al. 2015-TN5049)

M-24

1 M.3.1.3.1 Streams Crossed by the Proposed Route for the 69-kV Underground 2 Transmission Line 3 The 69-kV underground transmission line route proposed by TVA crosses six streams in an 4 existing 500-kV transmission line corridor that runs from the Bethel Valley Substation to the 5 CRN Site. The streams include:

6 Ish Creek, a second-order tributary of the Clinch River that contains a 2.1-mi Aquatic 7 Natural Area. Ish Creek originates as a spring and flows toward the Clinch River 8 approximately 0.5 mi east of the site. Surveys conducted by Oak Ridge National Laboratory 9 (ORNL) (Baranski 2011-TN5164; ORNL 2017-TN5358) did not find any Federally protected 10 species.

11 White Oak Creek is a second- and third-order stream (depending on specific location), and 12 the Northwest Tributary consists of three first-order streams and part of a second-order 13 stream (Baranski 2011-TN5164). Two of these streams cross the right-of-way 14 approximately 2.0 to 2.5 mi east of the CRN Site (TVA 2017-TN4921). Studies did not 15 indicate the presence of any Federally protected species (Baranski 2011-TN5164).

16 Upper Fifth Creek, is located slightly southwest of the Bethel Valley Substation and is 17 characterized as a spring-fed, first-order stream. It is also part of the White Oak Creek 18 drainage. Sampling studies did not report any Federally protected species (Baranski 2011-19 TN5164).

20 Streams S03 and S06 are near the northwest corner of the CRN Site. Stream S06 is a 21 perennial stream, for which no fish or crayfish were reported during sampling studies.

22 Stream S03, an intermittent stream, was not sampled because of lack of water at the time of 23 the surveys (Henderson and Phillips 2015-TN5162).

24 M.3.1.3.2 Clinch River Arm of Watts Bar Reservoir 25 Watts Bar Reservoir, including the Clinch River arm, was impounded by Watts Bar Dam, 26 52 river miles downstream of the CRN site in 1942. The CRN Site is located approximately 27 4 mi downstream of Melton Hill Dam, which was completed in 1963. Approximately 57 mi 28 upstream from Melton Hill Dam is Norris Dam, which was built in 1936.

29 Historical impoundment of the Clinch River both below and above the CRN Site has greatly 30 altered the dynamics of river flow. For example, spring floods that once occurred along the river 31 no longer occur, and the expansive rocky or gravel shoals that once abounded in the 32 Tennessee River system no longer exist (Etnier and Starnes 1993-TN5054). In addition, 33 changes in water depth and temperature, reductions in the amount of dissolved oxygen, and 34 increased sedimentation have resulted from placement of dams. These changes have affected 35 or are continuing to affect biota and have resulted in detectable changes in the aquatic 36 ecosystem compared to pre-impoundment (NRC 2013-TN5165).

37 The assemblage of organisms living in the river has changed in response to the impoundments.

38 According to Parmalee and Bogan (1998-TN5166), 11 species of the unionid mussel genus 39 Epioblasma that once inhabited shoals and riffles in the Tennessee River and its tributaries are 40 now extinct. Parmalee and Bogan (1998-TN5166) attribute this to direct or indirect results of M-25

1 impoundment. As Neves and Angermeier (1990-TN5053) reported, obligate river species 2 typically do not survive in reservoirs. Further, they reported that, even though fish sampling on 3 the Tennessee River system was not extensive in the years before construction of the dams, 4 enough surveys were conducted to allow documentation of the adverse effects that 5 impoundment had on native fish species. For example, fish surveys conducted before and after 6 impoundment of Melton Hill Reservoir (as reported in 1968) showed a shift in fauna. Those 7 species requiring shoal and riffle habitats were no longer present in the post-impoundment 8 surveys (NRC 2013-TN5165).

9 The impoundments helped to create good reservoir fisheries for sport and commercial 10 fishermen. According to Etnier and Starnes (1993-TN5054), resource managers and others, 11 whether purposely or accidentally, have introduced other species (including nuisance species) 12 into the system. Nuisance species are those non-native species whose introduction causes, or 13 is likely to cause, economic or environmental harm.

14 The water temperature in the Clinch River arm of the Watts Bar Reservoir is affected by 15 operation of the Bull Run Fossil Plant located in the Melton Hill Reservoir in combination with 16 the operation of Norris and Melton Hill Dams. The thermal discharges from the Bull Run Fossil 17 Plant result in the thermal stratification of the Melton Hill Reservoir. This results in hourly water 18 temperature fluctuations of as much as 4°F between a monitor at CRM 22.6 (downstream of 19 Melton Hill Dam) and one further downstream at CRM 16.1 at the location of the proposed CRN 20 discharge (TVA 2017-TN4921).

21 There is hazardous and radioactive contamination of the sediments in the Clinch River from 22 above Melton Hill Reservoir (CRM 44) to the confluence of the Clinch River with the main stem 23 of the Tennessee River (CRM 0). As a result, the State of Tennessee has issued fish 24 consumption advisories for contaminants (polychlorinated biphenyls) for striped bass (Morone 25 saxatilis) with a precautionary advisory for catfish (Family Ictaluridae) and sauger (Sander 26 canadensis) as a result of polychlorinated biphenyls (TDEC 2016-TN5172).

27 TVA conducted benthic macroinvertebrate sampling in 2011 at two locations: CRM 15.0 28 (slightly downstream from the proposed discharge) and CRM 18.8 (approximately a mile 29 upstream of the proposed intake). Ten samples were taken at each location in May, July, and 30 October 2011. Between September 21 and 26, 2011, a mollusk and habitat survey was 31 conducted using semi-quantitative and qualitative sampling methods (TRC 2011-TN5168). A 32 total of 74 living native mussels were collected from six different species. No Federally 33 protected species including the pink mucket (Lampsilis abrupta) and the sheepnose mussel 34 (Plethobasus cyphyus) were identified in either survey. The survey of mollusks observed that 35 zebra mussels (Dreissena polymorpha) were found attached to 71 of the 74 living native 36 mussels. The average area of coverage on an individual mussel was 28 percent and coverage 37 ranged from 5 to 100 percent (TRC 2011-TN5168). The presence of zebra mussels is 38 detrimental to the survival of native mussels. Zebra mussels affect the growth and reproduction 39 of native mussels by competing for space and food, interfering with the native mussels ability to 40 open and close their shells, impairing movement of the native mussels, and depositing 41 metabolic wastes on native mussels (FWS 2015-TN5218).

M-26

1 Based on the sampling studies and the condition of the living native mussels it is unlikely that 2 either of the protected mussel species would be located in the Clinch River arm of the Watts Bar 3 Reservoir.

4 During 2011, TVA performed fish sampling studies at two sampling locations downstream 5 between CRM 14 and CRM 15 and upstream between CRM 18 and CRM 19.8 using 6 electrofishing and gillnetting techniques (TVA 2013-TN5167). Surveys were conducted during 7 the months of February, May, July, and October. No Federally protected fish species were 8 identified during the surveys.

9 M.3.2 Offsite Transmission Line Upgrades 10 Uplands within the overhead transmission line right-of-ways depicted in Figure M-4 mostly 11 comprise artificially maintained scrub-shrub/herbaceous vegetation similar to that described for 12 the 500-kV transmission line corridor where the new 69-kV line would be buried (Section 13 M.3.1.1). These offsite corridors may also intersect wetlands, streams, rivers, ponds, and 14 reservoirs, as well as possible upland features different from scrub-shrub/herbaceous 15 vegetation. Because TVAs identification of these corridors currently is conceptual and because 16 TVA has not identified where specific upgrades would occur, the locations of relevant wetlands 17 and waterbodies and upland habitats that differ from scrub-shrub/herbaceous, within the offsite 18 transmission line corridors, are not described in this BA.

19 M.3.3 Possible Future CRN Facilities 20 The 935-ac CRN Site currently is undeveloped and not used for power-generating activities.

21 Although TVA has not yet selected a specific reactor design, TVAs PPE provides bounding 22 parameters for a surrogate plant that a future selected SMR design is expected to fall within.

23 The four SMR technologies used to develop the PPE (Section M.1) all represent pressurized 24 water reactors with below-grade containment, passive containment cooling for the ultimate heat 25 sink, and closed-cycle wet cooling for the cooling-water system (CWS) (TVA 2017-TN4921, 26 TVA 2017-TN4922). The general layout is depicted as part of Figure M-3 and includes the 27 power block, turbine island, switchyard, cooling tower, independent spent fuel storage 28 installation areas, offsite road improvement areas, and the areas that would be permanently or 29 temporarily disturbed on and near the CRN Site.

30 The paragraphs below briefly describe CRN facilities that would have a major plant-environment 31 interface. Not all proposed facilities are described; many are omitted that do not comprise a 32 major part of the development footprint or have a major interface with the environment.

33 M.3.3.1 Power Block 34 Much of the developed portion of the CRN Site would comprise the power block, a densely built 35 area containing the proposed SMRs and containment, auxiliary buildings, and many other 36 operationally connected facilities. TVAs PPE value for the height of the tallest power-block 37 structure is 160 ft above plant grade. The power block would also be where the deepest 38 excavation occurs; the PPE value for the depth of the deepest excavation is 138 ft below plant 39 grade (TVA 2017-TN4922). The power block would be built in the southern portion of the CRN M-27

1 Site, largely in the area that was previously disturbed for the CRBR. Several large cranes would 2 be needed to install reactors on the CRN Site. The largest would be a 638-ft heavy-lift crane 3 used in the main plant area (TVA 2017-TN4922).

4 M.3.3.2 Cooling-Water System 5 Cooling water typically is obtained from a surface-water source; heat in the cooling water is 6 typically rejected to the atmosphere; and blowdown and liquid effluents typically are discharged 7 to the environment. The source of cooling water would be surface water from the Clinch River 8 arm of the Watts Bar Reservoir. A portion of the makeup water would be discharged to the 9 Clinch River, approximately 2.5 mi downstream of the cooling-water intake. The remaining 10 portion of the water would be released to the atmosphere via evaporative cooling through 11 mechanical draft cooling towers (TVA 2017-TN4921, TVA 2016-TN5018).

12 The location of the intake structure is indicated in Figure M-3 at CRM 17.9, on the east side of 13 the CRN Site. The intake design features are intended to keep the water velocity through the 14 dual-flow traveling screens at less than 0.5 fps to minimize impingement of fish or other aquatic 15 biota (TVA 2017-TN4921).

16 TVA anticipates that the intake structure would be approximately 50 ft long and 50 ft wide, with 17 four intake channels leading to four pump bays. Bar screens would prevent debris from 18 entering the intake channels and dual-flow traveling screens would prevent smaller debris from 19 reaching the pumps in the pump bays. The vertical height of the structure would be 20 approximately 25 ft with the top deck elevation above the 100-year flood elevation. The 21 riverbed near the shore would need to be deepened slightly to form a forebay between the face 22 of the intake and the main channel of the river so water would enter the intake system below the 23 minimum water level of the reservoir. However, the precise location of the intake and the depth 24 and amount of riverbed excavated would be included in any future CP or COL application 25 (TVA 2017-TN4921).

26 Liquid effluents from the plant would be transported via pipeline to a holding pond and then to 27 the discharge structure indicated in Figure M-3. The discharge would be built at approximately 28 CRM 15.5 on the west side of the CRN Site. The diffuser pipe would be partially buried, 29 requiring in-water excavation of the river bottom. Installation of the discharge also might require 30 excavation near the shoreline (TVA 2017-TN4921). Installation of the discharge would require 31 placement of two parallel 3-ft-diameter pipes that extend into the river at an elevation of about 32 720 ft, or 4 ft above the bottom at the offshore end. The conceptual design would have diffuser 33 ports on the downstream side of the last 12 to 15 ft of each pipe in order to effect a discharge 34 velocity of 8 to 10 fps. A vault containing instruments to monitor effluent flow and temperature 35 would be located upstream. Valves installed in each pipe would be used to control discharge 36 flow for mixing or exit velocity or for directing flow to one pipe if needed for maintenance 37 (TVA 2017-TN4921).

38 Approximately 0.5 mi of new pipeline would be laid to convey water from the intake structure to 39 the main plant area; approximately 0.4 mi of new pipeline would be laid to convey water from 40 the main plant area to the discharge pipe (TVA 2017-TN4920).

M-28

1 TVAs conceptual design calls for a currently unknown number of linear mechanical draft cooling 2 towers to dissipate heat from the CWS. The cooling towers would be located just west of the 3 power block (Figure M-3) and would be 65 ft or less in height.

4 M.3.3.3 Barge-Unloading Facility 5 TVA proposes to refurbish an existing but inactive barge terminal (Figure M-3). Materials or 6 equipment shipped by barge to the CRN Site would be offloaded at this terminal. Anticipated 7 refurbishment activities are improvements to the existing retaining wall, and installation of 8 bollards or mooring cells to secure barges at the terminal.

9 M.3.3.4 Melton Hill Dam Bypass 10 TVA proposes to add a bypass flow system (conduit) through an existing part of the Melton Hill 11 Dam structure to maintain a minimum flow of 400 cubic feet per second (cfs) independent of the 12 hydroelectric generating system.

13 M.3.3.5 Onsite Transmission System 14 Existing transmission lines serving the area of the CRN Site are 161-kV and 500-kV lines.

15 Anticipated changes and additions to the transmission system that would connect a potential 16 800-MW(e) plant at the CRN Site to the grid that distributes power to the TVA service territory 17 include (1) new onsite switchyards, (2) relocation of an existing 161-kV line within CRN Site 18 boundary, and (3) addition of a new 69-kV underground line within the existing 500-kV corridor 19 that extends from within the CRN Site to the Bethel Valley Substation. Changes 1 and 2 are 20 part of the CRN Site development footprint (Figure M-3). Change 3 would occur partially within 21 the CRN Site development footprint (Figure M-3) and partially offsite (Figure M-2).

22 M.3.3.6 Support and Laydown Areas 23 Construction-support and laydown areas (Figure M-3) would be established to support 24 fabrication and installation activities and might be maintained as laydown areas for future 25 maintenance of the plant (TVA 2017-TN4922).

26 M.3.3.7 Other Facilities 27 Other facilities would include a concrete batch plant, and radioactive waste management and 28 diesel generator buildings.

29 M.3.3.8 Offsite Transmission Line Upgrades 30 TVA has conceptually identified multiple specific segments of existing overhead transmission 31 line in eastern Tennessee and in parts of Kentucky and Georgia that may have to be upgraded 32 to accommodate power delivered to TVAs grid from SMRs at the CRN Site.

33 In its environmental report (ER), TVA tabulated the total length of transmission line segments to 34 be uprated, reconductored, or rebuilt as approximately 191 mi, 122 mi, and 13 mi, respectively, 35 totaling about 326 mi (TVA 2017-TN4921). However, TVA subsequently provided spatial data 36 M-29

1 that indicated the segment lengths to be uprated or reconductored could be up to 215 and 2 212 mi, respectively, totaling 440 mi inclusive of the 13-mi line that would be rebuilt (TVA 2017-3 TN4920) (Table M-3).

4 The routes for each segment identified for possible upgrade by TVA are shown in Figure M-4.

5 Table M-3 lists each segment and the type of upgrade proposed by TVA. Rebuilds involve 6 building new transmission poles or towers and installing new conductors within an existing right-7 of-way. Reconductoring involves installing new conductors on existing poles or towers within an 8 existing right-of-way. Uprating a transmission line involves replacing conductors on existing 9 poles or towers within an existing right-of-way with new conductors capable of carrying a higher 10 voltage than the replaced conductors. These and related upgrade activities are described in 11 greater detail in Section M.4.2.

12 Table M-3. Offsite Transmission Lines where Upgrades (Uprate, Reconductor, Rebuild) 13 Would Occur and Related Information Based on TVA-Provided GIS Files Length Engineering State County Line Segment(s) (mi) Solution Georgia Catoosa L5697 141 - 154 5.92 Reconductor Kentucky Bell L5125 448 - 212 12.09 Reconductor Kentucky Whitley L5125 448 - 212 8.05 Reconductor Tennessee Anderson L5125 448 - 212 1.25 Reconductor Tennessee Anderson L5235 82 - 128 3.54 Reconductor Tennessee Anderson L5235 82 - 128 0.60 Reconductor Tennessee Anderson L5280 86 - 119 1.48 Reconductor Tennessee Anderson L5280 86 - 119 0.60 Reconductor Tennessee Anderson L5659 1 to 55 4.46 Reconductor Tennessee Anderson L5882 298A & 298-310 2.74 Reconductor Tennessee Anderson L5882 298A & 298-310 0.04 Reconductor Tennessee Anderson L5882 298A & 298-310 0.04 Reconductor Tennessee Anderson L5882 298A & 298-310 13.89 Reconductor County Total 28.63 Tennessee Bledsoe L5173 1-182A & 182A - 40 16.54 Uprate Tennessee Bledsoe L5173 1-182A & 182A - 40 3.91 Uprate County Total 20.45 Tennessee Campbell L5125 448 - 212 12.66 Reconductor Tennessee Campbell L5125 448 - 212 10.83 Reconductor Tennessee Campbell L5125 448 - 212 0.02 Reconductor Tennessee Campbell L5125 448 - 212 3.92 Reconductor County Total 27.42 Tennessee Claiborne L5125 448 - 212 2.43 Reconductor Tennessee Cocke L5957 51 - 181 & 1 - 50 4.37 Reconductor Tennessee Cocke L5957 51 - 181 & 1 - 50 7.98 Reconductor County Total 12.35 Tennessee Cumberland L5204 198A - 215 6.35 Reconductor Tennessee Cumberland L5204 198A - 215 6.09 Reconductor Tennessee Cumberland L5204 198A - 215 0.04 Reconductor Tennessee Cumberland L5204 198A - 215 3.90 Reconductor Tennessee Cumberland L5205 215-297 & A-G 17.43 Uprate Tennessee Cumberland L5205 215-297 & A-G 2.49 Uprate County Total 36.30 M-30

1 Table M-3. (contd)

Length Engineering State County Line Segment(s) (mi) Solution Tennessee Franklin L5167 941B-975 11.70 Uprate Tennessee Franklin L5702 1 9.15 Reconductor County Total 20.85 Tennessee Grainger L5186 E1 - E5 & 6 - 234 18.36 Uprate Tennessee Greene L5624 E1 - E39 & 40 & E35 & 192 - 84 8.25 Uprate Tennessee Greene L5624 E1 - E39 & 40 & E35 & 192 - 84 18.11 Uprate County Total 26.36 Tennessee Grundy L5167 941B-975 6.78 Uprate Tennessee Grundy L5167 941B-975 17.68 Uprate Tennessee Grundy L5167 941B-975 0.16 Uprate Tennessee Grundy L5167 941B-975 0.06 Uprate County Total 24.68 Tennessee Hamblen L5186 E1 - E5 & 6 - 234 1.45 Uprate Tennessee Hamblen L5624 E1 - E39 & 40 & E35 & 192 - 84 8.47 Uprate E136 - E120 & 120 - 164 & 164 Tennessee Hamblen L5940 - 185A 2.18 Uprate County Total 12.10 Tennessee Hamilton L5697 141 - 154 0.73 Reconductor Tennessee Hawkins L5186 E1 - E5 & 6 - 234 17.74 Uprate Tennessee Hawkins L5624 E1 - E39 & 40 & E35 & 192 - 84 4.10 Uprate County Total 21.85 Tennessee Jefferson L5624 E1 - E39 & 40 & E35 & 192 - 84 1.49 Uprate E136 - E120 & 120 - 164 & 164 Tennessee Jefferson L5940 - 185A 12.79 Uprate Tennessee Jefferson L5957 51 - 181 & 1 - 50 9.97 Reconductor Tennessee Jefferson L5957 51 - 181 & 1 - 50 8.90 Reconductor Tennessee Jefferson L5957 51 - 181 & 1 - 50 4.13 Reconductor County Total 37.29 Tennessee Knox L5092 120 - 212 12.57 Rebuild Tennessee Knox L5659 1 to 55 6.48 Reconductor County Total 19.05 Tennessee Putnam L5204 198A - 215 1.46 Reconductor Tennessee Rhea L5173 1-182A & 182A - 40 14.15 Uprate Tennessee Roane L5205 215-297 & A-G 1.87 Uprate Tennessee Roane L5235 82 - 128 0.24 Reconductor Tennessee Roane L5235 82 - 128 0.95 Reconductor Tennessee Roane L5280 86 - 119 0.28 Reconductor Tennessee Roane L5280 86 - 119 0.95 Reconductor Tennessee Roane L5743 150-208A 8.41 Reconductor Tennessee Roane L5743 150-208A 7.91 Reconductor Tennessee Roane L5743 150-208A 1.93 Reconductor Tennessee Roane L5743 150-208A 10.86 Reconductor Tennessee Roane L5743 150-208A 1.00 Reconductor Tennessee Roane L5743 150-208A 1.80 Reconductor Tennessee Roane L5743 150-208A 1.07 Reconductor Tennessee Roane L5743 150-208A 1.07 Reconductor M-31

Table M-3. (contd)

Length Engineering State County Line Segment(s) (mi) Solution County Total 38.34 Tennessee Scott L5882 298A & 298-310 2.68 Reconductor Tennessee Scott L5882 298A & 298-310 17.52 Reconductor County Total 20.20 Tennessee Sequatchie L5167 941B-975 7.02 Uprate Tennessee Sevier L5957 51 - 181 & 1 - 50 0.86 Reconductor Tennessee Van Buren L5173 1-182A & 182A - 40 15.71 Uprate Tennessee Warren L5173 1-182A & 182A - 40 1.05 Uprate Tennessee White L5173 1-182A & 182A - 40 5.65 Uprate Grand Total 439.35 1 M.4 Building Impacts 2 The discussion in this section provides an overview of potential impacts on terrestrial and aquatic 3 resources that could result from building the facilities discussed in the CRN Site PPE. Section 4 M.5 of this BA provides a complementary overview of potential impacts on terrestrial and aquatic 5 resources from operation of those facilities. Most information presented in these overview 6 sections is drawn from the review teams EIS to support its review of the ESP application.

7 Section M.7 of this BA provides an assessment of the potential effects on individual species and 8 habitats from the alteration of terrestrial and aquatic resources resulting from building and 9 operating the contemplated new facilities.

10 In a final rule dated October 9, 2007 (72 FR 57416-TN260), the NRC limited the definition of 11 construction to the activities that fall within its regulatory authority in 10 CFR Part 51.4 12 (TN250). Many of the site-preparation activities associated with building a nuclear power plant 13 are not part of the NRC action to license the plant. Activities that are associated with 14 construction, but that are not within the purview of the NRC action, are grouped under the term 15 preconstruction. Preconstruction activities include clearing and grading, excavating, erecting 16 support buildings and transmission lines, and other associated activities that lack a nexus to 17 nuclear safety. These preconstruction activities may take place before the application for a COL 18 is submitted, during the NRC staffs review of a COL application, or after a COL has been 19 granted. Although preconstruction activities are outside the NRCs regulatory authority, many of 20 the activities are within the regulatory authority of local, State, or other Federal agencies, 21 including the USACE. Because this is a joint BA for both the NRC and the USACE, the 22 distinction between construction and preconstruction is not carried forward in this BA; both are 23 jointly discussed using the term building.

24 M.4.1 CRN Site and Vicinity 25 This section provides information about the impacts on baseline terrestrial and aquatic 26 resources described in Section M.3.1 from site preparation and development activities on the 27 CRN Site, in the BTA, and within the existing 500-kV transmission line corridor where the new 28 69-kV transmission line would be buried.

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1 M.4.1.1 Upland Habitats 2 Building activities would start with land clearing and site preparation work on the CRN Site and 3 development of the barge facility and haul road in the BTA. The land-clearing and site 4 preparation phase would continue for about 1 year, during which time most impacts on 5 terrestrial habitats, including wetlands, would have taken place. Activities to further excavate 6 and develop the site and erect structures such as the intake, discharge and the support and 7 safety-related facilities would occur over a subsequent period of 4 to 5 years. (TVA 2017-8 TN4921).

9 Approximately 494 ac of the CRN Site and 45 ac of the BTA (approximately 539 ac total) would 10 be disturbed by building activities (Table M-4). The affected areas include approximately 327 ac 11 on the CRN Site and 30 ac in the BTA that would be permanently occupied by facilities over the 12 life of the project (Table M-4). The affected areas also include about 167 ac on the CRN Site 13 and about 15 ac in the BTA that would be only temporarily disturbed (Table M-4) (TVA 2017-14 TN4920). Figure M-7 is an overlay showing terrestrial habitats permanently and temporarily 15 cleared on the CRN Site and in the BTA. By making the maximum possible use of the existing 16 CRBR footprint, TVA has designed the building-activity footprint to minimize impacts on forest 17 and wetlands. Approximate affected acreages by habitat type/land cover on the CRN Site and 18 BTA are provided in Table M-4.

19 Table M-4. Habitat Types and Land-Cover Types that Would Be Disturbed by Developing 20 the CRN Site and BTA. Obtained from information provided by TVA (2017-21 TN4920).

Approximate Approximate Acreage Acreage Location/Habitat Types/ Permanently Temporarily Total Acreage Land-Cover Types Affected Affected Affected CRN Site Herbaceous/Grassland 152 41 193 Mixed Evergreen-Deciduous Forest 106 90 196 Deciduous Forest 53 19 72 Roads/Developed Areas (Existing) 13 -- 13 Evergreen Forest 3 17 20 Total 327 167 494 Barge Traffic Area Herbaceous/Grassland 1 1 2 Deciduous Forest 9 14 23 Roads/Developed Areas (Existing) 20 -- 20 Total 30 15 45 M-33

1 2 Figure M-7. CRN Site and BTA Development Footprint Overlaid on Terrestrial Habitat 3 Types M-34

1 M.4.1.1.1 Forest 2 Clearing would remove about 196 ac of mixed evergreen-deciduous forest on the CRN Site and 3 none in the BTA (Table M-4). Clearing would remove about 72 ac on the CRN Site and about 4 23 ac of deciduous forest in the BTA (Table M-4). About 20 ac of evergreen forest would be 5 cleared on the CRN Site and none in the BTA (Table M-4). The potentially affected evergreen 6 forest likely consists of remnant pine plantings from when the CRBR footprint was redressed 7 (discussed in Section M.3.1) (DOE 1984-TN5282). Of these impacts, 171 ac would be 8 permanent, and 140 ac would be temporary (Table M-4). Clearing forest would reduce the 9 extent of and fragment forest on the CRN Site and in the BTA. The overall forest impacts of 10 311 ac represent 0.7 percent of forest occurring in the 6-mi vicinity (Figure M-8).

11 Building the intake and discharge structures (Figure M-3) along the reservoir shoreline (the 12 Clinch River) would require removal of a relatively small patch of riparian vegetation within the 13 footprint of each structure. No riparian vegetation would be cleared to reactivate the existing 14 barge facility, and improvements to that facility would not require substantial additional clearing 15 of shoreline riparian vegetation.

16 M.4.1.1.2 Non-Forest Vegetation 17 Approximately 195 ac of herbaceous/grassland and old-field vegetation on the CRN Site and in 18 the BTA would be disturbed (Table M-4), mostly within the former footprint of the CRBR. Of 19 these disturbances, 153 ac would be permanent impacts, and 42 ac would be temporary 20 impacts (Table M-4). Much of the area that would be permanently affected is currently in a state 21 of early forest succession, and further succession to mature forest would be precluded. This 22 area comprises about 2 percent of the total acreage of similar vegetation within the 6-mi vicinity 23 (Figure M-8).

24 An additional 210 ac of herbaceous/grassland would be temporarily disturbed east of the CRN 25 Site by installation of the proposed 69-kV underground line within the existing Watts Bar Nuclear 26 Plant-Bull Run Fossil Plant 500-kV corridor, which crosses the CRN Site and ties into the 27 existing Bethel Valley Substation (Figure M-2). This area is currently a maintained right-of-way 28 and would continue to be similarly maintained after installation of the underground transmission 29 line. As part of implementing its proposed best management practices (BMPs), TVA would 30 seed disturbed areas after installation of the underground conductors, and the review team 31 expects that the affected areas would regenerate typical right-of-way vegetation in a few years.

32 An additional 0.33 ac of herbaceous/grassland would be permanently removed by expansion of 33 the Bethel Valley Substation.

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1 2 Figure M-8. Land Cover within the 6-Mi Vicinity of the Clinch River Site.

3 (Source: NASS 2017-TN5144)

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1 M.4.1.1.3 Revegetation of Temporarily Disturbed Land 2 Temporarily disturbed acreage may be revegetated or otherwise restored after clearing and 3 building activities using native or noninvasive herbaceous species. Revegetating using native 4 plant species would reduce competition from invasive species and facilitate forest succession.

5 Other temporarily disturbed areas may be replanted in trees (TVA 2017-TN4921), which would 6 likely further accelerate forest succession. Over several decades, some of these areas likely 7 would gradually transition physically and functionally from herbaceous/grassland to forest 8 habitat (TVA 2017-TN4921). Nevertheless, re-establishment of temporarily disturbed forest, 9 especially mature deciduous forest, could require several decades to more than a century.

10 In areas of permanent habitat conversion (e.g., forest to herbaceous/grassland or shrubland 11 such as in the relocated 161-kV transmission line onsite or water pipeline corridors for the intake 12 and discharge [Figure M-2]), habitat would be maintained in its converted state and the prior 13 functional value of the former forest communities would not be restored.

14 M.4.1.2 Wetland Habitats 15 Four wetlands (W001, W002, W008, and W012) (Figure M-4) with a total area of approximately 16 1.2 ac would be filled to build the proposed facilities on the CRN Site. The type, location, size, 17 condition, and jurisdictional status of these four wetlands are provided in Table M-5. The 18 condition of the affected wetlands ranges from degraded to moderate (Pilarski-Hall 2015-19 TN5185). The functions of these wetlands, including any as wildlife habitat, would be lost.

20 Table M-5. Affected Wetlands on the CRN Site (Source: TVA 2017)

TVA Wetland Wetland Condition Size Number Type(a) Location Impact Category(b) (ac)

W001 PF01E Water discharge pipeline corridor on a Fill 2 0.67 terrace of the Clinch River W002 PEM1E Power-block area Fill 1 0.13 W008 PF01E Water intake pipeline corridor Fill 2 0.23 W012 PEM1E Power block and parking areas Fill 1 0.13 Total 1.16 (a) Classification codes as defined in Cowardin et al. 1979-TN5186: PEM1E = Palustrine emergent, persistent vegetation, seasonally flooded/saturated; PFO1E = Palustrine forested, broad-leaved deciduous vegetation, seasonally flooded/saturated; PSS1E = Palustrine scrub-shrub, broad-leaved deciduous vegetation, seasonally flooded/saturated; PSSHh = Palustrine scrub-shrub, broad-leaved deciduous vegetation, permanently flooded, diked/impounded.

(b) Category 1 = degraded; Category 2 = moderate quality; Category 3 = high quality.

21 The other wetlands on the CRN Site listed in Table M-2 would be avoided and thus not 22 directly affected by building activities. Indirect effects on downgradient wetlands outside the 23 footprint of development would largely be reduced by the use of BMPs to prevent erosion and 24 sedimentation. These include soil stabilization via revegetation, drainage control measures, 25 and managing discharges in accordance with the CRN Sites future Storm Water Pollution 26 Prevention Plan and National Pollutant Discharge Elimination System (NPDES) permit, etc.

27 (TVA 2017-TN4921).

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1 Dewatering of groundwater within the power-block excavation at the CRN Site would be 2 necessary during development of the below-grade nuclear island structures and foundations 3 described in Section M.3.2. Wetlands on the CRN Site and in the BTA are associated with 4 surface water (streams or the Clinch River), and their association with groundwater is assumed 5 but the extent of the connection is unknown. Because of their surface-water connection and the 6 temporary nature of the power-block excavation, it is anticipated three nearby moderate quality 7 wetlandsW003 (0.18 ac), W004 (0.24 ac), and W007 (0.17 ac) (Figure M-6 and Table M-2) 8 (TVA 2017-TN4921)could experience temporary dewatering during the power-block 9 excavation.

10 TVA estimated that a total of approximately 0.5 ac across W013, W014, W015, and W017 (all 11 moderate quality wetlands except W017, which is high quality [Table M-2]) in the BTA would be 12 affected. Partial removal of these wetlands may adversely affect the integrity of the remaining 13 portions of these wetlands (e.g., by providing an inroad for the establishment of invasive 14 species). In addition, 0.11 ac (W016 [a moderate quality wetland (Table M-2)]) may be filled 15 (TVA 2017-TN4921, TVA 2016-TN5145).

16 Using the FWS National Wetland Inventory database (FWS 2017-TN5327) and assuming fringe 17 wetlands along streams, it is conservatively assumed that up to 2 ac of wetlands may occur 18 within the existing 500-kV transmission line corridor where the proposed new 69-kV 19 underground transmission line would be buried. It is conservatively assumed these 2 ac would 20 be disturbed, although TVA would install the 69-kV line in accordance with its wetland clearing, 21 building activities, and restoration BMPs that are specific to activities in transmission line 22 corridors (TVA 2012-TN4911).

23 The approximately 1.2 ac of wetland impacts on the CRN Site, 0.6 ac of wetland impacts in the 24 BTA, and the 2 ac of wetlands impacts within the existing 500-kV transmission line corridor total 25 about 3.8 ac, which compose about 0.4 percent of the total acreage of wetlands within a 6-mi 26 radius.

27 M.4.1.3 Aquatic Habitats 28 TVA plans to site the proposed facilities and structures to avoid, to the extent possible, impacts 29 on streams and other waterbodies.

30 M.4.1.3.1 Streams and Ponds 31 One perennial stream (S01) and six ephemeral streams/wet weather conveyances (C01, C02, 32 C03, C13, C14, C15) lie within TVAs estimated building-activity footprint. Two freshwater 33 ponds (P04 and P06) also lie within the footprint (TVA 2017-TN4921). Five additional 34 ephemeral streams located in the northeast section of the CRN Site (C04, C05, C06, C07, and 35 C08) may be temporarily disturbed and then restored.

36 Within the BTA, two intermittent streams (S09 and S10) and six ephemeral streams (C26, C27, 37 C28, C29, C30, and C31) would be affected by building improvements to Bear Creek Road, the 38 CRN Site entrances, and development of a new intersection and access ramps on State Route M-38

1 58 (SR 58). Stream S10 and the six ephemeral streams would be permanently altered through 2 grading and filling as part of the road development (TVA 2017-TN4921).

3 TVA has stated that they would use BMPs to minimize erosion and transport of sediments in the 4 streams. TVA uses BMPs specifically directed toward avoiding or minimizing adverse impacts 5 on streamside management zones (SMZ) and the waterbodies. TVA also indicated they would 6 follow a stormwater pollution prevention plan that sets controls to manage runoff during clearing 7 and building activities (TVA 2017-TN4921).

8 The project would also include installing a new right-of-way segment for the 161-kV line on the 9 CRN Site and an underground 69-kV line for the 5-mi segment between the Bethel Valley 10 Substation and the CRN Site as discussed previously. Installation of the buried 69-kV line 11 would take place entirely within an existing right-of-way. However, the installation would cross 12 six streams that flow roughly perpendicularly across the right-of-way., as discussed in Section 13 2.4.2.1. TVA has indicated that they would attempt to tunnel under the streams where 14 practicable (TVA 2017-TN4921). TVA expects to employ BMPs to reduce the impacts from 15 sediment during the installation of the underground conductors. TVA has committed to restoring 16 any disturbance to streams immediately after work is completed (TVA 2017-TN4921). The 17 review team expects that the USACE would require TVA to restore surface disturbances to 18 jurisdictional streams as part of any Department of the Army permit issued under the Clean 19 Water Act.

20 M.4.1.3.2 Clinch River Arm of Watts Bar Reservoir 21 Aquatic habitats and organisms in the Clinch River could be affected by installation of the intake 22 structure, discharge structure, improvements to the barge facility, and installation of a new 23 culvert under the road in the Grassy Creek embayment (that is part of the Clinch River arm of 24 Watts Bar Reservoir).

25 The proposed cooling-water intake and discharge structures are described in Section M.3.3.

26 TVA discusses the installation of the intake and discharge and indicates that these activities 27 would affect only small areas of the reservoir (TVA 2017-TN4921). In addition, these activities 28 would require a Department of the Army permit from the USACE, and TVA would need to 29 conduct activities in accordance with the requirements of the permit. TVA has indicated that no 30 in-stream dredging would be required for activities to build the intake or place the discharge 31 although shoreline excavation or underwater excavation would be necessary (TVA 2017-32 TN4921). TVA anticipates using BMPs to prevent erosion and sediment transport. The review 33 team expects that TVA would use a temporary cofferdam during placement of the intake 34 structure, and TVA may use temporary silt curtains or cofferdams when building the discharge 35 structure (TVA 2017-TN4921).

36 TVA would install a new culvert in the Grassy Creek embayment of the Clinch River arm of the 37 Watts Bar Reservoir as part of the roadway improvements to the access road as discussed in 38 Section M.3. TVA would use BMPs such as silt curtains and cofferdams to minimize erosion 39 and prevent the transport of sediments into the reservoir (TVA 2017-TN4921).

M-39

1 TVA would refurbish the existing inactive barge terminal at CRM 14.2 near the entrance to the 2 CRN Site and Bear Creek Road. TVA can be expected to repair or enlarge the existing 3 retaining wall and install steel or wooden pilings or mooring posts to secure the barges.

4 Dredging activities are not anticipated; however, piles may be installed during the barge facility 5 improvements. The review team does not anticipate that TVA would disturb much river-bottom 6 area when rebuilding the barge terminal facilities.

7 TVA would conduct barging activities while building the project. However, TVA indicated that 8 most deliveries of modules and components would occur via road or rail (TVA 2017-TN4921).

9 Thus, the barges arriving at the barge facility are anticipated to be only a few per year.

10 Other than at the proposed locations for the features noted above, TVA indicates in figures in 11 the ER that a buffer of undisturbed riparian forest vegetation would be left between disturbed 12 lands and the river (TVA 2017-TN4921). This buffer, combined with BMPs to prevent erosion 13 and sedimentation from disturbed soils, would effectively prevent sedimentation of aquatic 14 habitats in the river and would preserve shaded aquatic habitats at the edge of the river.

15 The bypass that TVA proposes to build at the Melton Hill Dam would be built inside the existing 16 dam; therefore, building it would not affect aquatic life or disturb sediments (TVA 2017-TN4921).

17 M.4.1.4 Noise Impacts during Building Activities 18 Building activities are usually performed in a series of steps or phases, and noise associated 19 with different phases can vary greatly depending on the type of equipment used (WSDOT 2017-20 TN5313). TVA stated that typical noise and vibration would be generated by the operation of 21 machinery and vehicles, including internal combustion engines (e.g., front-end loaders, tractors, 22 scrapers/graders, heavy trucks, cranes, concrete pumps, and generators), impact equipment 23 (e.g., pneumatic equipment, jack hammers, and pile drivers), other equipment (e.g., vibrators, 24 saws, and hydro excavation equipment), and machine backup alarms (TVA 2017-TN4921).

25 These include apparatuses in each of the three categories of typical construction equipment 26 identified by Washington State Department of Transportation (WSDOT) (2017-TN5313), heavy 27 equipment (earth-moving); stationary equipment (pumps, generators, etc.); and impact 28 equipment (pile drivers, etc.). TVA stated that more intense noise would be generated by 29 blasting, demolition, and testing of the emergency warning siren. Use of equipment and 30 blasting activities add noise to background sound levels and cause ground vibration that may 31 affect surface and underground structures (OSMRE 2017-TN5353).

32 M.4.1.4.1 Typical Construction Equipment 33 TVAs maximum expected noise level of 101 decibels adjusted (dBA) due to building activities 34 measured at 50 ft from the source (TVA 2017-TN4921) comports with the high end of average 35 maximum noise levels at 50 feet that range from about 73 to 101 dBA for non-impact heavy 36 equipment (WSDOT 2017-TN5313). TVA stated that some infrequent or nighttime construction 37 activities could generate temporary noise levels at or above 60 to 90 dBA at a distance of 100 ft 38 from the source (TVA 2017-TN4921). TVA also noted use of impact equipment (see above) 39 that may generate noise levels from 79 to 110 dBA at 50 ft from the source (WSDOT 2017-40 TN5313). Stationary equipment (such as that noted above by TVA) generally runs continuously M-40

1 at relatively constant power and speeds, and produces noise levels that can range from 68 to 2 88 dBA 50 ft from the source (WSDOT 2017-TN5313). TVA has stated that background sound 3 in the project area is about 46 to 48 dBA during the day and between 41 and 49 dBA during the 4 night (TVA 2017-TN4921).

5 Substrate, topography, vegetation, and atmospheric conditions affect the intensity level of noise 6 as it is propagated over distance. Because vegetation, topography, and atmospheric conditions 7 can vary greatly, these factors are generally not included in a BA (WSDOT 2017-TN5313). The 8 standard attenuation rate for hard site conditions (substrate such as concrete or open water) is 9 6 dB per doubling of distance for point source noise (WSDOT 2017-TN5313), which includes all 10 the equipment noted above. When ground cover or normal unpacked earth (i.e., a soft site) 11 exists, the ground becomes absorptive of noise energy and can result in an additional 1.5 dB 12 reduction per doubling of distance as it spreads from the source (WSDOT 2017-TN5313). Note 13 that use of this factor alone (without topography, vegetation, and atmospheric conditions) likely 14 predicts noise levels that are higher than actual noise levels (WSDOT 2017-TN5313).

15 Assuming noise decreases by approximately 7.5 dBA per doubling of distance from the source 16 over soft ground (WSDOT 2017-TN5313), project construction noise could travel as little as 17 400 ft (starting as 60 dBA at 100 ft from the source) up to 12,800 ft (roughly 2.4 mi) (starting 18 at 110 dBA at 50 ft from the source) before it attenuates to 45 and 50 dBA, respectively, 19 (i.e., approximate background sound levels). These noise intensity levels may represent 20 episodic highs and lows. Heavy construction equipment more typically generates an 21 estimated noise level of approximately 85 decibels adjusted (dBA) at 50 ft from the source 22 (USDOT 2017-TN5383) and would thus travel up to 1,600 ft before it attenuates to 47.5 dBA.

23 This noise intensity level may be more representative of typical bouts of noise. The above noise 24 levels could occur at most locations on the CRN Site and in the BTA, and also along the roughly 25 5-mi-long underground transmission line between the CRN Site and Bethel Valley Substation, 26 and could thus inject noise at the above levels and distances into the surrounding landscape.

27 M.4.1.4.2 Noise to Aquatic Ecosystems 28 Dredging activities are not anticipated; however, piles may be driven during the barge facility 29 improvements. Placement of piles would affect small areas of habitat within the footprint of the 30 piles (TVA 2017-TN4921). In addition, although most fish species would avoid the underwater 31 noise of pile driving, some species could be affected by the noise and the pressure wave 32 generated by the pile driver.

33 M.4.1.4.3 Blasting and Demolition 34 Excavation for the power block(s) (Section M.3.2) requires the removal of soil and rock.

35 Periodic blasting during the dayshift would be used to remove rock. Blasting and demolition 36 would occur early in the building activities at intermittent frequencies and only occur during the 37 daylight hours (between 7:00 a.m. and 5:00 p.m.) (TVA 2017-TN4921). Blasting noise can 38 reach 126 dBA (WSDOT 2017-TN5313). Assuming noise decreases by approximately 7.5 dBA 39 per doubling of distance from the source over soft ground (WSDOT 2017-TN5313), blasting-40 type construction noise could travel 51,200 ft (roughly 9.6 mi) before it attenuates to 51 dBA 41 (i.e., approximate background sound level).

M-41

1 M.4.1.4.4 Combined Noise 2 Excavation activities for the power block(s) may occur in conjunction with site preparation 3 activities. Thus, blasting may be concurrent with the use of the typical construction equipment 4 described above. Also, the different types of typical construction equipment may be operated at 5 the same time in the absence of blasting.

6 Although noise from multiple sources at the same location may result in louder levels than a 7 single source alone, the decibel is measured on a logarithmic scale, so noise levels cannot be 8 added by standard addition. For example, two noises of equal level (+1 dB) combine to raise 9 the noise level by 3 dB. However, if two noises differ by more than 10 dB, there is no combined 10 increase in the noise level; the higher output covers any other noise (WSDOT 2017-TN5313).

11 It is necessary to follow the rules of decibel addition provided by WSDOT (2017-TN5313) to 12 determine the combined noise level of blasting and typical construction equipment operating 13 together. The three loudest noise levels are 126 dBA (blasting), 110 dBA (impact equipment),

14 and 101 dBA (earth-moving equipment). There is a difference of 9 dBA between the lower two 15 noise levels, so 1 dBA is added to 110 dBA. The difference between the resultant combined 16 level of 102 dBA and 126 dBA is greater than 10 dBA; thus, nothing is added to 126 dBA. The 17 126 dBA blasting noise covers any other noise and there would be no increase due to other 18 concurrent noises at these levels.

19 Without blasting, the three loudest noise levels would be 110 dBA (impact equipment), 101 dBA 20 (earth-moving equipment), and 88 dBA (stationary equipment). The difference between the 21 lower two levels is greater than 10 dBA so nothing is added to 101 dBA. However, the 22 difference between 110 dBA and 101 dBA is 9 dBA, so 1 dBA is added to 110 dBA to create a 23 combined noise level of 111 dBA, which is a very minor increase.

24 Consequently, there would be virtually no combined noise levels of any consequence above 25 and beyond the above individual noise levels.

26 M.4.1.4.5 Noise Reduction 27 TVA has stated in its application (TVA 2017) that it would attempt noise reduction via the 28 following methods:

29 Using noise-reduction devices on heavy equipment (i.e., mufflers) 30 Limiting driving speeds, use of Jake brakes, and tail-gate slamming 31 Building earthen berms 32 Placing foliage or ground cover between the noise sources and receptors.

33 M.4.1.5 Wildlife Collisions with Tall Structures 34 Tall construction equipment present potential collision obstacles for volant (flying) wildlife that 35 otherwise would not be present. Several large cranes would be used, the largest being 638 ft in 36 height (TVA 2017-TN4922).

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1 M.4.1.6 Herbicide Use 2 In areas of land clearing that would result in permanent habitat conversion (e.g., forest 3 converted to herbaceous/grassland or shrubland) habitat would be maintained in its converted 4 state using herbicides (as well as mechanical means). Such areas include the relocated 161-kV 5 transmission line on the CRN Site, water pipeline corridors for the intake and discharge, and the 6 500-kV transmission line corridor where the new 69-kV transmission line would be buried 7 (Figure M-2). Herbicides are used around wetlands and sensitive biological resources as 8 directed by TVA BMPs (TVA 2012-TN4911).

9 M.4.2 Offsite Transmission Line Upgrades 10 TVA identified transmission line segments for possible upgrade (Table M-3) based on an 11 initial interconnection system impact study of projected future transmission system conditions.

12 TVA has stated it used available information about transmission and generation additions and 13 upgrades that may subsequently change. TVA also stated that given the dynamic nature of its 14 transmission system and the time lapse between issuance of the ESP and possible COL, the 15 planning assumptions are anticipated to change (depending on the final configuration and 16 additional electrical capacity of the specific reactors ultimately proposed) along with associated 17 changes in the corridor segments and engineering solutions (TVA 2017-TN4921, TVA 2016-18 TN5145).

19 TVA has stated that all work associated with the currently identified upgrades would occur within 20 existing corridors and that no new corridors would be developed or widened (TVA 2017-21 TN4921, TVA 2016-TN5145). The review team estimates that the total length of transmission 22 lines requiring upgrades is approximately 440 mi (Table M-3). TVA estimates that the total land 23 area subject to potential disturbance is about 5,327 ac (TVA 2017-TN4920).

24 Uprating, reconductoring, and rebuilding activities as currently proposed are described below.

25 Removing structures that interfere with clearance (due to increased electrical load 26 increasing line temperature and sag).

27 Replacement or modification of existing structures or installation of intermediate structures:

28 This activity would be performed with standard transmission line equipment such as 29 bulldozers, bucket trucks, boom trucks, and forklifts to raise the existing conductor to provide 30 proper ground clearance. Disturbance would typically be limited to a radius of about 100 ft 31 around the work structure.

32 Conductor modification: This activity would include conductor slides, cuts, or floating dead-33 ends to increase ground clearance (described in TVA 2016-TN5145). These improvements 34 require the use of a bucket truck; disturbance would be minimal and confined to the 35 immediate area of the clearance issue.

36 Conductor replacement (a.k.a., reconductoring) (described in TVA 2016-TN5145): Bucket 37 trucks would be used for access and stringing equipment. A bulldozer and specialized 38 tensioning equipment would be used to pull conductors to the proper tension. Wire pulls 39 would be limited to a maximum of 5 mi. Pull points would typically be located along the most 40 accessible path on the right-of-way (adjacent to road crossings or existing access roads).

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1 The area of disturbance at each pull point would typically range from 200 to 300 ft along the 2 right-of-way.

3 Adding surcharge: This activity would involve adding a stone base and rock or dirt 4 (surcharge) to structure footings. Typical installation of surcharge would be performed with 5 tracked equipment with minimal ground disturbance.

6 Modification of local power company transmission lines: If a local utility crossing does not 7 have adequate clearance, TVA would request that the local utility lower or re-route the 8 crossing.

9 Rebuild: Installing intermediate structures between existing structures for added structural 10 support and/or clearance, and/or tearing down existing structures and replacing with more 11 robust structures (TVA 2017-TN4921, TVA 2016-TN5145).

12 Potential impacts to resources within the transmission line corridors would depend on the 13 engineering solution (type of upgrade) selected, which is currently uncertain, and the location 14 and extent of habitat disturbance. The above description of upgrade activities indicates that 15 much less than the full 440 mi or 5,327 ac are likely to be disturbed, and TVA has not yet 16 identified where and to what extent habitat disturbance would take place within the corridors.

17 Lacking this necessary information to perform an assessment, the review team assumes, 18 subject to future confirmation, that TVA would limit ground disturbance to upland areas within 19 the existing bounds of established rights-of-way, and thus would not physically disturb aquatic 20 habitats or wetlands. The review team likewise assumes that TVA would not remove any 21 mature trees or forest cover as part of the transmission line upgrades, including trees from 22 forested wetlands, stream banks, or reservoir shorelines. TVA has committed to using BMPs to 23 avoid impacts on wetlands (Section M.4.1.2) and aquatic habitats (Section M.4.1.3) when 24 possible.

25 M.5 Operation Impacts 26 The discussion in this section provides an overview of potential impacts on terrestrial and aquatic 27 resources that could result from operating the facilities discussed in the CRN Site PPE. Section 28 M.4 provides a complementary overview of potential impacts on terrestrial and aquatic resources 29 from building those facilities. Most information presented in these overview sections is drawn 30 from the review teams EIS to support its review of the ESP application. Section M.7 of this BA 31 provides an assessment of the potential effects on individual species and habitats from the 32 alteration of terrestrial and aquatic resources resulting from building and operating the 33 contemplated new facilities.

34 M.5.1 CRN Site and Vicinity 35 M.5.1.1 Cooling-Tower Impacts on Vegetation 36 Two mechanical draft cooling towers (two blocks of 9 cells each, for a total of 18 cells) would be 37 located just west of the reactor buildings (Figure M-3). In each cooling tower, the heat in the 38 CWS water would be transferred to the atmosphere. Operation of the CWS would be based on 39 two cycles of concentration, which means the total dissolved solids (TDS) in the makeup water M-44

1 would be concentrated to approximately two times the ambient concentration in the Clinch River 2 before being released to the atmosphere. Cooled CWS water would be recirculated to complete 3 the closed-cycle cooling loop. Through the process of evaporation, the TDS concentration in 4 the CWS increases. A small percentage of the water in the CWS is released into the 5 atmosphere as fine droplets (i.e., cooling-tower drift) containing elevated TDS levels that can be 6 deposited on nearby vegetation and soil. Vapor plumes and drift may affect vegetation, and the 7 water lost from cooling-tower operation could lower river levels and affect associated shoreline 8 habitat.

9 Depending on the makeup source waterbody, the TDS concentration in the drift can contain 10 high levels of salts that can stress and damage vegetation, either directly by deposition onto 11 foliage or indirectly from accumulation in the soils. TVA modeled salt-drift deposition using the 12 Electric Power Research Institutes Seasonal and Annual Cooling Tower Impact model 13 (TVA 2017-TN4921). TVAs modeling used conservative parameters and addressed all 14 directions from the cooling towers, during all seasons, and annually. Maximum deposition rates 15 took place during summer. Summer deposition rates (TVA 2017-TN4921) were overlaid on the 16 CRN Site vegetation map and development footprint to produce Figure M-9. Deposition rates at 17 or above the threshold of possible vegetation damage stated in NUREG-1555, the 18 Environmental Standard Review Plan (NRC 2000-TN614) (i.e., 1000 kg/km2/month) would affect 19 mostly non-forested early successional vegetation in the CRBR footprint, most of which would 20 be permanently cleared and developed prior to operation of the cooling towers (Figure M-9).

21 However, in the southwest direction, a small parcel of forest would be in the above-threshold 22 salt-deposition footprint; however, this forest parcel lies within the site development footprint 23 (Figure M-9) and would be cleared.

24 The model analysis also demonstrated that, considering the relatively small size and low height 25 of these cooling towers and the temperature and climate of the area, there would be no hours of 26 fogging or icing (TVA 2017-TN4921) and thus no potential associated impacts on vegetation.

27 M.5.1.2 Collisions with Cooling Towers 28 Because the cooling towers would not exceed 65 ft in height (Section M.3.3), they would not 29 present a potential collision hazard for volant (flying) wildlife.

30 M.5.1.3 Cooling-Tower Noise 31 The maximum expected noise level produced by the operation of cooling towers measured at 32 1,000 ft from the source would be <70 dBA (TVA 2017-TN4921). Using the methodology in 33 Section M.4.1.4, cooling-tower noise is expected to attenuate to background levels at around 34 6,000 ft from the source. Unlike noise generated by construction equipment, which may oft be 35 punctuated by bouts of relative calm, cooling-tower noise would be constant throughout the 36 operating life of the project and, therefore, may be less likely to startle or induce a flushing or 37 avoidance response from wildlife.

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1 2 Figure M-9. Salt-Deposition Rates that Exceed 1,000 kg/km2/mo within Depicted 3 Distances, Overlaid on Terrestrial Vegetation and the Development Footprint 4 on the CRN Site M-46

1 M.5.1.4 Transmission Line Corridor Maintenance 2 No new or expanded transmission line corridors would be needed in connection with SMR 3 power generation at the CRN Site (Section M.3.1.3), and thus, no new corridor vegetation 4 maintenance (routine use of herbicides along with mowing and hand-clearing of vegetation) 5 would be required. New transmission line corridor vegetation maintenance only would be 6 required within the relocated section of the 161-kV corridor on the CRN Site (Figure M-3). This 7 would be offset by the cessation of vegetation maintenance practices in the existing section of 8 this corridor on the CRN Site.

9 M.5.1.5 Water Withdrawal and Consumption 10 The U.S. Environmental Protection Agency (EPA) has developed regulations that address water 11 withdrawals and intake flow restrictions for new facilities that produce electric power (40 CFR 12 Part 125-TN254). These regulations implement Section 316(b) of the Clean Water Act. These 13 regulations provide limits on the total design intake flow for all cooling-water intake structures.

14 The limits depend on the type of waterbody in which the intake structure is located. For facilities 15 that withdraw from a freshwater river or stream, the regulations limit the total design intake flow 16 to no more than 5 percent of the mean annual flow. For facilities that withdraw water from lakes 17 or reservoirs, the regulations indicate that the withdrawals must not disrupt the natural 18 thermal stratification or turnover pattern of the source water, although there is an exception if a 19 Federal or State resource agency indicates that the disruption has a beneficial effect on the 20 management of fisheries (40 CFR Part 125-TN254).

21 Based on an estimated expected average withdrawal rate of 40 cfs for normal plant operation, 22 on average less than 1 percent of the mean annual discharge from Melton Hill Reservoir to the 23 Clinch River would be withdrawn from the intake located near CRM 17.9. However, although 24 TVAs proposed withdrawal rate using the CRN intake meets the limits for a river, the Clinch 25 River arm of the Watts Bar Reservoir is considered a reservoir. The upstream location in the 26 vicinity of the proposed intake exhibited no stratification during measurements conducted by 27 TVA in February of 2011. However, the downstream location showed a decrease in water 28 temperature with depth during the July 2011 sampling as well as dissolved oxygen levels below 29 the State water-quality criterion, indicating that some stratification may be taking place 30 (TVA 2013-TN5167). There is no indication that the withdrawal of water would disrupt the 31 minimal amounts of stratification occurring downstream of the intake.

32 TVA estimated the proposed consumptive use of 12,808 gpm (28.5 cfs) to be about 0.6 percent 33 of the average flow rate (TVA 2017-TN4921). This is the percentage of the water withdrawn 34 from the river that is not returned to the river, but instead is evaporated or lost in the form of 35 water droplets from the cooling towers.

36 TVA has stated that the intake would be designed such that the maximum intake velocity 37 through the inlet, the trash racks, and the water screens would be less than 0.5 ft/s (TVA 2017-38 TN4921), as required in the EPA regulations that address water withdrawals and intake flow 39 restrictions for new facilities that produce electric power (40 CFR Part 125-TN254). EPA 40 indicated that this approach velocity is recommended based on a fish swimming speed study.

41 The study suggested that the species and life stages evaluated could endure a 1.0 ft/s velocity M-47

1 (66 FR 65256-TN243). The EPA regulations assume a safety factor of 2 and derive the 0.5 ft/s 2 threshold (66 FR 65256-TN243). These regulations are specified to limit the effects of 3 entrainment and impingement.

4 Compliance with EPA regulations addressing cooling-water intake structures for new facilities 5 (Subpart I of 40 CFR Part 125 [TN254]) is generally protective of fish and shellfish populations 6 and usually does not result in detectable effects on populations of aquatic organisms from 7 impingement or entrainment.

8 M.5.1.6 Discharge Analysis 9 Discharge of heated water back into the Clinch River arm of the Watts Bar Reservoir may affect 10 aquatic habitats and species in several ways. Thermal discharges increase the temperature of 11 the water and can cause adverse effects. Chemically treated water is also a stressor of aquatic 12 biota, as is physical alteration of habitat that may occur through scouring or other sediment 13 transportation processes during cooling-water discharges. Although most of the excess heat in 14 the cooling water transfers to the atmosphere in the cooling tower by evaporation and 15 conductive cooling, some water that does not evaporate or drift from the tower ends up in the 16 cooling-tower basin. A portion of the water in the cooling-tower basin is returned to the river at a 17 higher temperature than when it was originally removed. Thermal discharge would be regulated 18 as part of the NPDES permit administered by Tennessee Department of Environment and 19 Conservation (TDEC) (TVA 2017-TN4921). The applicable temperature-related Tennessee 20 water-quality criteria for the CRN Site discharge are applicable at a depth of 5 ft. and include the 21 following (TNSOS 2017-TN5071): (1) a maximum change in river temperature not to exceed 22 3°C (5.4°F) relative to an unaffected upstream control location; (2) maximum river temperature 23 not to exceed 30.5°C (86.9°F); and (3) maximum river temperature rate of change not to exceed 24 +/-2°C (3.6°F) per hour. These criteria would be required to be met outside the mixing zone, 25 which would be determined by TDEC and stipulated as part of the NPDES permit along with any 26 monitoring requirements. Tennessees water-quality criteria specify that mixing zones be 27 restricted in area and not prevent the free passage of fish or cause aquatic life mortality, among 28 other requirements (TNSOS 2017-TN5071).

29 TVA evaluated the extent of the thermal discharge in the mixing zone by assuming the 30 maximum values for withdrawal, discharge, and discharge temperature occurring during 31 extreme summer and winter conditions when the plant was operating at full power. TVAs 32 model suggested that the largest mixing zone occurs during the winter and results in local 33 excursions of high-temperature water beyond a 150-ft-diameter mixing zone. The mixing zone 34 covers about 45 percent of the river width at the discharge at a depth of 5 ft. This mixing zone 35 was the result of a flow reversal that can occur in the reservoir as a result of the timing of water 36 release from Melton Hill Dam. The flow reversal reduces the extent of downstream dispersion 37 of the thermal plume and causes it to occupy a wider area of the reservoir as it moves upstream 38 from the discharge (TVA 2017-TN4921). However, the models show that there is still room for 39 fish to avoid the thermal plume and pass without any obstruction (TVA 2017-TN4921).

40 Discharge from the cooling towers would contain anti-scaling compounds, corrosion inhibitors, 41 and biocides to eliminate growth of bacteria and algae. The discharge could also contain 42 concentrated minerals, salts, and organic compounds that enter the makeup water system.

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1 TDEC would approve the use and quantities of chemicals for treatment of intake water based on 2 the specifications TVA includes in their future Biocide/Corrosion Treatment Plan. This approval 3 would be requested as part of the NPDES permit application for the facility. The review team 4 expects that, as part of standard practices, the treatment plan would likely include biocides for 5 zebra mussels. TVA would provide the quantities of these chemicals at the COL application 6 stage (TVA 2017-TN4921).

7 Physical impacts on water quality could occur from increased water velocity or dredging activity 8 that could result in sediment erosion, suspension, and transport. However, the diffuser ports 9 direct effluent upward into the water column such that no physical alteration or scouring occurs 10 that could affect benthic habitat or species (TVA 2017-TN4921, TVA 2016-TN5008). TVA also 11 stated that no dredging to maintain the intake or discharge structures is anticipated during 12 operation, because sediment accumulation is not anticipated (TVA 2017-TN4921).

13 M.5.2 Offsite Transmission Line Upgrades 14 M.5.2.1 Terrestrial Resources 15 As noted in Section M.4.2, work as part of the upgrades would be confined to existing right-of-16 ways. TVA would manage these right-of-ways in the same manner as at present after the 17 upgrades are completed. Thus, there are no operations impacts on terrestrial resources within 18 the offsite transmission line corridors.

19 M.5.2.2 Aquatic Resources 20 The only potential offsite aquatic impacts during operations would be from maintaining the 21 upgraded overhead transmission lines. TVA recognizes SMZs along the border of surface 22 waters including intermittent and perennial streams and other perennial waterbodies such as 23 ponds. TVA guidance for Environmental Protection and BMPs (TVA 2012-TN4911) limits the 24 broadcast application of fertilizers and herbicides in SMZs, including the spraying of herbicides 25 other than those labeled for aquatic use. TVA guidance indicates that these chemicals should 26 not be applied either directly to perennial streams and waterbodies or intermittent ones and that 27 drift should also not be allowed. In addition, application should not be on land surfaces that are 28 adjacent to or where direct washoff into a stream or waterbody could occur. This applies to the 29 surface of drainage canals or streams where direct washoff into a waterbody or stream could 30 occur. Specific herbicides are labeled for use within SMZs but they are only used selectively 31 (TVA 2017-TN4921).

32 M.6 Species and Critical Habitat Identification 33 This section describes individual species and critical habitats considered in this BA. Species 34 and critical habitats are treated separately for two different parts of the project area: (1) the 35 CRN Site and vicinity, including the BTA and proposed underground 69-kV transmission line 36 route, and (2) the offsite transmission lines identified for possible upgrading.

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1 M.6.1 CRN Site and Vicinity 2 The FWS letter of July 2017 requests that three terrestrial species and four aquatic species be 3 considered for the CRN Site and vicinity (FWS 2017-TN5091). In the October conference call 4 with NRC, FWS requested inclusion of two additional bat species. Although these two bat 5 species and the hellbender (Cryptobranchus alleganiensis) are not presently listed or otherwise 6 regulated under the ESA, FWS anticipates that they may be listed in the near future (see 7 Sections M.6.1.4, M.6.1.5, and M.6.1.8). Considering the long-term nature of activities 8 envisioned at the CRN Site, BTA, and affected transmission line areas, the NRC and USACE 9 review team agrees that inclusion of these species in the BA could facilitate long-term 10 environmental planning. Each species addressed in the BA for the CRN Site and vicinity are 11 listed in Table M-6.

12 Table M-6. Species and Critical Habitats Considered in this BA for the CRN Site and 13 Vicinity (including the BTA and buried 68-kV transmission line) in Roane 14 County, Tennessee Scientific Name(a,b) Common Name Federal Status Terrestrial Species Myotis grisescens(a) Gray Bat Endangered Myotis lucifugus(b) Little Brown Bat Petitioned for Listing Myotis sodalis(a) Indiana bat Endangered Myotis septentrionalis(a) Northern Long-Eared Bat Threatened Perimyotis subflavus (b) Tri-Colored Bat Petitioned for Listing Aquatic Species Cryptobranchus alleganiensis(a) Hellbender Petitioned for Listing Erimonax monachus(a) Spotfin chub Threatened Lampsilllis abrupta(a) Pink Mucket Endangered Plethobasus cyphus(a) Sheepnose Mussel Endangered (a) Species listed in the FWS July 2017 letter (FWS 2017-TN5091).

(b) Species recommended by FWS in its October 2017 conference call with NRC (PNNL 2017-TN5384).

15 M.6.1.1 Gray Bat 16 M.6.1.1.1 Status and Threats 17 Range-wide, gray bats (Myotis grisescens) have been documented in a few hundred caves 18 (FWS 2009-TN5330). Gray bats are endangered largely because 95 percent hibernate in only 19 eight caves making the species extremely vulnerable to disturbance (FWS 1997-TN5194; 20 TNBWG 2017-TN5329). Multiple factors contributed to the initial decline of gray bats, including 21 human disturbance at hibernacula, natural flooding, impoundment of waterways, and 22 contamination from pesticides. Although human disturbance at hibernacula remains the number 23 one reason for the continued decline of some populations of gray bat, natural and manmade 24 flooding remains a secondary threat (FWS 2009-TN5330). Overall, this species is recovering 25 since FWS publication of its recovery plan in 1982 (increased about 104 percent between 1982 26 and 2007), and numbers have increased significantly in many areas (FWS 2009-TN5330).

27 White nose syndrome (WNS) is an undocumented but possible threat to gray bats (FWS 2009-28 TN5330).

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1 M.6.1.1.2 Life History 2 Gray bats occupy a limited geographic range in limestone karst areas of the southeastern 3 United States. They are mainly found in the cave regions of Alabama, northern Arkansas, 4 Kentucky, Missouri, and Tennessee (FWS 1997-TN5194).

5 Prior to major declines of the species, individual hibernating populations contained from 100,000 6 to 1.5 million bats. Ninety-five percent of the species hibernated in nine caves, with over more 7 than 50 percent in a single cave. Summer colonies in Tennessee and Alabama contained 5,000 8 to 250,000 each, with most numbering between 10,000 and 50,000 (FWS 1982-TN929).

9 Overall, gray bat populations have increased and recovered in many areas throughout the 10 species range. As of 2007, the species was known to occur in 384 caves scattered across 11 11 states (FWS 2009-TN5330).

12 With rare exceptions, gray bats live in caves year-round (FWS 1982-TN929, FWS 1997-13 TN5194; TNBWG 2017-TN5329). The species shows strong philopatry to both summering and 14 wintering sites. Because of their highly specific roost and habitat requirements, only about 15 5 percent of available caves are suitable for occupancy by gray bats (FWS 2009-TN5330).

16 During the winter, the species hibernates in deep, vertical caves (FWS 1982-TN929, 17 FWS 1997-TN5194), which act as cold air traps (FWS 1982-TN929). Gray bats regularly 18 migrate from 17 to 437 km (11 to 272 mi) between summer maternity sites and winter 19 hibernacula, and some individuals move as much as 689 to 775 km (428 to 482 mi) (FWS 2009-20 TN5330). A wide variety of caves are used during the spring and fall transient period 21 (FWS 1982-TN929). In summer, female gray bats form maternity colonies of a few hundred to 22 many thousands of individuals (FWS 2009-TN5330) and roost in caves, which act as warm air 23 traps and are scattered along rivers (FWS 1982-TN929, FWS 1997-TN5194). These caves are 24 in limestone karst areas. They do not use human dwellings (FWS 1997-TN5194). Summer 25 caves, especially maternity caves, are almost always located within 1 km (rarely more than 26 4 km) of a river or reservoir. A maternity colony may disperse from about 20 km to over several 27 hundred kilometers of shoreline to feed. All bats fly in the protection of forest canopy between 28 caves and foraging areas. Forested areas surrounding caves and between caves and over-29 water feeding habitat are advantageous for gray bat survival. Gray bat feeding areas have not 30 been found over rivers or reservoirs where adjacent areas of forest have been cleared 31 (FWS 1982-TN929).

32 Upon arriving at hibernating caves in September and October, adult bats mate and females 33 immediately begin hibernation, followed several weeks thereafter by juveniles of both sexes and 34 adult males, with most in hibernation by early November. Adult females emerge from 35 hibernation in late March or early April, followed by adult males and by juveniles of both sexes 36 from mid-April to mid-May. Mortality is high in late March and April when fat reserves and food 37 supply are low (FWS 1982-TN929).

38 Maternity colonies each occupy a traditional home range containing several roosting caves 39 along about a 70 km stretch of river or reservoir shoreline (FWS 1982-TN929). Adult females 40 store sperm over winter, become pregnant upon spring emergence, and give birth to a single 41 young in late May or early June (FWS 1982-TN929, FWS 1997-TN5194, FWS 2009-TN5330).

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1 Reproductive females congregate in a single, traditional maternity cave, while males and 2 nonreproductive females roost in peripheral caves. Maternity colonies consist of a few hundred 3 to many thousands of individuals (FWS 2009-TN5330). Most young begin to fly within 20 to 4 25 days after birth (FWS 1982-TN929).

5 Although the species may travel up to 35 km between prime feeding areas over lakes or rivers 6 and occupied caves, most maternity colonies are usually located 1 to 4 km from foraging 7 locations (FWS 2009-TN5330). Gray bats are highly dependent on aquatic insects, especially 8 mayflies, caddisflies, and stoneflies, and forage within roughly three meters of the waters 9 surface. The species is an opportunistic forager, however, and also consumes beetles and 10 moths (FWS 2009-TN5330). Foraging territories may be occupied by 15 or more bats and are 11 controlled by reproductive females. Foraging territories are used by the same individual bats 12 from one year to the next. Foraging may focus on a particular insect that may be important to 13 the species survival (FWS 1982-TN929).

14 M.6.1.1.3 Critical Habitat 15 Critical habitat has not been designated for the gray bat.

16 M.6.1.1.4 Site and Vicinity Baseline 17 One individual gray bat was captured in mist nets in summer on the CRN Site in 2011, and 18 there was a total of 361 to 381 acoustic recordings in spring, summer, and fall on the CRN Site 19 and in the BTA in 2013 and 2015 (Hamrick 2015-TN5187; LeGrand et al. 2015-TN5188). The 20 sex, age, and reproductive condition of the captured individual were not documented (LeGrand 21 et al. 2015-TN5188). No caves are known to be located on the CRN Site or in the BTA; 22 however, Rennies Cave and 2-Batteries Cave are located within the Grassy Creek Habitat 23 Protection Area, and there are three additional caves/karst openings near Grassy Creek 24 (LeGrand et al. 2015-TN5188). Thus, the species likely uses the CRN Site and BTA for 25 foraging but does not roost there. Acoustic recordings during summer indicated the CRN Site 26 and BTA may be part of a foraging territory for bats in a maternity or non-maternity summer 27 roost located somewhere offsite, likely within 1 to 4 km of the Clinch River. Acoustic recordings 28 during spring and fall may indicate the presence of a hibernaculum in the vicinity. The five 29 caves noted above have not been surveyed.

30 The gray bat was captured in mist nets on the ORR in 1996, 2006, 2011, and 2013, and 31 detected acoustically in areas across the ORR in 2013, 2014, and 2015 (McCracken et al. 2015-32 TN5287). The species was also detected acoustically in areas across the ORR from April 15 to 33 October 31 in 2013, 2014, and 2015 (TDEC 2014-TN5288; Middleton 2014-TN5347, 34 Middleton 2015-TN5348, Middleton 2016-TN5349), including those closely surrounding the 35 CRN Site (e.g., Grassy Creek in the northwest portion of the Grassy Creek Habitat Protection 36 Area, the junction of Bear Creek Valley Road and Highway 95 located just northeast of the CRN 37 Site, and along the Clinch River between the CRN Site and Jones Island) and in the BTA in 38 2013 (e.g., Gallaher Cemetery just north of the BTA) (TDEC 2014-TN5288).

39 From examination of ORNLs and TDECs 3-year acoustic detection data (McCracken et 40 al. 2015-TN5287; TDEC 2014-TN5288, TDEC 2016-TN5350; Middleton 2014-TN5347, M-52

1 Middleton 2015-TN5348, Middleton 2016-TN5349), no direct comparisons can be made of 2 numbers of gray bat acoustic recordings between sites and or years. However, total acoustic 3 detection data for the gray bat on the ORR over the 3 years reported by ORNL and TDEC 4 appear to provide somewhat of an indication of the relative prevalence of the species compared 5 to the other four bat species considered in this BA (Table M-7). Across the ORR, the gray bat 6 appears to be generally more prevalent than the other two Federally listed species considered 7 in this BA (i.e., Indiana bat and northern long-eared bat).

8 Table M-7. Number of Acoustic Recordings by Species and Year Bat Species(a)

Organization/Year Observed MYGR MYLU MYSE MYSO PESU McCracken et al. (2015-TN5287) /2013 7,908 1,427 326 262 23,784 McCracken et al. (2015-TN5287) /2014 4,236 447 426 91 2,958 McCracken et al. (2015-TN5287) /2015 108 139 193 16 60 Total 12,252 2,013 945 369 26,802 Middleton (2014-TN5347)/2013 480 356 47 181 3,423 Middleton (2015-TN5348)/2014 255 424 460 12 1,241 Middleton (2016-TN5349)/2015 1,010 498 49 74 1,230 Total 1,745 1,278 556 267 5,894 (a) Bat species abbreviations: MYGR = Myotis grisescens (gray bat), MYLU = Myotis lucifugus (little brown bat),

MYSE = Myotis septentrionalis (northern long-eared bat), MYSO = Myotis sodalis (Indiana bat), PESU =

Perimyotis subflavus (tri-colored bat).

9 M.6.1.2 Indiana Bat 10 M.6.1.2.1 Status and Threats 11 The Indiana bat (Myotis sodalis) was originally listed as in danger of extinction under the 12 Endangered Species Preservation Act of 1966 (80 Stat. 926-TN5344) on March 11, 1967 13 (32 FR 4001-TN2750). It was subsequently listed as endangered under the Act, as amended.

14 Thirteen winter hibernacula in six states were designated as critical habitat for the Indiana bat 15 on September 24, 1976, one of which is in TennesseeWhite Oak Blowhole Cave in Blount 16 County (41 FR 41914-TN275).

17 The historic range of the Indiana bat includes much of the eastern United States in which the 18 species has greatly declined (NatureServe 2017-TN5216). Significant threats to the Indiana bat 19 include human-induced disturbance and alterations at hibernation sites; loss, fragmentation, and 20 isolation of summer and fall swarming/spring staging habitat; contaminants (may affect bat 21 health and decrease prey base); wind power development (collisions with equipment and 22 barotrauma); and WNS (FWS 2007-TN934, FWS 2006-TN4167).

23 M.6.1.2.2 Life History 24 Bats enter hibernation by late November when prey are typically no longer available and survive 25 on stored fat until spring (NatureServe 2017-TN5216; FWS 2017-TN5346). Indiana bats roost 26 in caves or mines with configurations that provide suitable temperatures and humid 27 microclimates. Roosts are usually located near cave entrances. Hibernacula often contain 28 large assemblages of several species of bats, including little brown bats (Myotis lucifugus),

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1 northern long-eared bats (Myotis septentrionalis), tri-colored bats (Perimyotis subflavus), gray 2 bats, big brown bats (Eptesicus fuscus) and silver-haired bats (Lasionycteris noctivagans) 3 (FWS 2017-TN5346).

4 Female Indiana bats emerge first from hibernation by late March or early April, followed by 5 males. Most individuals have completely left their hibernacula by late April. Spring staging for 6 Indiana bats occurs in late March or early April, following hibernation, when most individuals 7 emerge and forage for a few days or weeks near their hibernaculum before migrating to their 8 traditional summer roosting areas. During spring staging, bats exit the hibernacula to feed, but 9 re-enter the same or alternative hibernacula to resume torpor (FWS 2017-TN5346).

10 Spring migration to summer roosting areas is stressful due to low fat reserves and food 11 supplies. As a result, adult mortality may be highest during late March and April (FWS 2017-12 TN5346). Fertilization occurs in spring, a single pup is born in June or July, and volancy (i.e.,

13 weaning) occurs between mid-July and mid-August (NatureServe 2017-TN5216; FWS 2017-14 TN5346). Mortality between birth and volancy has been determined to be about 8 percent 15 (FWS 2017-TN5346).

16 In summer and fall, Indiana bats primarily use wooded or semi-wooded habitats, usually near 17 water, and hunt flying aquatic and terrestrial insects along riparian areas, ponds, and wetlands, 18 but also in upland forests and fields (NatureServe 2017-TN5216). They typically forage in and 19 around tree canopies and within floodplain, riparian, and upland forest openings. Ideal foraging 20 habitat would have 50 to 70 percent canopy closure (FWS 2017-TN5346). The Indiana bat also 21 may persist in highly altered and fragmented forest landscapes. Instances have been 22 documented of bats using forests altered by grazing, swine feedlots, row-crops, hay fields, 23 residential developments, clearcut timber harvests and shelterwood cuts. Roosts have been 24 found near lightly traveled, low-maintenance roads, as well as higher disturbances areas, such 25 as the Indianapolis Airport, Indiana, in the vicinity of Interstate 70 (FWS 2017-TN5346).

26 Indiana bat maternity colonies most commonly consist of 60 to 100 adult females and typically 27 occupy multiple roosts in riparian bottomland and upland forests. Roost trees have exfoliating 28 bark (which allows the bat to roost between the bark and bole of the tree), a southeast or south-29 southwest solar exposure, and an open canopy. Roost trees are often located on forest edges 30 or openings with open canopy and open understory. A variety of trees are used for roosts, 31 including both conifers and hardwoods. Roost tree use is primarily related to the local 32 availability of trees with suitable structure rather than a preference for a particular species.

33 Roosts are transient and frequently associated with dead or dying trees. Roost longevity is 34 variable due to many factors such as the bark sloughing off or the tree falling down. Indiana bat 35 maternity sites generally consist of one or more primary maternity roost trees, which are used 36 repeatedly by large numbers of bats, and varying numbers of alternate roosts, which may be 37 used less frequently and by smaller numbers of bats. Primary maternity roosts are often located 38 in openings or at the edge of forests, while alternate roosts can be in either openings or the 39 interior of forests. It is not known how many alternate roosts must be available to assure 40 retention of a colony within a particular area, but large, nearby, forest tracts improve the 41 potential for an area to provide adequate roosting habitat. Trees in excess of 15.7 in. in 42 diameter at breast height (DBH) are considered optimal for maternity colonies. Trees in excess 43 of 8.6 in. DBH are used as alternate roosts by Indiana bats. However, females have also been M-54

1 documented using roost trees as small as 5.5 in. DBH. Distances between roosts can vary from 2 a few yards up to a few miles. Day and night roosts may be different (FWS 2007-TN934, 3 FWS 2017-TN5346). Indiana bats exhibit strong site fidelity to their traditional summer 4 maternity colony areas and foraging habitat and annually return to the same sites in the summer 5 (FWS 2017-TN5346).

6 Many male Indiana bats appear to remain at or near the hibernacula in summer and some fan 7 out in a broad band around the hibernacula. Males roost singly or in small groups in two to five 8 roost trees, similar to those used by females. Because males typically roost individually or in 9 small groups, the average size of their roost trees tends to be smaller than the roost trees used 10 by female maternity colonies; males have been observed roosting in trees as small as 2.5 in.

11 DBH. Males have shown summer site fidelity and have been recaptured in the same foraging 12 areas as they had used in prior years (FWS 2017-TN5346).

13 Bats accumulate fat reserves in late summer for fall migration. Most Indiana bats arrive at their 14 traditional hibernacula in August or September and begin to swarm. Swarming assists with 15 mating and foraging (NatureServe 2017-TN5216) until sufficient fat reserves have been 16 deposited to sustain the bats throughout the winter (FWS 2017-TN5346). During swarming, 17 most bats will continue to roost individually in trees during day light hours and forage within 2 to 18 3 mi of the hibernacula; however, some have been found up to 5 mi or further from hibernacula 19 (FWS 2017-TN5346).

20 M.6.1.2.3 Critical Habitat 21 Critical habitat has been designated for the Indiana bat (42 FR 47840-TN5355; FWS 2017-22 TN5357). The only critical habitat in Tennessee is White Oak Blowhole Cave in Blount County 23 (FWS 2007-TN934, FWS 2009-TN5356), which does not occur in the vicinity of the CRN Site.

24 M.6.1.2.4 Site and Vicinity Baseline 25 Indiana bats were surveyed with mist nets and acoustically July 11-21, 2011 at eight locations 26 across the CRN Site (LeGrand et al. 2015-TN5188). The species was surveyed acoustically in 27 fall (October), spring (April), and summer (July) 2013 at six locations across the CRN Site 28 (LeGrand et al. 2015-TN5188). The species was surveyed acoustically at four locations across 29 the BTA in fall (November) 2014 and spring (April) and summer (June) 2015 (Hamrick 2015-30 TN5187; LeGrand et al. 2015-TN5188). The species was not detected with mist nets or 31 acoustically in 2011 but was detected acoustically in 2013 both on the CRN Site and in the BTA 32 (17 recordings on the CRN Site and four recordings in the BTA [note that multiple recordings 33 may be from one individual]). Recordings from the BTA identified as belonging to the Indiana 34 bat could not be considered definitive (Hamrick 2015-TN5187; LeGrand et al. 2015-TN5188).

35 Because there were no mist-net captures and few acoustic recordings over three seasons, use 36 of the CRN Site and BTA by the species for maternal roosting is unlikely. The closest known 37 Indiana bat maternity roost is in Cherokee National Forest in Blount County, at least 30 mi east 38 of the CRN Site (TWRA 2017-TN5362). The CRN Site and BTA are most likely used for 39 roosting and foraging by males and nonreproductive females, which roost singly or in small 40 groups.

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1 A roost tree study was conducted by TVA in areas of forest cover on the CRN Site in January, 2 April, and May 2011, and the site was found to provide suitable roosting habitat (LeGrand et 3 al. 2015-TN5188). The roost tree study did not include the BTA. Based on general 4 observations of tree size and bark conditions made during the surveys of plant communities on 5 the BTA in May 2015 (Cox et al. 2015-TN5193), TVA has stated that the deciduous forest in the 6 BTA also should be considered suitable Indiana bat roosting habitat.

7 The Indiana bat was detected acoustically in areas across the ORR in 2013, 2014, and 2015 8 (McCracken et al. 2015-TN5287). The species also was detected acoustically in areas across 9 the ORR from April 15-October 31 in 2013, 2014, and 2015 (TDEC 2014-TN5288; 10 Middleton 2014-TN5347, Middleton 2015-TN5348, Middleton 2016-TN5349), including those 11 closely surrounding the CRN Site (e.g., Grassy Creek in the northwest portion of the Grassy 12 Creek Habitat Protection Area and the junction of Bear Creek Valley Road and Highway 95 13 located just northeast of the CRN Site) and in the BTA in 2013 (e.g., Gallaher Cemetery just 14 north of the BTA) (TDEC 2014-TN5288). Across the ORR, the Indiana bat appears to be the 15 least prevalent of the Federally listed species considered in this BA (Table M-8). A male 16 Indiana bat was captured on the ORR during a mist-net survey (at Freels Bend) in June 2013 17 (TDEC 2014-TN5288; McCracken et al. 2015-TN5287), confirming the species is present on the 18 ORR during the non-hibernating season. This was the first confirmation of an Indiana bat on the 19 ORR since 1950 (TDEC 2014-TN5288).

20 No known caves are located on the CRN Site or in the BTA, but Rennies Cave and 2-Batteries 21 Cave are located within Grassy Creek Habitat Protection Area, and there are three additional 22 caves/karst openings near Grassy Creek (LeGrand et al. 2015-TN5188). Because the species 23 was detected only in spring and summer but not fall (when swarming in the vicinity of a 24 hibernaculum would occur), either on the CRN Site or in the BTA, a hibernaculum probably is 25 not located in the immediate vicinity at this time. The closest known Indiana bat hibernacula are 26 Grassy Cove Saltpeter (Cumberland County) and White Oak Blowhole (Blount County, Great 27 Smoky Mountains National Park), both more than 30 mi from the CRN Site (TWRA 2017-28 TN5362).

29 M.6.1.3 Northern Long-Eared Bat 30 M.6.1.3.1 Status and Threats 31 The northern long-eared bat (NLEB; Myotis septentrionalis) was listed as a threatened species 32 on May 4, 2015 (80 FR 17974-TN4216), in response to the effects of WNS (78 FR 61046-33 TN3207), which continues to spread across the remainder of the species range. The NLEB 34 ranges over the eastern and north-central United States (76 FR 38095-TN1798) and has 35 experienced a 99 percent population reduction across the northeastern portion of its range due 36 to WNS. A final rule under the authority of Section 4(d) of the ESA, providing measures that are 37 necessary and advisable for conservation of the NLEB, also became effective on May 4, 2015 38 (80 FR 17974-TN4216).

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1 M.6.1.3.2 Life History 2 NLEBs hibernate in caves or inactive mines (76 FR 38095-TN1798), but they may also 3 overwinter in similar manmade structures (e.g., railroad tunnels, sewers, aqueducts, wells).

4 NLEBs enter hibernation in October and November, and leave the hibernacula in March or April 5 (76 FR 38095-TN1798). Other species that commonly occupy the same hibernacula include 6 little brown bat, big brown bat, eastern small-footed bat, tri-colored bat, and Indiana bat 7 (FWS 2017-TN5346). Breeding occurs when males swarm hibernacula from late summer to 8 early fall (78 FR 61046-TN3207) and may also occur around hibernacula during spring staging 9 (76 FR 38095-TN1798). Fertilization of a single egg occurs in the spring after hibernation 10 (78 FR 61046-TN3207). NLEBs may migrate 35 to 55 mi between hibernacula and summer 11 roosts (FWS 2017-TN5346). Birth of a single pup occurs in May to early June and volancy 12 occurs in 21 days (78 FR 61046-TN3207).

13 Summer roosting habitat generally consists of late-successional forests with intact interior forest 14 habitat, which typically provide a relatively large number of partially dead or decaying trees that 15 the species uses for breeding, summer day roosting, and gleaning insects (76 FR 38095-16 TN1798). The species prefers forested hillsides and ridges for foraging, including hawking 17 insects over small ponds and forest clearings under the forest canopy or along streams, 18 and occasionally in forest clearings, over water, and along roads (76 FR 38095-TN1798; 19 78 FR 61046-TN3207). Summer habitat may also include some adjacent and interspersed 20 non-forested habitats (e.g., old fields) as well as linear features (e.g., riparian forest) 21 (78 FR 61046-TN3207).

22 During the summer, the species roosts underneath tree bark or in cavities or crevices of both 23 live and dead trees (Johnson et al. 2011-TN1852; 78 FR 61046-TN3207). Females may form 24 small maternity colonies (30 to 60 individuals) behind exfoliating bark (76 FR 38095-TN1798; 25 FWS 2017-TN5346). Males typically roost singly and nonreproductive females roost singly or in 26 small groups (76 FR 38095-TN1798) behind exfoliating bark, and both may also roost in caves 27 and mines (78 FR 61046-TN3207). NLEBs likely are not dependent on certain tree species for 28 roosts, but use trees that form suitable cavities or bark structure opportunistically. NLEBs may 29 switch roosts often, typically every 2 to 3 days (FWS 2017-TN5346).

30 Suitable summer forest habitat consists of a wide variety of wooded habitats where the species 31 roosts, forages, and travels, and may include some adjacent and interspersed non-forested 32 habitats such as emergent wetlands and adjacent edges of agricultural fields, old fields and 33 pastures (80 FR 17974-TN4216). This includes forests and woodlots containing suitable roost 34 trees (i.e., live trees and/or snags 3 in. DBH that have exfoliating bark, cracks, crevices, and/or 35 cavities), as well as linear features such as fencerows, riparian forests, and other wooded 36 corridors with dense or loose aggregates of trees with variable amounts of canopy closure.

37 NLEBs typically occupy summer habitat from mid-May through mid-August (80 FR 17974-38 TN4216). Spring staging/fall swarming habitat is similar and occurs most typically within 5 mi of 39 a hibernaculum (FWS 2014-TN4162). NLEBs typically occupy their spring staging/fall swarming 40 habitat from between hibernation and migration to summer habitat and after migration from 41 summer habitat to hibernacula but before hibernation (80 FR 17974-TN4216).

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1 M.6.1.3.3 Critical Habitat 2 Critical habitat has not been designated for the NLEB.

3 M.6.1.3.4 Site and Vicinity Baseline 4 One individual was captured in mist nets in the summer of 2011 on the CRN Site, and there was 5 a total of 25 to 32 acoustic recordings in spring, summer, and fall on the CRN Site and in the 6 BTA in 2013 and 2015 (Hamrick 2015-TN5187; LeGrand et al. 2015-TN5188). The sex, age, 7 and reproductive condition of the captured individual were not documented (LeGrand et 8 al. 2015-TN5188). Because there was only one mist-net capture and few acoustic recordings 9 over three seasons, use of the CRN Site and BTA by the species for maternal roosting is 10 unlikely. The closest known NLEB maternity roost is in the Catoosa Wildlife Management Area 11 in Morgan County, at least 20 mi west of the CRN Site (TWRA 2017-TN5362). The CRN Site 12 and BTA are most likely used for roosting and foraging by males and nonreproductive females, 13 which roost singly or in small groups.

14 The NLEB was captured in mist nets on the ORR in 1997, 2006, 2011, and 2013 (McCracken et 15 al. 2015-TN5287). The species was also detected acoustically in areas across the ORR from 16 April 15 to October 31 in 2013, 2014, and 2015 (TDEC 2014-TN5288; Middleton 2014-TN5347, 17 Middleton 2015-TN5348, Middleton 2016-TN5349), including those closely surrounding the 18 CRN Site in 2013 (e.g., Grassy Creek in the northwest portion of the Grassy Creek Habitat 19 Protection Area and the junction of Bear Creek Valley Road and Highway 95 located just 20 northeast of the CRN Site) (TDEC 2014-TN5288). None was detected in close proximity to the 21 BTA in 2013 (TDEC 2014-TN5288). Across the ORR, the NLEB bat appears to be less 22 prevalent than the gray bat but more prevalent than the Indiana bat (Table M-7).

23 Thus, suitable habitat for the Indiana bat on the CRN Site and in the BTA (discussed above) is 24 also suitable for the NLEB for summer and fall roosting and foraging. Acoustic recordings 25 during the fall may indicate the presence of a hibernaculum in the vicinity, but this is based on 26 only four fall recordings. A hibernaculum about 8 to 9 mi away was discovered by TVA in 27 January 2014 (LeGrand et al. 2015-TN5188), likely located in Marble Bluff Cave in Roane 28 County (TWRA 2017-TN5362). Suitable habitat on the CRN Site and in the BTA likely also 29 contains NLEB potential roost trees from 3 to 5 in. DBH that are unsuitable for the Indiana bat.

30 There may also be early successional forest parcels on the CRN Site and in the BTA that were 31 not considered in the Indiana bat roost tree study (discussed above) and would not provide 32 suitable habitat for the Indiana bat because of a prevalence of smaller-diameter trees, but may 33 provide suitable roosting habitat for the NLEB.

34 M.6.1.4 Tri-Colored Bat 35 M.6.1.4.1 Status and Threats 36 The tri-colored bat (Perimyotus subflavus) ranges across most of eastern North America. The 37 species was petitioned for listing under the ESA in June 2016 (CBD and DoW 2016-TN5360),

38 and in December 2017, FWS found the petitioned action may be warranted (82 FR 60362-39 TN5416). Threats to the species cited in support of the petition to list include WNS, habitat loss 40 and degradation driven by agricultural and residential development, logging, mining and other M-58

1 resource extractive practices, industrial wind energy, environmental contaminants, and 2 disturbance by vandalism and recreation. WNS has resulted in a dramatic drop in tri-colored 3 bat populations throughout much of its range (greater than 98 percent in the northeastern 4 United States). Prior to WNS, the tri-colored bat was in a state of gradual decline in the eastern 5 United States (by 34 percent in New York, Pennsylvania, West Virginia, and Tennessee). Local 6 declines of tri-colored bat populations began 3 to 7 years prior to the detection of WNS in those 7 populations. The causes for the tri-colored bats pre-WNS decline are presumably ongoing in 8 the post-WNS environment and likely include loss and disturbance of critical roost and foraging 9 sites; toxicity from agricultural pesticides and other chemical compounds; altered roost 10 microclimates, foraging habitats, and prey communities from climate change; and heightened 11 mortality from inflight collisions with vehicles, buildings, and wind turbines (CBD and DoW 2016-12 TN5360).

13 M.6.1.4.2 Life History 14 The tri-colored bat is an insectivorous bat that is found in a variety of terrestrial habitats, 15 including grasslands, old fields, suburban areas, orchards, urban areas, and woodlands, 16 especially hardwood woodlands. However, they generally avoid deep woods as well as large, 17 open fields (CBD and DoW 2016-TN5360). The species prefers large trees and woodland 18 edges (CBD and DoW 2016-TN5360; NatureServe 2017-TN5216), and often forages over 19 waterways and forest edges (CBD and DoW 2016-TN5360; TNBWG 2017-TN5359).

20 Summer roosts are mainly in live and dead foliage in both live and dead deciduous and 21 coniferous trees (CBD and DoW 2016-TN5360; TNBWG 2017-TN5359), and occasionally in 22 buildings (NatureServe 2017-TN5216). Forest on the CRN Site and in the BTA likely provides 23 suitable summer roost habitat for the species. Females exhibit a fairly high degree of roost 24 fidelity, returning to the same small roosting area day after day within a single summer and 25 across successive years. However, tri-colored females may switch specific roost sites 26 frequently during the maternity period. Males exhibit a somewhat lesser degree of roost fidelity 27 than females (CBD and DoW 2016-TN5360).

28 Hibernation sites usually are in caves or mines (NatureServe 2017-TN5216; TNBWG 2017-29 TN5359). Mating occurs in autumn during swarming around hibernation sites, sperm are stored 30 during winter, and fertilization takes place in early spring. The species usually bears twins in 31 late spring or early summer (CBD and DoW 2016-TN5360; TNBWG 2017-TN5359). In southern 32 portions of their range, females arrive from hibernacula beginning in late April (CBD and 33 DoW 2016-TN5360). Maternity colonies use manmade structures or tree cavities, often in open 34 areas (NatureServe 2017-TN5216). Maternity colonies are small, often consisting of from 35 several individuals to several tens of individuals (CBD and DoW 2016-TN5360). Young grow 36 rapidly and can fly within a month (TNBWG 2017-TN5359).

37 M.6.1.4.3 Critical Habitat 38 Critical habitat has not been designated for the tri-colored bat (and cannot be designated, as 39 this species is not yet formally listed as threatened or endangered).

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1 M.6.1.4.4 Site and Vicinity Baseline 2 Three individuals were caught in mist nets on the CRN Site in 2011 and the species was 3 recorded acoustically (the number of recordings was undocumented) on the CRN Site and in 4 the BTA in spring, summer, and fall in 2013 and 2015 (LeGrand et al. 2015-TN5188). The sex, 5 age, and reproductive condition of the captured individuals were not documented (LeGrand et 6 al. 2015-TN5188). The species was the most prevalent species acoustically recorded in the 7 BTA in 2015 (Hamrick 2015-TN5187). Recordings of the species in the fall may indicate a 8 possible hibernaculum in the vicinity of the CRN Site or BTA. Roosting bats were observed in 9 Rennies Cave by archaeological surveyors in April 2011. One bat was identified from a photo 10 as a tri-colored bat (LeGrand et al. 2015-TN5188).

11 The species was detected acoustically in areas across the ORR in 2013, 2014, and 2015 12 (McCracken et al. 2015-TN5287). The species also was detected acoustically in areas across 13 the ORR from April 15 to October 31 in 2013, 2014, and 2015 (TDEC 2014-TN5288; 14 Middleton 2014-TN5347, Middleton 2015-TN5348, Middleton 2016-TN5349), including those 15 closely surrounding the CRN Site in 2013 (e.g., Grassy Creek in the northwest portion of the 16 Grassy Creek Habitat Protection Area, the junction of Bear Creek Valley Road and Highway 95 17 located just northeast of the CRN Site, and along the Clinch River between the CRN Site and 18 Jones Island) (TDEC 2014-TN5288). None were detected in close proximity to the BTA in 2013 19 (TDEC 2014-TN5288). Across the ORR, the tri-colored bat appears to be more prevalent than 20 the little brown bat, and more prevalent than the three Federally listed bat species considered in 21 this BA (Table M-7).

22 M.6.1.5 Little Brown Bat 23 M.6.1.5.1 Status and Threats 24 The little brown bat (Myotis lucifugus) was petitioned for listing under the ESA in 2010 (Kunz 25 and Reichard 2010-TN5373). The range of the little brown bat extends across North America, 26 from Alaska to central Mexico and from the Pacific to Atlantic coasts. The little brown bat was 27 considered one of the most common and widespread bat species in North America. Its core 28 range is considered the northeastern United States where ideal hibernacula conditions 29 predominate and the vast majority of ideal habitat is found. Numbers substantially decrease 30 southward and westward in this core area. The pre-WNS population of this speciesboth 31 throughout its range and within its core northeastern rangewas viable and did not face 32 imminent risk of extinction. However, extinction is virtually certain to occur in the core range of 33 this species by 2026, and range-wide extinction may very well follow based on the known and 34 predicted infection dynamics of WNS. This conclusion is based on a thorough population 35 viability analysis incorporating extensive empirical data collected before and since the 36 appearance of WNS in the species core range, including the species starting population, vital 37 rates, and observed morbidity rates. Other natural and manmade factors that have an adverse 38 impact on the species include climate change (reduced rainfall in late summer in the 39 northeastern United States resulting in reduced insect production and drying up of water 40 sources) and pollutants in waterbodies (Kunz and Reichard 2010-TN5373).

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1 M.6.1.5.2 Life History 2 Caves and mines serve as swarming sites during the autumn mating period and as hibernacula 3 (NatureServe 2017-TN5216). The little brown bat swarms and mates at hibernacula, and 4 females store sperm during hibernation with fertilization occurring in spring after emergence 5 (Kunz and Reichard 2010-TN5373).

6 In spring, reproductive female bats form maternity colonies in barns, attics, and tree cavities.

7 Maternity colonies range in size from tens to hundreds of individuals. Fidelity of females to 8 summer roosts tends to be high with adult females typically returning to their natal roosts.

9 Nonreproductive females and adult males usually inhabit separate roosts individually or in small 10 groups. A single pup is born during the late spring/early summer timeframe. Pups are weaned 11 and begin to fly at about 26 days (Kunz and Reichard 2010-TN5373).

12 The little brown bat feeds on aerial insects over open water (Kunz and Reichard 2010-TN5373) 13 and along the margins of lakes and streams, or in woodlands near water (NatureServe 2017-14 TN5216). First-year survival of female little brown bat ranges from 23 to 46 percent, and adult 15 survival rate was 63 to 90 percent from 1993 to 2008 (Kunz and Reichard 2010-TN5373).

16 M.6.1.5.3 Critical Habitat 17 Critical habitat has not been designated for the little brown bat (and cannot be designated, as 18 this species is not yet formally listed as threatened or endangered).

19 M.6.1.5.4 Site and Vicinity Baseline 20 The species was not captured in mist nets on the CRN Site in 2011 (LeGrand et al. 2015-21 TN5188). It was recorded acoustically (the number of recordings was undocumented) on the 22 CRN Site and in the BTA in spring, summer, and fall in 2013 and 2015 (LeGrand et al. 2015-23 TN5188; Hamrick 2015-TN5187). Recordings of the species in the fall may indicate a possible 24 hibernaculum in the vicinity of the CRN Site or BTA.

25 The species was detected acoustically in areas across the ORR in 2013, 2014, and 2015 26 (McCracken et al. 2015-TN5287). The species also was detected acoustically in areas across 27 the ORR from April 15-October 31 in 2013, 2014, and 2015 (TDEC 2014-TN5288; 28 Middleton 2014-TN5347, Middleton 2015-TN5348, Middleton 2016-TN5349), including those 29 closely surrounding the CRN Site (e.g., Grassy Creek in the northwest portion of the Grassy 30 Creek Habitat Protection Area, the junction of Bear Creek Valley Road and Highway 95 located 31 just northeast of the CRN Site, and along the Clinch River between the CRN Site and Jones 32 Island) and in the BTA in 2013 (e.g., Gallaher Cemetery just north of the BTA) (TDEC 2014-33 TN5288). Across the ORR, the little brown bat appears to be less prevalent than the tri-colored 34 bat, and less prevalent than the gray bat but more prevalent than the Indiana bat and NLEB 35 (Table M-7).

36 M.6.1.6 Freshwater Mussels - Pink Mucket (Lampsilis abrupta) and Sheepnose 37 Mussel (Plethobasus cyphyus) 38 M.6.1.6.1 Status and Threats 39 Mussel populations have declined in the last several decades in species diversity and at an 40 individual level. Population declines are caused by habitat destruction and degradation and M-61

1 their inability to move from poor-quality habitat. Habitat destruction includes impoundment by 2 dams, dredging and channelization as well as erosion, siltation, and contamination of the 3 environment. Most habitat destruction and degradation is caused by human activities, but the 4 expansion of populations of nonindigenous mollusks such as the zebra mussel (Dreissena 5 polymoprha) and the Asian clam (Corbicula fluminea) is negatively affecting the remaining 6 native mussel populations (Williams et al. 1993-TN5369).

7 The FWS identified two species of unionid mussels from the vicinity of the CRN Site: the pink 8 mucket (Lampsilis abrupta) and the sheepnose mussel (Plethobasus cyphyus). The FWS 9 designated the pink mucket mussel as endangered in 1976 (41 FR 24062-TN5173). The FWS 10 listed the sheepnose mussel as endangered in the Federal Register on March 13, 2012 (77 FR 11 14914-TN5177).

12 M.6.1.6.2 Life History of Unionid Mussels 13 Mussels spend their entire juvenile and adult lives buried either partially or completely in the 14 substrate. Many factors may affect the preferred habitat of mussels, including substrate 15 composition, water depth, water temperature and velocity, turbidity, and bottom roughness 16 (Williams et al. 2008-TN5372). Although mussels are able to change their position and location, 17 they rarely move more than a few hundred yards during their lifetime unless dislodged.

18 Reservoirs have been documented as uninhabitable for the majority of mussel species (Williams 19 et al. 2008-TN5372). Williams et al. (2008-TN5372) reported mussel extirpation from the area 20 downstream of Norris Dam, caused by a decrease in water temperature and dissolved oxygen, 21 as was well as scouring effects from dam discharge.

22 Native freshwater mussels have an unusual reproductive cycle. Although some species are 23 hermaphroditic, the species discussed in this BA have separate sexes. The eggs of female 24 mussels move from the ovaries to the gills where fertilization occurs. Sperm is released to the 25 water by male mussels and is carried into the females body through the incurrent aperture.

26 The gills, or a portion of the gills, serve as brood pouches, called marsupia. The fertilized eggs 27 develop into small larvae, called glochidia, which release into the water. At the time of their 28 release from the marsupia, the glochidia possess only the embryonic stages of a mouth, 29 intestines, a foot, and a heart. If the glochidia do not encounter a passing fish and attach to its 30 gills, skin, or fins then they fall to the bottom and die a short time later. The glochidia usually 31 remain on the fish from 1 to 6 weeks (sometimes longer) and then fall off and begin their growth 32 into adulthood. Each mussel species has specific species of fish that serve as a host fish for 33 the glochidia (Parmalee and Bogan 1998-TN5166). The survival of freshwater mussel species 34 depends not only on the environmental conditions for the mussel, but on the survival and health 35 of the host fish populations.

36 Pink muckets have several species of fishes that reportedly serve as hosts for their glochidia, 37 including three species of bass: smallmouth (Micropterus dolomieu), spotted (M. punctulatus),

38 and largemouth bass (M. salmoides) as well as freshwater drum (Aplodinotus grunniens) and 39 possibly sauger (Sander canadensis) (Mirarchi et al. 2004-TN5174). Fish community sampling 40 by TVA in February, May, July, and October of 2011 at stations extending from CRM 14 to 16 41 and CRM 18 to 19.8 indicated the presence of all five host fish species (TVA 2013-TN5167).

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1 For sheepnose mussel glochidia, the sauger (Sander canadensis) is the only known host 2 (Parmalee and Bogan 1998-TN5166). However, Williams et al. (2008-TN5372) reported central 3 stoneroller (Campostoma anomalum) as a host for sheepnose glochidia in a laboratory setting.

4 Only the sauger was identified in TVAs fish community sampling from the vicinity of the CRN 5 Site. Sheepnose mussels live nearly 30 years (77 FR 14914-TN5177).

6 M.6.1.6.3 Critical Habitat 7 Currently no critical habitat has been designated for either the pink mucket (FWS 2017-TN5370) 8 or the sheepnose mussel (FWS 2017-TN5371).

9 M.6.1.6.4 Site and Vicinity Baseline 10 The pink mucket mussels prefer free-flowing reaches of large rivers, typically in gravel 11 substrates with interstitial sand but silt-free. They have also been occasionally reported in large 12 creeks and small rivers (Williams et al. 2008-TN5372). Historically, the pink mucket species 13 was recorded from the Mississippi, Ohio, and Cumberland Rivers and in the Tennessee River 14 up to the lower Clinch River (Parmalee and Bogan 1998-TN5166). Currently, it occurs only in 15 the riverine reaches such as downstream of Wilson Dam in Tennessee and Guntersville Dam in 16 Alabama (Mirarchi et al. 2004-TN5174) and in the Cumberland River in Smith County, 17 Tennessee (Parmalee and Bogan 1998-TN5166). Researchers report specimens younger than 18 10 years of age as rare in the Wilson and Guntersville Dam tailwaters.

19 The most recent siting of a pink mucket in the Clinch River was in 1984 at CRM 19.1, slightly 20 above the CRN Site. No pink muckets, either living or as relic shells, were found in the 2011 21 surveys at the CRN Site. TVA has found the pink mucket mussel more recently elsewhere in 22 the Tennessee River system. A single individual was found as recently as a September 2010 23 survey (TRC 2010-TN5175) in the tailrace of Watts Bar Dam in Chickamauga Reservoir.

24 Sheepnose mussels prefer flowing water of medium to large rivers in a sand and gravel 25 substrate mixture (Williams et al. 2008-TN5372; Parmalee and Bogan 1998-TN5166). Further, 26 in unimpounded rivers sheepnose mussels can be found in less than 0.6 m (2 ft) of water and 27 in relatively fast currents. In reservoirs, sheepnose mussels can be found at depths of 3.6 to 28 4.6 m (12 to 15 ft) (Parmalee and Bogan 1998-TN5166), though they have also been reported 29 at depths exceeding 6 m (20 ft) (77 FR 14914-TN5177).

30 They occur across the Southeast and the Midwest, but are likely extirpated from two-thirds of 31 streams where they had previously been known to occur. Parmalee and Bogan (1998-TN5166) 32 indicated that the most stable and viable populations of sheepnose mussels in Tennessee were 33 located in the upper Clinch River (Hancock County) and below Pickwick Landing Dam (Harding 34 County) in the Tennessee River. The sheepnose mussel was last observed in 1994 at CRM 35 21.4 downstream of Melton Hill Dam (TWRA 2017-TN5362). More recent sightings have 36 occurred elsewhere in the Tennessee River system. In September 2010, TVA found a 37 specimen, judged to be approximately 20 years old, during sampling in the tailrace of Watts Bar 38 Dam in Chickamauga Reservoir (TRM 526 to 527) (TRC 2010-TN5175). The sheepnose is 39 known to have existed recently farther upstream in the Clinch River above CRM 168 and the 40 last recorded sightings occurred between 2004 and 2006 (Jones et al. 2014-TN5324).

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1 Neither the pink mucket or the sheepnose mussel were observed in benthic macroinvertebrate 2 sampling in 2011 at either of two locations, CRM 15.0 (slightly downstream from the proposed 3 discharge) and CRM 18.8 (approximately a mile upstream of the proposed intake). As 4 discussed in Section M.3.1.3.2, a total of 74 living native mussels from six different species 5 were collected in 2011 in the Clinch River arm of Watts Barr Reservoir. The mollusk survey 6 observed that zebra mussels were found attached to 71 of the 74 living native mussels. The 7 average area of coverage on an individual mussel was 28 percent and coverage ranged from 8 5 to 100 percent (TRC 2011-TN5168). It appears that zebra mussels are out-competing native 9 mussels for space and food, interfering with the native mussels ability to open and close their 10 shells, impairing movement of the native mussels, and depositing metabolic wastes on the 11 native mussels (FWS 2015-TN5218). Based on the sampling studies and the condition of the 12 living native mussels it is unlikely that either the pink mucket or the sheepnose mussel species 13 would be located in the Clinch River arm of the Watts Bar Reservoir.

14 M.6.1.7 Spotfin Chub (Erimonax monachus) 15 M.6.1.7.1 Status and Threats 16 The FWS listed the spotfin chub (Erimonax monachus) (= Cyprinella monacha = Hybopsis 17 monacha) as threatened in 1977 (42 FR 45526-TN5178). Threats to the spotfin chub include 18 habitat destruction and degradation such as from siltation, and runoff from coal mining, 19 operations, and municipal and industrial wastes (42 FR 45526-TN5178).

20 M.6.1.7.2 Life History 21 The estimated age of maturity for spotfin chub is 2 years. Spotfin chubs are estimated to live for 22 3 or 4 years, and adults may spawn in consecutive years. They are crevice spawnerstheir 23 eggs are deposited in rock crevices on the bottom of the stream, and they prefer the lowermost 24 crevices (adjacent to the substrate) (Rakes et al. 1999-TN5367). There is no parental care of 25 the eggs or guarding of the nest after spawning. Spotfin chub larvae and juveniles are benthic 26 after hatching and do not shift to the middle of the water column until their total length is 1.8 to 27 2.3 cm (0.71 to 0.91 in.). Once large enough, the spotfin chub is typically a mid-water schooling 28 minnow (Shute et al. 2005-TN5366). As adults, spotfin chub are small fish, less than 12.1 cm 29 (4.75 in.) long.

30 Spotfin Chub inhabit clear upland rivers and are typically found in habitats with boulders in swift 31 currents. Their diet is primarily aquatic insects such as midges, mayflies, and caddisfly larvae 32 (Etnier and Starnes 1993-TN5054).

33 M.6.1.7.3 Critical Habitat 34 Critical habitat for the spotfin chub exists in Tennessee in portions of the Emory River in Morgan 35 County and the Obed River, Clear Creek, and Daddys Creek in Morgan and Cumberland 36 Counties. Critical habitat in Tennessee also exists in the North Fork of the Holston from the 37 junction with the South Fork Holston River to the Tennessee- Virginia State line in Hawkins and 38 Sullivan Counties. No critical habitat exists in Roane County near the CRN Site.

M-64

1 M.6.1.7.4 Site and Vicinity Baseline 2 The spotfin chub were historically found in Alabama, Georgia, North Carolina, Virginia, and 3 Tennessee inhabiting streams in upper and middle Tennessee River Basin (FWS 2017-TN5219; 4 Holliman et al. 2003-TN5364). Experimental populations are now found in three river systems 5 including the Tennessee portions of Tellico River, Shoal Creek, French Broad River, and 6 Holston River (FWS 2017-TN5219).

7 It is unlikely that spotfin chub still inhabit the Clinch River arm of the Watts Bar Reservoir 8 because of siltation and changes in the river-bottom substrate that would prevent them from 9 spawning. The Clinch River arm of the Watts Bar Reservoir adjacent to the CRN Site lacks the 10 appropriate habitat features for spotfin chub. Furthermore, the spotfin chub was not identified in 11 the sampling that occurred Clinch River or the streams on the CRN Site or in the transmission 12 corridor within the vicinity of the CRN Site during electrofishing studies between CRM 14 and 15 13 and CRM 18 and 19.8 (TVA 2013-TN5167). It is unlikely that the spotfin chub is present in the 14 vicinity of the site.

15 M.6.1.8 Hellbender 16 M.6.1.8.1 Status and Threats 17 The status of the hellbender (Cryptobranchus alleganiensis), an aquatic salamander, is currently 18 under review by the FWS (2017-TN5365). Threats to the hellbender may include habitat 19 alterations such as siltation, water impoundment, and degradation of water quality (Mayasich et 20 al. 2003-TN5179).

21 M.6.1.8.2 Life History 22 The hellbender, also called the mudpuppy or waterdog grows from 30 to 74 cm (12 to 29 in.)

23 long. Hellbenders are a unique salamander because they are completely aquatic throughout 24 their life history. They tend to be nocturnal in nature, exhibiting positive thigmotaxis (i.e., seeking 25 contact with other objects such as rocks) and negative phototaxis (avoiding light). Hellbenders 26 have a well-developed dermal sense of light, particularly in their tail, which may serve as an 27 initial light exposure receptor (Nickerson et al. 2003-TN5368). Hellbenders are also cannibalistic 28 in nature, consuming its eggs and smaller hellbenders (Nickerson et al. 2003-TN5368).

29 The hellbender prefers habitats with swift running, fairly shallow, highly oxygenated waters that 30 are cool in temperature (Humphries and Pauley 2004-TN5363) and tend to be more alkaline 31 (Nickerson et al. 2003-TN5368). This species finds flat rocks, logs, or other cover in the vicinity 32 of riffle areas, essential for hiding/shelter, feeding, and breeding (Mayasich et al. 2003-TN5179; 33 Humphries and Pauley 2004-TN5363). Its habitat is generally medium to large clear, fast-34 flowing streams with rocky bottoms, especially riffle areas and upper pool reaches. Larvae are 35 typically found under small rocks, juveniles under rock piles or gravel beds, and adults under 36 larger rocks, all in riffles (Nickerson et al. 2003-TN5368). Their diet primarily consists of crayfish 37 (Humphries and Pauley 2004-TN5363).

M-65

1 M.6.1.8.3 Critical Habitat 2 No critical habitat is designated by the FWS for the hellbender.

3 M.6.1.8.4 Site and Vicinity Baseline 4 Hellbenders are found distributed from southern New York, west to Missouri and Arkansas, and 5 south to Alabama and Mississippi (Humphries and Pauley 2004-TN5363). The Clinch River arm 6 of the Watts Bar Reservoir adjacent to the CRN Site lacks the appropriate habitat for the 7 hellbender because it is now impounded and lacks the fast-flowing water over rocky bottoms 8 and riffle areas. But potentially this species could still exist in the area upstream of the site 9 immediately below Melton Hill Dam because the faster moving water in the tailrace provides 10 more suitable habitat. A hellbender was most recently observed in 1989 in the Clinch River 11 downstream of Jones Island within the tailrace below Melton Hill Dam (TNHP 2017-TN5361).

12 This location, however, it is upstream of the CRN Site and would be unaffected by the building 13 or operation of the CRN Site.

14 M.6.2 Offsite Transmission Lines 15 The FWS July 2017 letter (FWS 2017-TN5091) suggested what species to consider in this BA 16 for the offsite transmission lines, based on visual comparison of Figure M-4, a county map of 17 Tennessee, and species known to occur in those counties according to the FWS Information for 18 Planning and Consultation (IPaC) database (FWS 2017-TN5328). In November 2017, the 19 review team generated a more definitive list by overlaying the offsite transmission layer on 20 layers of the counties in Tennessee, Kentucky, and Georgia in ArcGIS (version 10.4) to derive a 21 list of the counties in each state in which the offsite transmission lines occur (Table M-3). The 22 review team then queried IPaC (FWS 2017-TN5328) and the TDEC rare species by county 23 database (TDEC 2017-TN5217) to identify those Federally threatened and endangered species 24 known to occur in each county (Table M-8). As directed in the FWS July 2017 letter 25 (FWS 2017-TN5091), the IPaC (FWS 2017-TN5328) was also queried to identify which of the 26 species also have designated critical habitat in these counties, including counties in which the 27 species are not known to occur (Table M-8).

28 Table M-9 identifies Federally listed species with known occurrences within 0.125 mi of the 29 transmission line segments identified for upgrading in Tennessee (Table M-3), and notes 30 whether the locations lie within the bounds of the existing corridors. Table M-9 was developed 31 using data obtained from the Tennessee Natural Heritage Program (TNHP 2017-TN5361). This 32 table provides a description of the known occurrences as well as the date of most recent 33 observation. Data obtained from the Kentucky and Georgia Natural Heritage Programs 34 (KNSPC 2017-TN5400; GDNR 2017-TN5397) did not identify Federally listed terrestrial or 35 aquatic species with known occurrences within 0.125 mi of the transmission line segments that 36 occur in those states (Table M-9).

37 Habitat preferences for the species identified in Table M-8 are provided in (Table M-10). Table 38 M-10 also indicates the possible presence of suitable habitat for the species within the 39 transmission line corridors in counties where the species are known to occur.

40 M-66

1 Table M-8. Federally Listed Species (not including experimental populations) in the Counties where Upgrades (Uprate, 2 Reconductor, Rebuild) of Offsite Transmission Lines May Occur (FWS 2017-TN5091; TDEC 2017-TN5217). X =

3 species present in county based on IPaC (FWS 2017-TN5328) and TDEC Rare Species by County Database 4 (TDEC 2017-TN5217); Y = critical habitat present in the county; N = no critical habitat designated for the species 5 or critical habitat designated but does not occur in the county. All cells where IPaC indicates the presence of 6 critical habitat in the indicated county are highlighted blue; orange highlighted cells indicate critical habitat in 7 proximity to offsite transmission lines that is depicted in figures provided later in Section M.6.2 State GA KY TN Statusa Catoosa Bell Whitley Anderson Bledsoe Campbell Claiborne Cocke Cumberland Franklin Grainger Greene Grundy Hamblen Hamilton Hawkins Jefferson Knox Putnam Rhea Roane Scott Sequatchie Sevier Van Buren Warren White Scientific Name Common Name Mammals Corynorhinus (=Plecotus) townsendii Virginia big-eared bat E X virginianus N M-67 Glaucomys sabrinus coloratus Carolina northern flying E X squirrel N Myotis grisescens Gray bat E XN X X X X X X X X X X X X X X X X X X X X X X X X X X N N N N N N N N N N N N N N N N N N N N N N N N N N Myotis septentrionalis Northern long-eared bat T XN X X X X X X X X X X X X X X X X X X X X X X X X X X N N N N N N N N N N N N N N N N N N N N N N N N N N Myotis sodalis Indiana bat E XN X X X X X X X X X X X X X X X X X X X X X X X X X X N N N N N N Y N N N N N N N N Y Y N N N N N Y N N N Amphibians Gyrinophilus gulolineatus Berry cave salamander C X X N N Fishes Chrosomus saylori Laurel dace E X X X X X X Y N N Y N Y Erimystax cahni Slender chub T X Y Y X X c

N N N Erimonax monachus Spotfin chub T X X X X X X X X X X X X N N N N Y N N Y N N Y N Etheostoma akatulo Bluemask (Jewel) darter E X X X X X X X X N N N N N N N N Etheostoma lemniscatum Tuxedo darter E X N

8

Table M-8. (contd)

State GA KY TN Statusa Catoosa Bell Whitley Anderson Bledsoe Campbell Claiborne Cocke Cumberland Franklin Grainger Greene Grundy Hamblen Hamilton Hawkins Jefferson Knox Putnam Rhea Roane Scott Sequatchie Sevier Van Buren Warren White Scientific Name Common Name Etheostoma percnurum Duskytail darter E X X N N Etheostoma spilotum Kentucky arrow darter T X N

Etheostoma susanae Cumberland darter E X X X N N N Etheostoma wapiti Boulder darter E X N

Notropis albizonatus Palezone shiner E X N

Noturus crypticus Chucky madtom E X X X X X N Y N N N M-68 Noturus flavipinnis Yellowfin madtom T X Y X N N Noturus stanauli Pygmy madtom E X X N N Percina tanasi Snail darter T XN X X X X X X X X X X X X X X N N N N N N N N N N N N N N Phoxinus cumberlandensis Blackside dace T X X X X X X N N N N N N Mollusks Alasmidonta atropurpurea Cumberland elktoe E X X X X Y X X X X X N Y N Y N Y N N N Alasmidonta raveneliana Appalachian elktoe E X X X X X N N N N N Cumberlandia monodonta Spectaclecase (mussel) E X X X X X X X X X X X X X X X X N N N N N N N N N N N N N N N N Cyprogenia stegaria Fanshell E X X X X X X X X X X X X X X N N N N N N N N N N N N N N Dromus dromas Dromedary pearlymussel E X X X X X X X X X X X X X X X X N N N N N N N N N N N N N N N N Epioblasma brevidens Cumberlandian combshell E X X X Y X X Y X X X X N N Y N Y N N N Y

Table M-8. (contd)

State GA KY TN Statusa Catoosa Bell Whitley Anderson Bledsoe Campbell Claiborne Cocke Cumberland Franklin Grainger Greene Grundy Hamblen Hamilton Hawkins Jefferson Knox Putnam Rhea Roane Scott Sequatchie Sevier Van Buren Warren White Scientific Name Common Name Epioblasma capsaeformis Oyster mussel E X X X X X X X X X X X X Y X X X N N Y Y N Y N Y N N N N N N N Epioblasma florentina walkeri (=E. Tan riffleshell E X X walkeri) N N Epioblasma obliquata Catspaw E X N

Epioblasma torulosa Tubercled blossom E X X X X X X (pearlymussel) N N N N N N Epioblasma triquetra Snuffbox mussel E X X X X X N N N N N Epioblasma turgidula Turgid blossom E X X X X X X X X X X X (pearlymussel) N N N N N N N N N N N M-69 Fusconaia cor Shiny pigtoe E X X X X X X X X X X N N N N N N N N N N Fusconaia cuneolus Finerayed pigtoe E X X X X X X X X X X X X X X X X X N N N N N N N N N N N N N N N N N Hemistena lata Cracking pearlymussel E X X X X X X X X N N N N N N N N Lampsilis abrupta Pink mucket (pearlymussel) E X X X X X X X X X X X X X X X X N N N N N N N N N N N N N N N N Lampsilis virescens Alabama lampmussel E X X X X X X X N N N N N N N Lemiox rimosa Birdwing pearlymussel E X X X X X N N N N N Obovaria retusa Ring pink (mussel) E X X X X X X X N N N N N N N Pegias fabula Littlewing pearlymussel E X X X X X X X X X X X N N N N N N N N N N N Plethobasus cooperianus Orangefoot pimpleback E X X X X X X X X X X X (pearlymussel) N N N N N N N N N N N Plethobasus cicatricosus White wartyback E X X X X X X X X X (pearlymussel) N N N N N N N N N Plethobasus cyphyus Sheepnose mussel E X X X X X X X X X X N N N N N N N N N N

Table M-8. (contd)

State GA KY TN Statusa Catoosa Bell Whitley Anderson Bledsoe Campbell Claiborne Cocke Cumberland Franklin Grainger Greene Grundy Hamblen Hamilton Hawkins Jefferson Knox Putnam Rhea Roane Scott Sequatchie Sevier Van Buren Warren White Scientific Name Common Name Pleurobema clava Clubshell E X N

Pleuronaia gibberum Cumberland pigtoe E X X X X X X X X X N N N N N N N N N Pleurobema plenum Rough pigtoe E X X X X X X X X X X X N N N N N N N N N N N Pleuronaia dolabelloides Slabside pearlymussel E X X X X X Y X X Y X X X X Y Y Y N Y Y N N N Y N Ptychobranchus subtentum Fluted kidneyshell E X X X X X X X X X X Y X Y Y N N Y Y Y Y Y Y N Y N Quadrula cylindrica Rabbitsfoot T X X X N N N M-70 Quadrula cylindrica strigillata Rough rabbitsfoot E X X X X X X X X X N N Y Y N N N N N Quadrula intermedia Cumberland monkeyface E X X X X X N N N N N Quadrula sparsa Appalachian monkeyface E X X N N Toxolasma cylindrellus Pale lilliput (pearlymussel) E X X N N Villosa fabalis Rayed bean E X X X N N N Villosa perpurpurea Purple bean E Y X Y X X X Y Y N N Villosa trabalis Cumberland bean E X X X X X X X X X X X X X X X X X X X X X (pearlymussel) N N N N N N N N N N N N N N N N N N N N N Arachnids Microhexura montivaga Spruce-fir moss spider E X Y

Insects Bombus affinis Rusty-patched bumble bee E X X X N N N Snails

Table M-8. (contd)

State GA KY TN Statusa Catoosa Bell Whitley Anderson Bledsoe Campbell Claiborne Cocke Cumberland Franklin Grainger Greene Grundy Hamblen Hamilton Hawkins Jefferson Knox Putnam Rhea Roane Scott Sequatchie Sevier Van Buren Warren White Scientific Name Common Name Anguispira picta Painted tigersnail T X N

Athearnia anthonyi Anthony's riversnail E X X X X X X N N N N N N Plants Apios priceana Price's potato-bean T X N

Arenaria cumberlandensis Cumberland sandwort E X N

Asplenium scolopendrium var. Harts-tongue fern T X americanum N M-71 Clematis morefieldii Morefield's leather flower E X X N N Conradina verticillata Cumberland rosemary T X X X N N N Geum radiatum Spreading avens E X N

Isotria medeoloides Small whorled pogonia T X N

Platanthera integrilabia White fringeless orchid T X X X X X X X X X X X N N N N N N N N N N N Scutellaria montana Large-flowered skullcap T XN X X X N N N Spiraea virginiana Virginia spiraea T X X X X X X X X X X N N N N N N N N N N Fungus Gymnoderma lineare Rock gnome lichen E X N

(a) E = endangered; T = threatened; C = candidate.

(b) Y for the Indiana bat indicates the spatial extent of the population associated with White Oak Blowhole Cave hibernation site in Blount County (FWS 2017-TN5357, FWS 2017-TN5328), the only critical habitat designated for the species in Tennessee (FWS 2007-TN934, FWS 2009-TN5356).

(c) Y alone = only critical habitat present.

1

1 Table M-9. Tennessee Natural Heritage Program Locations of Federally Listed Species within 0.125 Mi of the Transmission 2 Line Segments Identified for Upgrade in Tennessee (TNHP 2017-TN5361)

Transmission Federal Last County Line Scientific Name Common Name Status Comments Observed Fish Van Buren (TN) L5173 Etheostoma akatulo Bluemask (Jewel) E In Caney Creek near transmission line but 1972 Darter outside of corridor.

Campbell (TN) L5125 Chrosomus Blackside Dace T In Sandlick Branch near transmission line but 2008 cumberlandensis outside of corridor.

Mollusks Anderson (TN) L5125 Cyprogenia stegaria Fanshell E In Clinch River by Norris Dam and near 1936 transmission line but outside of corridor.

Anderson (TN); L5125 Athearnia anthonyi Anthonys Riversnail E In Clinch River by Norris Dam and near 1985 Campbell (TN) transmission line but outside of corridor.

Anderson (TN); L5125 Dromus dromas Dromedary E In Clinch River by Norris Dam and near 1936 Campbell (TN) Pearlymussel transmission line but outside of corridor.

Franklin (TN); L5167 Toxolasma Pale Lilliput E In Elk River near transmission line but outside 1954 M-72 Coffee (TN); cylindrellus of corridor.

Grundy (TN)

Plants Rhea (TN) L5173 Spiraea virginiana Virginia Spiraea T Near Piney Creek near transmission line but 2015 outside of corridor.

Bats Campbell (TN) L5125 Myotis grisescens Gray bat E Reports from various authors in various years 2002 from 1968 to 2002 indicate Norris Dam cave (Figure M-10) used by gray bats as a maternity, swarming, and hibernation site, Cave located near the Clinch River within the transmission line corridor.

Campbell (TN) L5125 Myotis septentrionalis Northern long-eared E Norris Dam cave (Figure M-10) used as a No date bat hibernation site. Cave located in the transmission line corridor and near the Clinch River.

1 Table M-9. (contd)

Transmission Scientific Common Federal Last County Line Name Name Status Comments Observed Campbell (TN) L5125 Myotis sodalis Indiana Bat E Conflicting reports from various authors indicate 2002 Norris Dam cave (Figure M-10) was and was not used as a hibernation site. To be conservative occurrence in the cave is assumed. Cave located in the transmission line corridor near the Clinch River.

Anderson (TN) L5235 Myotis Gray Bat E One dead individual in the U.S. Department of 1994 grisescens Energy Y-12 facility on the ORR. Facility near but outside the transmission line corridor.

Franklin (TN) L5702 Myotis Gray Bat E One juvenile gray bat observed on Arnold Airforce 1998 grisescens Base. Site near Roland Creek near but outside transmission line corridor (Figure M-13).

Scott (TN) L5882 Myotis Gray Bat E One dead individual in a Y-12 facility on the ORR. 1994 grisescens Facility near but outside the transmission line corridor.

2 M-73

1 Table M-10. Habitat Preferences for the Species Known to Occur in the Counties Containing the Transmission Lines 2 Identified by TVA for Possible Upgrade (Table M-8). Habitat description from TDEC (2017-TN5217) unless 3 otherwise indicated. NA = not applicable for the species and any associated critical habitat noted in Table M-8 4 because (1) the species and critical habitat occur in waterbodies or wetlands which the review team has 5 assumed would not be affected by transmission line upgrades (see Section M.4.2), or (2) suitable habitat for 6 the species based on habitat preferences is unlikely to be present in the upland part of transmission line 7 corridors (i.e., in scrub-shrub/herbaceous vegetation) to which it is assumed habitat disturbance would be 8 limited (see Section M.4.2).

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Mammals Corynorhinus (= Plecotus) Virginia big-eared E Caves typically in limestone karst regions Possible occurrence in transmission line L5125 in townsendii virginianus bat dominated by mature hardwood forests. Prefers Whitley County, Kentucky (No figure), if suitable cool, well-ventilated caves for hibernation. cave habitat were to occur in this corridor.

Maternity colonies deep within caves.

Glaucomys sabrinus Carolina northern E Spruce-fir or mature hardwood forest with snags; NA M-74 coloratus flying squirrel in tree cavities or leaf nests; higher elevations of the Appalachians.

Myotis grisescens Gray bat E Cave obligate year-round; frequents forested Known occurrence in Norris Dam cave, located areas; migratory. within the corridor of L5125 in Campbell County, Tennessee (Figure M-10), has been used by gray bats as a maternity, swarming, and hibernation site (Table M-8). One individual captured near Roland Creek at Arnold Airforce Base along transmission line L5702 in Franklin County, TN (Figure M-13).

Possible occurrence in all transmission line corridors in all three states if suitable cave habitat were to occur in these corridors, since the species is present in all counties.

9

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Myotis septentrionalis NLEB T A forest bat whose summer roosts may include Known occurrence in Norris Dam cave, located within caves, mines, live trees and snags; hibernates in the corridor of L5125 in Campbell County, Tennessee caves and mines, often using small cracks and (Figure M-10), is reported to be used by NLEBs as a fissures. Notably susceptible to WNS. hibernation site (Table M-8).

Possible occurrence in all transmission line corridors in all three states if suitable cave habitat were to occur in these corridors, since the species is present in all counties (Table M-8).

Myotis sodalis Indiana bat E Hibernates in caves; spring/summer maternity Conflicting data as to presence (Table M-8) so roosts are normally under the bark of standing trees. assumed occurrence in Norris Dam cave, located within the corridor of L5125 in Campbell County, Tennessee (Figure M-10).

Possible occurrence in all transmission line corridors M-75 in all three states if suitable cave habitat were to occur in these corridors, since the species is present in all counties (Table M-8).

Amphibians Gyrinophilus gulolineatus Berry cave C Aquatic cave obligate; Ridge and Valley Ecoregion; Possible occurrence in L5092 and L5659 in Knox salamander formerly included with G. palleucus. County, and L5205, L5235, L5280, and L5743 in Roane County, Tennessee (No figure), if suitable cave habitat were to occur in these corridors.

Fishes Chrosomus saylori Laurel dace E Cool 1st-2nd order streams with slabrock and Critical habitat as shown in Figure M-11 in Bledsoe rubble substrate; Walden Ridge of the Cumberland and Rhea Counties, Tennessee, is in the vicinity of, Plateau; Tennessee River watershed. but does not cross transmission corridor L5173.

Erimystax cahni Slender chub T Major headwater tributaries to the Tennessee River NA with small gravel substrates and swift-moderate currents.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Erimonax monachus Spotfin chub T Clear upland rivers with swift currents and boulder Critical habitat as shown in Figure M-14 in substrates; portions of the Tennessee River Cumberland County, Tennessee, crossing watershed. transmission line corridor L5204 in the Gum Branch of the Clear Creek and the Obed River and crossing transmission line L5205 in Daddys Creek.

Etheostoma akatulo Bluemask (Jewel) E Streams with slow to moderate current over clean Occurrence in vicinity of transmission line corridor darter sand and fine gravel; Caney Fork River system L5173 in Caney Creek in Van Buren County, (above Great Falls Reservoir). Tennessee, as shown in Figure M-11.

Last observed in 1972.

Etheostoma lemniscatum Tuxedo darter E Gently flowing, silt-free pools or runs immediately NA upstream of riffles with cobble, boulders, and slabrock; Big South Fork Cumberland River.

Etheostoma percnurum Duskytail darter E Gravel, rubble, and slabrock pools and runs of small NA to medium rivers (NatureServe 2017-TN5216).

Etheostoma spilotum Cumberland T Upland creeks and streams, generally in NA M-76 Plateau darter headwaters, sometimes in larger streams; generally in slow to moderate current in cool, sluggish pools or areas above and below riffles over bedrock, rubble, cobble, and pebble, often interspersed with sandy areas. Common only in intermittently flowing first- or second-order creeks, preferring protective stones near the bank, or ledges and recesses at stream margins (NatureServe 2017-TN5216).

Etheostoma susanae Cumberland E Creeks in the upper Cumberland River watershed of NA darter the Cumberland Mountains; extremely rare.

Etheostoma wapiti Boulder darter E Fast rocky riffles of small to medium rivers and large NA creeks; Elk River watershed.

Notropis albizonatus Palezone shiner E Large upland creeks and small rivers in quiet waters NA and flowing pools; possibly extirpated from Tennessee.

Noturus crypticus Chucky madtom E Stream runs with slow to moderate current over pea Critical habitat as shown in Figure M-15 in Greene gravel, cobble, or slabrock; Little Chucky Creek; County, Tennessee, is within a mile of transmission Nolichucky River system. line corridor L5624 in Little Chucky Creek.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Noturus flavipinnis Yellowfin madtom T Medium-size to large creeks and small rivers that NA are unpolluted and relatively unsilted; upper Tennessee River watershed.

Noturus stanauli Pygmy madtom E Medium to large rivers with moderate to strong NA current over gravel substrates; Tennessee River watershed.

Percina tanasi Snail darter T Sand and gravel shoals of moderately flowing, Occurrence within 0.4 mi SE of transmission line vegetated, large creeks; upper Tennessee River corridor L5697 in South Chickamauga Creek in watershed. Georgia (no figure). Last observed date is unknown.

Phoxinus cumberlandensis Blackside dace T Small upland tributaries with sand, sandstone, and Occurrence in the vicinity of line L5125 in Sandlick shale substrates in unsilted conditions; upper Branch of Davis Creek in Campbell County, Cumberland River watershed. Tennessee, as shown in Figure M-12. Last observed 3/21/2008.

A second species occurrence is within 0.3 mi. of M-77 transmission line corridor L5125 in Buffalo Creek in Whitley County, Kentucky, as shown in Figure M-19.

Most recent observation in September of 2015.

Mussels Alasmidonta atropurpurea Cumberland E Small creeks to medium-size rivers with slow Critical habitat as shown in Figure M-15 within 0.5 mi elktoe current, sand substrates, and large cobble; upper in the Nolichucky River on the border of Green and Cumberland River watershed. Hamblen Counties, Tennessee, in the vicinity of transmission corridor L5624.

Critical habitat as shown in Figure M-17 in the New River in Scott County, Tennessee, is approximately 0.5 mi from transmission line corridor L5882.

Critical habitat for the Cumberland elktoe as shown in Figure M-19 in the Laurel Fork of the Clear Fork River in Whitley County, Kentucky, less than 1 mi from transmission line corridor L5125.

Alasmidonta raveneliana Appalachian E Large creeks/small rivers with stable coarse sand NA elktoe and gravel substrates with cobble and boulders; upper Tennessee River watershed.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Cumberlandia monodonta Spectaclecase E Medium to large rivers; in substrates from mud and NA (mussel) sand to gravel, cobble, and boulders; Cumberland and Tennessee River systems.

Cyprogenia stegaria Fanshell E Medium to large streams and rivers with coarse NA sand and gravel substrates; Cumberland and Tennessee River systems.

Dromus dromas Dromedary E Medium to large rivers with riffles and shoals with Species located in the vicinity of transmission line pearlymussel relatively firm rubble, gravel, and stable substrates; corridor L5125 in Clinch River in Campbell County, Tennessee and Cumberland river systems. Tennessee, L5125 as shown in Figure M-10.

Last observed in 1936.

Epioblasma brevidens Cumberlandian E Large creeks to large rivers, in coarse sand or Critical habitat as shown in Figure M-15 in the combshell mixtures of gravel, cobble, or rocks; Tennessee and Nolichucky River within 0.5 mi of transmission Cumberland river systems. corridor L5624 on the border of Green and Hamblen Counties, Tennessee.

M-78 Critical habitat as shown in Figure M-17 along the New River in Scott County, Tennessee, is approximately 0.5 mi from transmission line corridor L5882.

Epioblasma capsaeformis Oyster mussel E Shallow riffles in mod-swift current of small-medium Critical habitat as shown in Figure M-15 along the rivers with coarse sand and gravel; Tennessee and Nolichucky River in Greene and Hamblen Counties, Cumberland river systems excluding the Duck River. Tennessee, is within 0.5 mi of transmission line corridor L5624.

Critical habitat as shown in Figure M-17 along the New River in Scott County, Tennessee, is within approximately 0.5 mi of transmission line corridor L5882.

Epioblasma florentina walkeri Tan riffleshell E River headwaters, in riffles and shoals in sand and NA

(=E. walkeri) gravel substrates; Tennessee and Cumberland river systems.

Epioblasma obliquata Catspaw E Medium to large rivers, in sand and gravel NA substrates in runs and riffles; Tennessee and Cumberland river systems.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Epioblasma torulosa Tubercled E High-gradient creeks, riffles of medium-size rivers. NA blossom Riffles or shoals in shallow water with sandy gravel (pearlymussel) substrate and rapid currents (NatureServe 2017-TN5216).

Epioblasma triquetra Snuffbox mussel E Riffles of medium-large rivers with stony or sandy NA bottoms, in swift currents, usually deeply buried; Tennessee and Cumberland river systems.

Epioblasma turgidula Turgid blossom E Riffles of creeks and medium-size rivers. Requires NA (pearlymussel) clear, unpolluted water; typically found buried in sand and gravel substrates of shallow, fast-flowing streams (NatureServe 2017-TN5216).

Fusconaia cor Shiny pigtoe E Shoals and riffles of small- to medium-size rivers NA with moderate to fast current over sand-cobble substrates; upper Tennessee River watershed.

Fusconaia cuneolus Finerayed pigtoe E Riffles of fords and shoals of mod gradient streams NA M-79 in firm cobble and gravel substrates; middle and upper Tennessee River watershed.

Hemistena lata Cracking E Medium-size rivers of moderate current, deeply NA pearlymussel buried in mud, sand, gravel, and cobble substrates; Tennessee and Cumberland river systems.

Lampsilis abrupta Pink mucket E Generally a large river species, preferring sand- NA (pearlymussel) gravel or rocky substrates with moderate to strong currents; Tennessee and Cumberland river systems.

Lampsilis virescens Alabama E Found in sand and gravel substrates in shoal areas NA lampmussel of small- to medium-size rivers; middle and upper Tennessee River system; recently rediscovered in Emory River.

Lemiox rimosa Birdwing E Small- to medium-size rivers in riffle areas with sand NA pearlymussel and gravel substrates in moderate to fast currents; Tennessee River system.

Obovaria retusa Ring pink (mussel) E Large rivers in gravel and sand bars; Tennessee NA and Cumberland river watersheds; many historic locations currently inundated.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Pegias fabula Littlewing E Cool, clear, high-gradient streams in sand, gravel, NA pearlymussel and cobble substrates, riffles; portions of Cumberland and upper Tennessee River systems.

Plethobasus cooperianus Orangefoot E Large rivers in sand-gravel-cobble substrates in NA pimpleback riffles and shoals in deep flowing water; Cumberland (pearlymussel) and Tennessee River systems.

Plethobasus cicatricosus White wartyback E Presumed to inhabit shoals and riffles in large rivers; NA (pearlymussel) Tennessee and Cumberland river systems. Very rare and possibly extirpated in Tennessee.

Plethobasus cyphyus Sheepnose E Large- to medium-size rivers, in riffles and coarse NA mussel sand/gravel substrate; Tennessee and Cumberland river systems including Kentucky Reservoir; Uplands, and Rim.

Pleurobema clava Clubshell E Small- to medium-size rivers and streams; deeply NA buried in sand/fine gravel or in clean, coarse M-80 sand/gravel runs; lower Cumberland and Tennessee rivers.

Pleurobema gibberum Cumberland E Shallow areas in small- to medium-size rivers in NA pigtoe riffles with sand and gravel substrates; tributaries of Cumberland River and possibly Tennessee River in middle Tennessee.

Pleurobema plenum Rough pigtoe E Medium- to large-size rivers in sand, gravel, and NA cobble substrates of shoals; Tennessee and Cumberland river systems.

Pleuronaia dolabelloides Slabside E Large creeks to moderate size rivers, in Critical habitat as shown in Figure M-11 in the pearlymussel riffles/shoals of sand, fine gravel, and cobble Sequatchie River crossing transmission line corridor substrates with moderate current; Tennessee River L5173 in Bledsoe County, Tennessee.

watershed.

Critical habitat as shown in Figure M-15 in the Nolichucky River within 0.5 mi of transmission corridor L5624 on the border of Green and Hamblen Counties, Tennessee.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Ptychobranchus subtentum Fluted kidneyshell E Small- to medium-size rivers in swift current or Critical habitat as shown in Figure M-15 along the riffles, in sand, gravel, and cobble substrates; Nolichucky River in Greene and Hamblen Counties, Tennessee and Cumberland river systems. Tennessee, is within 0.5 mi of transmission line corridor L5624.

Critical habitat as shown in Figure M-16 along the Holston River in Jefferson County, Tennessee, is adjacent to transmission line corridor L5186.

Critical habitat as shown in Figure M-17 along the New River in Scott County, Tennessee, is approximately 0.5 mi from transmission line corridor L5882.

Critical habitat as shown in Figure M-18 in the French Broad River in Sevier County, Tennessee, is within M-81 less than 0.25 mi of transmission line corridor L5957.

Quadrula cylindrica Rabbitsfoot T Large rivers in sand and gravel; Tennessee and NA Cumberland systems. Big river form of Q.

cylindrica.

Quadrula cylindrica strigillata Rough rabbitsfoot E Small- to medium-size rivers, in clear, shallow riffles NA with sand-gravel substrates; Tennessee and Cumberland river systems.

Quadrula intermedia Cumberland E Shallow riffle and shoal areas of headwater streams NA monkeyface and bigger rivers, in coarse sand/gravel substrates; Tennessee River system.

Quadrula sparsa Appalachian E Headwater sections of rivers in shallow riffles/runs NA monkeyface with sand-gravel substrate and moderate current; upper Tennessee River drainage.

Toxolasma cylindrellus Pale lilliput E Small tributary rivers and streams, in firm rubble, Species located in the vicinity of transmission line (pearlymussel) gravel, and sand substrates in shallow riffles and corridor L5167 on the Elk River in Frankllin County, shoals; lower Tennessee River system. Tennessee, as shown in Figure M-13. Last observed October 13, 1954.

Villosa fabalis Rayed bean E Riffles of medium to small rivers and creeks, in NA gravel and sand substrates associated with Justicia americana; Tennessee River watershed.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Villosa perpurpurea Purple bean E Creeks to medium-size rivers, headwaters, in riffles Critical habitat as shown in Figure M-14 in the Obed with coarse sand and gravel and some silt; upper River in Morgan and Cumberland Counties, Tennessee River watershed. Tennessee, is in the vicinity of, but does not cross, transmission corridor L5204 and L5205.

Villosa trabalis Cumberland bean E Riffle areas of small rivers and streams in sand, NA (pearlymussel) gravel, and cobble substrates with swift current; upper Cumberland and upper Tennessee River systems.

Arachnids Microhexura montivaga Spruce-fir moss E Moss mats in high-elevation spruce-fir forests; NA spider Southern Appalachians.

Insects Bombus affinis Rusty-patched E Once occupied grasslands and tallgrass prairies of NA bumble bee the Upper Midwest and Northeast, but most have M-82 been lost, degraded, or fragmented by conversion to other uses. Bumble bees need areas that provide nectar and pollen from flowers, nesting sites (underground and abandoned rodent cavities or clumps of grasses), and overwintering sites for hibernating queens (undisturbed soil) (FWS 2017-TN5376).

Snails Anguispira picta Painted tigersnail T A calciphile; limestone outcrops and cliff faces of NA karstic woods; South Cumberland Mountains; Sherwood community of upper Crow Creek valley (TDEC 2017-TN5217). Not found in habitats no longer having forest cover (43 FR 28932-TN5374).

Athearnia anthonyi Anthony's E Larger rivers and downstream stretches of large Species located in the vicinity of transmission line riversnail creeks, on cobble/boulder substrates adjacent to corridor L5125 in the Clinch River, Campbell County, riffles; portions of upper Tennessee River basin. Tennessee, as shown in Figure M-10. Last observed 1985.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Plants Apios priceana Price's potato- T Lightly disturbed areas, such as forest openings, Possible occurrence in L5167 and L5702 in Franklin bean woodland edges, where bluffs descend to streams, County, Tennessee depending on whether the and highway right-of-way and powerline corridors species is present in the uplands of these corridors.

(FWS 2015-TN5375)

Arenaria cumberlandensis Cumberland E Restricted to sandstone rock houses, ledges, and NA sandwort solution pockets on sandstone rock faces. Habitat requirements include shade, moisture, relatively constant cool temperatures, and high humidity (McKerrow 1996-TN5302).

Asplenium scolopendrium Harts-tongue fern T Southern populations (e.g., Tennessee) are found NA var. americanum only within limestone pits that trap cold air, have high humidity, and are well shaded. At all known locations, the species appears to require high humidity, shaded conditions, a moist substrate, and M-83 the presence of dolomitic limestone (Currie 1993-TN5306).

Clematis morefieldii Morefield's leather E Seeps/springs in rocky limestone woods NA flower (TDEC 2017-TN5217; Norquist 1994-TN939; FWS 2017-TN5411).

Conradina verticillata Cumberland T Grows in full to moderate sunlight in the floodplain of Possible occurrence in L5204 and L5205 in rosemary major streams flowing over sandstone bedrock. Cumberland County and L5882 in Scott County and Occurs on boulder bars, bouldery gravel bars, sandy L5173 in White County, Tennessee, depending on gravel bars, and terraces of sand on gradually the presence of the species along major streams sloped riverbanks and islands, and sandy pockets within these corridors.

between boulders. Essential habitat requirements include periodic flooding to maintain openness, topographic features to enhance sand deposition, and periods of inundation of at least 2 weeks (Shea and Roulston 1996-TN5303).

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Geum radiatum Spreading avens E Grows in pioneer perennial herb communities at NA (Elevation of L5957 in Sevier County (located just high-elevation rocky sites where it is exposed to north of Douglas Lake Dam), Tennessee, does not direct sunlight for at least part of the day. exceed about 400 m).

Populations occur at altitudes ranging from 1,400 to 1,911 m (Murdock 1993-TN5377).

Isotria medeoloides Small whorled T Forests in second- or third-growth successional NA (However, note that the species may occur on pogonia stages, both in young forests and in maturing corridor fringes along L5697 in Hamilton County, stands, including near logging roads, Tennessee.

streams,or other features that create long persisting breaks in the forest canopy (von Oettingen 1992-TN5307).

Platanthera integrilabia White fringeless T Acidic seeps and stream heads (TDEC 2017- Possible occurrence in the transmission line corridors orchid TN5217). TVA has stated that nearly 20 percent of in Whitely County, Kentucky, and Bledsoe, extant white fringeless orchid occurrences are Cumberland, Franklin, Grundy, Hamilton, Roane, located in transportation or utility right-of-ways, Scott, Sequatchie, Van Buren, and Warren Counties, illustrating that the species occurs in these settings Tennessee, (depending on whether suitable habitat M-84 at a disproportionately high rate when compared to and the species are present in these corridors.

its overall prevalence on the landscape (81 FR 62826-TN5378).

Scutellaria montana Large-flowered T Rocky, submesic to xeric, well-drained, slightly NA skullcap acidic slope, ravine and stream bottom forests.

Recruitment into disturbed sites is not likely (McKerrow 1996-TN5304).

Spiraea virginiana Virginia spiraea T Banks of high-gradient sections of second- and Known occurrence near Piney Creek just outside the third-order streams, or on meander scrolls and point corridor of L5173 in Rhea County, Tennessee, bars, natural levees, and other braided features of (Table M-8) (Figure M-11). Last observed 2015 lower reaches (often near the stream mouth) in oft- (Table M-8). Thus, possible occurrence in L5173 in disturbed early successional areas (Ogle 1992- Rhea County, and within the transmission line TN5379).

corridors in Whitely County, Kentucky, and Bledsoe, Cumberland, Hamilton, Roane, Scott, Sequatchie, Van Buren, and White Counties, Tennessee, depending on whether suitable habitat and the species are present in these corridors.

Table M-10. (contd)

Status Transmission Lines and Segments by County Scientific Name Common Name Habitat Preferences with Potentially Suitable Habitat Fungus Gymnoderma lineare Rock gnome E Primarily limited to vertical rock faces with seepage NA (Elevation of L5957 in Sevier County [located just lichen water. Thrives on moist, generally open sites with north of Douglas Lake dam], Tennessee, does not northern exposures, but needs partial canopy exceed about 400 m).

coverage on southern or western exposures.

Common associates include spreading avens (discussed above in this table). Most populations occur above 1,524 m elevation (Murdock and Langdon 1997-TN5380).

M-85

1 Figure M-10 through Figure M-19 show species and critical habitat locations that are within or in 2 close proximity to the transmission line corridors. Table M-10 provides the callouts for these 3 figures as identified in the last column of the table.

4 Note that, in addition to the notations for Norris Dam cave for Federally listed bat species in 5 Table M-10, this cave (first described in Table M-9) has also been used by little brown bats 6 (described in Section M.6.1.5) as a hibernation site (Figure M-10) (TNHP 2017-TN5361). This 7 species, as well as the tri-colored bat (described in Section M.6.1.4), could potentially occur in 8 all transmission line corridors in all three states if suitable cave habitat were to occur in these 9 corridors.

10 Notes on Critical Habitat for Terrestrial Species Near Transmission Line Upgrades: The critical 11 habitat noted in Table M-8 for the spruce-fir moss spider (Microhexura montivaga) in Sevier 12 County, Tennessee (FWS 2017-TN5328; 66 FR 35547-TN5381), does not overlap and is not 13 located in proximity to L5957, the only transmission line identified for upgrade in Sevier County 14 (Table M-10). The critical habitat noted in Table M-8 for the Indiana bat in Cocke, Jefferson, 15 Knox, and Sevier Counties actually concerns the spatial extent of populations associated with 16 White Oak Blowhole Cave in neighboring Blount County (FWS 2017-TN5357, FWS 2017-17 TN5328), the only actual critical habitat for the species designated in Tennessee (FWS 2007-18 TN934, FWS 2009-TN5356). The hibernation site in Blount County is not located in proximity to 19 any of the transmission lines in the counties for which critical habitat is listed for the species in 20 Table M-8. Therefore, critical habitat for the spruce-fir moss spider and Indiana bat will not be 21 carried forward for potential impact evaluation in Section M.7.8.

22 Notes on critical habitat for aquatic species near transmission line upgrades: critical habitat 23 noted in Table M-7 for aquatic species follow:

24 Critical habitat for the slabside pearly mussel (Pleuronaia dolabelloides) that intersects 25 transmission line corridor L5173 in Bledsoe County, Tennessee, as shown in Figure M-11.

26 Critical habitat in Bledsoe and Rhea Counties, Tennessee, for the Laurel Dace (Chrosomus 27 saylori) also shown in Figure M-11 is not crossed by a transmission line corridor L5173.

28 Critical habitat for the spotfin chub (Erimonax monachus) intersects transmission line 29 corridor L5204 on the Gum Branch of the Clear Creek, the Obed River and transmission 30 corridor L5205 in Daddys Creek in Cumberland County, Tennessee as shown in 31 Figure M-14. Critical habitat for the purple bean (Villosa perpurpurea) is also shown in 32 Morgan and Cumberland Counties, Tennessee, but it is several miles from the transmission 33 line corridors.

34 Critical habitat less than a mile from transmission corridor L5624 is shown in Figure M-15 for 35 the chucky madtom (Noturus crypticus) in Little Chucky Creek in Greene County, 36 Tennessee. Critical habitat for the fluted kidneyshell (Ptychobranchus subtentum), slabside 37 pearly mussel, Cumberlandian combshell (Epioblasma brevidens), Cumberland elktoe 38 (Alasmidonta atropurpurea) and the oyster mussel (Epioblasma capsaeformis) in the 39 Nolichucky River in Greene County and Hamblen County, Tennessee, is shown within 40 0.5 mi of the transmission corridor.

41 Critical habitat for the fluted kidneyshell mussel in the Holston River in Jefferson County on 42 the border with Grainger County, Tennessee, is adjacent to, but not within, transmission line 43 corridor L5186 as shown in Figure M-16.

M-86

1 Critical habitat for the fluted kidneyshell mussel, the oyster mussel, the Cumberlandian 2 combshell and the Cumberland elktoe in the New River in Scott County, Tennessee is 3 approximately 0.5 mi from transmission line corridor L5882 as shown in Figure M-17.

4 Critical habitat for the fluted kidneyshell mussel in the French Broad River in Sevier County, 5 Tennessee, is within less than 0.25 mi of transmission line corridor L5957 as shown in 6 Figure M-18.

7 Critical habitat for the Cumberland elktoe in the Laurel Fork of the Clear Fork River in 8 Whitley County, Kentucky, is less than 1 mi from transmission line corridor L5125 as shown 9 in Figure M-19.

10 11 Figure M-10. Location of Norris Dam Cave along the Clinch River within Transmission 12 Line Corridor L5125 in Campbell County, Tennessee. Records of prior cave 13 use by various bat species, and records of various mussel species in the 14 river.

M-87

1 2 Figure M-11. Occurrence of Virginia Spiraea (Spiraea virginiana) near Piney Creek and 3 bluemask (jewel) darter (Etheostoma akatulo) in Caney Creek, as well as 4 critical habitat for the laurel dace (Chrosomus saylori) and slabside 5 pearlymussel (Pleuronaia dolabelloides) along Transmission Line Corridor 6 L5173 in Tennessee.

M-89

1 2 Figure M-12. Occurrence of blackside dace (Phoxinus cumberlandensis) in Sandlick 3 Branch along Transmission Line Corridor L5125 in Tennessee.

4 M-90

1 2 Figure M-13. Occurrence of gray bat (Myotis grisescens) near Rowland Creek on Arnold 3 Airforce Base along Transmission Line Corridor L5702 in Tennessee.

4 Occurrence of pale lilliput (Toxolasma cylindrellus) along Transmission 5 Line Corridor L5167, in Tennessee.

M-91

1 2 Figure M-14. Critical habitats for the purple bean (Villosa perpurpurea) and spotfin chub 3 (Erimonax monachus) along Transmission Corridors L5204 and L5205 in 4 Tennessee.

M-92

1 2 Figure M-15. Critical habitats for various aquatic species along Transmission Corridor 3 L5624 in Tennessee.

4 M-93

1 2 Figure M-16. Critical habitat for the fluted kidneyshell (Ptychobranchus subtentum) 3 along Transmission Corridor L5186 in Tennessee..

M-94

1 2 Figure M-17. Critical habitats for various aquatic species along Transmission Corridor 3 L5882 in Tennessee.

4 M-95

1 2 Figure M-18. Critical habitat for the fluted kidneyshell (Ptychobranchus subtentum) 3 along Transmission Corridor L5957 in Tennessee.

4 M-96

1 2 Figure M-19. Occurrences of blackside dace (Phoxinus cumberlandensis) and location 3 of critical habitat for the Cumberland elktoe (Alasmidonta atropurpurea) 4 along Transmission Corridor L5125 in Kentucky.

5 M.7 Potential Effects on Species and Habitats 6 This section describes the potential direct and indirect impacts on the species and critical 7 habitats discussed in Section M.6 from changes in baseline terrestrial and aquatic resources 8 (Section M.3) due to building (Section M.4) and operating (Section M.5) a reactor at the CRN 9 Site. This section also describes various areas where the species described in Section M.6.1 10 may be affected in the CRN Site vicinity.

11 Sections M.7.1 through M.7.6 address the bat species covered in this BA. Section M.7.1 12 provides an overview of possible effects of building and operating SMRs at the CRN Site on 13 bats, while Sections M.7.2 through M.7.6 individually address the gray bat, Indiana bat, NLEB, 14 tri-colored bat, and little brown bat. Section M.7.7 addresses the aquatic species covered in this 15 BA, specifically, the pink mucket mussel, sheepnose mussel, spotfin chub (a fish), and the M-97

1 hellbender (an amphibian). Section M.7.8 separately addresses the potential effects of the 2 proposed transmission line upgrades on listed species and habitats.

3 M.7.1 Bat Species 4 M.7.1.1 CRN Site and Vicinity 5 As is evident from the descriptive characterizations provided in Section M.6.1 of this BA, the 6 Indiana bat, NLEB, little brown bat, and tri-colored bat have similar (although not identical) life 7 histories and habitat requirements in that they roost in trees during the non-hibernation season; 8 forage in riparian areas, ponds, and wetlands, and in upland forest, forest openings, and fields; 9 and use caves and mines as hibernacula. These four species are thus addressed together for 10 effects due to potential loss of roosting and foraging habitat. The gray bat roosts in caves year-11 round and forages over waterbodies, and so is addressed individually for effects due to potential 12 loss of forest cover providing access to foraging habitat. Noise impacts (Section M.7.1.4) are 13 addressed for all five bat species collectively, and are used to describe the Action Area for bats.

14 The analysis methods provided in FWS (2017-TN5346) are followed for the major impact 15 activities of habitat removal and noise. Other minimal impact activities are addressed more 16 succinctly for all five bat species collectively. Hypothetical blasting and demolition impacts to 17 bats potentially using the five caves along Grassy Creek are discussed in Section M.7.1.4 18 because some use of the caves appears probable but is unknown. Separate summaries and 19 conclusions are provided for each species but do not include as a basis the hypothetical 20 blasting and demolition impacts to bats potentially using the caves along Grassy Creek 21 discussed in Section M.7.1.4.

22 M.7.1.2 Activity Vegetation Clearing (Forest and Non-Forest) 23 As noted in Section M.4.1 of this BA, about 311 ac of forest and about 195 ac of non-forested 24 vegetation would be removed on the CRN Site and in the BTA to build the proposed facilities.

25 An additional 210 ac of non-forested vegetation would be temporarily removed within an 26 approximate 5-mi length of the 500-kV transmission line corridor (where the 69-kV buried line 27 would be installed) between the perimeter of the CRN Site and the Bethel Valley Substation.

28 Potential cooling-tower salt deposition during project operations (Section M.5.1.1) would affect 29 forest and non-forest vegetation that would already be cleared for building as described above, 30 and thus would not add to the effects of vegetation clearing.

31 M.7.1.2.1 Stressor 32 Removing forest vegetation would remove non-hibernating roosting habitat potentially used by 33 Indiana, northern long-eared, little brown, and tri-colored bats, but not gray bats which roost in 34 caves. Removing forest vegetation would remove potential travel corridors for gray bats 35 between summer cave roosts and foraging habitat over the Clinch River and associated 36 wetlands, ponds, and streams. Removing non-forest vegetation would remove foraging habitat 37 potentially used by Indiana, northern long-eared, little brown, and tri-colored bats, but not gray 38 bats which forage over waterbodies.

M-98

1 M.7.1.2.2 Exposure (Time and Space) 2 Removal of the forested habitats potentially used by Indiana, northern long-eared, little brown, 3 and tri-colored bats for non-hibernation roosting, and by gray bats as commuting corridors (to 4 foraging habitat over the Clinch River and associated wetlands, ponds, and streams), would 5 affect these species during the non-hibernating season (April 1-October 15). The permanent 6 removal of forest vegetation (171 ac) (Section M.4.1.1.1) would permanently affect these 7 species within the development footprint (Figure M-7). The temporary removal of forest 8 vegetation (140 ac) (Section M.4.1.1.1) would affect these species until re-establishment of 9 forests with trees sufficiently large to provide suitable roost sites and commuting corridors. The 10 amount of time required to re-establish forest habitats that could provide roost sites and 11 commuting corridors could vary from about 40 to 100 years, depending on the bat species. This 12 time span may be reduced somewhat by replanting trees in temporarily disturbed areas (Section 13 M.4.1.1.3).

14 Removal of the non-forested habitats potentially used by Indiana, northern long-eared, little 15 brown, and tri-colored bats for foraging would affect these species during the non-hibernating 16 season (April 1 to October 15). The permanent removal of non-forest vegetation (153 ac) 17 (Section M.4.1.1.2) would permanently affect these species within the development footprint 18 (Figure M-7). The temporary removal of non-forest vegetation (42 ac) (Section M.4.1.1.2) would 19 affect these species until re-establishment of scrub-shrub/herbaceous vegetation sufficient to 20 produce an insect prey base. The amount of time required to re-establish early successional 21 habitats that would provide a prey base could be 10 years. This time may be reduced 22 somewhat by revegetating temporarily disturbed areas (Section M.4.1.1.3).

23 M.7.1.2.3 Individual Response 24 Indiana, northern long-eared, little brown, and tri-colored bats using the forested portion of the 25 development footprint for roosting when TVA fells trees for site preparation would be directly 26 affected by being displaced and possibly experiencing injury or death. Displaced individuals 27 would have to find alternate roost trees, and in doing so, could experience increased 28 competition with other bats for remaining suitable roosts. Gray bats using forested areas on the 29 CRN Site to commute nocturnally from cave roosts to foraging areas would not be directly 30 affected during daytime tree removal, but may be indirectly affected by having to establish new 31 nighttime commuting patterns to the same or to new foraging areas.

32 M.7.1.2.4 Interpretation 33 Removal of forested areas potentially used by Indiana, northern long-eared, little brown, and tri-34 colored bats during the non-hibernating season could reduce fitness for individuals that were 35 disturbed or flushed because they would need to expend energy to find other appropriate roost 36 trees in the vicinity, or because they may incur injury or mortality. Removal of forest cover used 37 by gray bats as commuting corridors to the Clinch River and associated wetlands, ponds, and 38 streams could reduce fitness for individuals required to find other forest commuting habitat in 39 the vicinity. Removal of non-forested habitat used by Indiana, northern long-eared, little brown, 40 and tri-colored bats as foraging habitat could reduce fitness for individuals required to find other M-99

1 foraging habitat in the vicinity. These impacts would last for the duration of vegetation removal 2 activities, which TVA has estimated would continue for about 1 year (Section M.4.1.1).

3 Considering the abundance of forest and other terrestrial habitat in the region, as evident from 4 Figure M-8, the losses of forest in the development footprint are unlikely to materially reduce the 5 availability of suitable roosting, commuting, or foraging habitat for any of the subject bat species.

6 This is especially true in the landscape north of the CRN site, which consists mostly of broad 7 blocks of mature deciduous forest that are part of the ORR.

8 M.7.1.3 Activity Wetland and Waterbody Removal 9 As noted in Section M.4.1.2 and Figure M-7, wetland loss on the CRN Site would total about 10 1.2 ac. Wetland loss in the BTA would total about 0.6 ac (Section M.4.1.2). Wetland loss within 11 the existing 500-kV transmission line corridor where the 69-kV transmission line would be buried 12 could total up to 2 ac (Section M.4.1.2). This constitutes a potential maximal permanent loss of 13 less than 4 ac of wetland.

14 Wetland dewatering (Section M.4.1.2) is uncertain and would be temporary if it were to occur, 15 and thus would not substantively add to the effects of wetland removal on bats.

16 One perennial stream, six ephemeral streams/wet weather conveyances, and two freshwater 17 ponds lie within TVAs estimated building-activity footprint and would be permanently removed 18 (Section M.4.1.3 and Figure M-7) (TVA 2017-TN4921). Five additional ephemeral streams 19 located in the northeast section of the CRN Site (C04, C05, C06, C07, and C08) would be 20 temporarily disturbed and then restored (Section M.4.1.3).

21 M.7.1.3.1 Stressor 22 Loss of wetlands, ponds, and perennial and ephemeral streams would remove foraging habitat 23 potentially used by Indiana, northern long-eared, little brown, tri-colored, and gray bats.

24 M.7.1.3.2 Exposure (Time and Space) 25 Removal of the 4 ac of wetland habitats, and ponds and perennial and ephemeral streams 26 potentially used by Indiana, northern long-eared, little brown, tri-colored, and gray bats for 27 foraging would affect the species during the non-hibernating season (April 1 to October 15).

28 The permanent removal of wetland, ponds, and perennial and ephemeral streams would 29 permanently affect these species within the development footprint (Figure M-7). The temporary 30 removal of ephemeral streams would affect these species until restoration of the ephemeral 31 streams (Section M.4.1.3) and recolonization of an insect prey base. The amount of time 32 required to restore ephemeral streams that would provide a prey base could be 10 years.

33 M.7.1.3.3 Individual Response 34 Bats using the wetlands, ponds, and perennial and ephemeral streams in the development 35 footprint would not be directly affected by removal of these resources, because foraging takes 36 place at night. However, removal of these resources could indirectly affect bats by causing 37 them to need to find alternate foraging habitat.

M-100

1 M.7.1.3.4 Interpretation 2 Removal of wetlands, ponds, and perennial and ephemeral streams potentially used by Indiana, 3 northern long-eared, little brown, tri-colored, and gray bats could reduce fitness for individuals 4 required to expend energy to find other appropriate foraging habitat elsewhere in the vicinity.

5 This impact would last for the duration of wetland and waterbody removal activities, which TVA 6 has estimated would continue for about 1 year (Section M.4.1.1).

7 Considering the abundance of other wetlands, ponds, and streams in the region, as evident 8 from Figure M-8, the loss of these resources from building and operating activities at the CRN 9 Site, BTA, and underground transmission line areas are unlikely to materially reduce the 10 availability of such foraging habitat for any of the subject bat species in the surrounding 11 landscape.

12 M.7.1.4 Activity - Noise Generation (Building and Operation) 13 Daytime episodic construction noise produced by blasting and demolition would likely originate 14 in the power-block area of the southern part of the CRN Site (Figure M-3) and may travel 15 roughly 9 to 10 mi from the site before it attenuates to background levels (Section M.4.1.4).

16 Vibrations from blasting may result in damage to structures as far away as 0.7 mi (FWS 2005-17 TN5382). Daytime noise from heavy construction equipment would be more regular, could 18 originate from anywhere on the CRN Site, in the BTA, or along the 69-kV transmission line 19 during burial, and may travel from about 1,600 ft (general noise levels from non-blasting, non-20 impact equipment) to about 2.5 mi (maximum noise levels from non-blasting impact equipment) 21 before it attenuates to background levels (Section M.4.1.4). Nighttime noise from construction 22 equipment may travel up to 3,200 ft before attenuating to background (Section M.4.1.4). In 23 addition, human activity may also occur day and night during building activities, along with 24 increased light levels during nighttime. Daytime and nighttime noise from the operation of 25 cooling towers would originate from the southern part of the CRN Site (Figure M-3) and may 26 travel about 6,000 ft before attenuating to background levels (Section M.4.1.4). Human activity 27 may also occur day and night during the operation period, along with increased light levels 28 during nighttime.

29 As noted in Section M.4.1.4, the sound attenuation rates used by the review team account only 30 for distance and the soft site factor and do not consider other factors contributing to attenuation 31 such as topography, vegetation, and atmospheric conditions. The review team estimates that 32 effects of construction noise on the five bat species may be experienced up to about 0.5 mi from 33 development activities. In developing this estimate, the review team considered the disparate 34 locations of contributing noise sources, the conservatism inherent in the review teams 35 projections of noise attenuation, and mitigative noise reduction methods proposed by TVA in 36 their application. The review team also assumes that noise from the operation of cooling-towers 37 could affect bats as far as 0.5 mi away.

38 Note that 0.5 mi from the CRN Site, the BTA, and the 69-kV transmission line constitutes the 39 Action Area for bats, because it encompasses the area of direct and indirect effects of habitat 40 loss (the above two activities described in Sections M.7.1.2 and M.7.1.3) and the indirect effects 41 of noise.

M-101

1 M.7.1.4.1 Stressor 2 Daytime building noise (including ground vibrations from blasting and demolition that would 3 occur only during daytime [Section M.4.1.4]), operation noise (cooling towers), and increased 4 human activity could disturb tree-roosting bats (Indiana, northern long-eared, little brown, and 5 tri-colored bats) during the non-hibernating season (April 1 to October 15). Nighttime building 6 noise, operation noise (cooling towers), and increased human activity and lighting could disturb 7 foraging Indiana, northern long-eared, little brown, tri-colored, and gray bats during the non-8 hibernating season.

9 Daytime ground vibrations and noise from blasting and demolition could potentially disturb gray 10 bats if they were roosting in any of the five caves located on the Grassy Creek Habitat 11 Protection Area during the non-hibernating season, and any of the five bat species if they were 12 to use the caves for hibernation (October 15 to April 1). The risk of disturbance may be 13 decreased by Chestnut Ridge, which lies between Grassy Creek and the CRN Site. However, 14 the locations of the surface openings of the caves have not been mapped, nor have the 15 underground portions been mapped, which may lie closer to the source of blasting on the 16 CRN Site.

17 M.7.1.4.2 Exposure (Time and Space) 18 Building noise (including ground vibrations from blasting and demolition) and increased human 19 presence and lighting could disturb the tree-roosting bat species day and night and during the 20 non-hibernation season, as indicated in Section M.7.1.4.1, up to 0.5 mi from the 21 CRN Site boundary, BTA, and the route of the 69-kV transmission line over a period of several 22 years. Operation noise and increased human presence and lighting could disturb the subject 23 bat species day and night during the non-hibernation period, as indicated in Section M.7.1.4.1, 24 up to 0.5 mi from the CRN Site boundary over a period of 20 years.

25 The effects of daytime ground vibrations due blasting and demolition on bats potentially 26 occupying the five caves located on the Grassy Creek Habitat Protection Area, as described in 27 Section M.7.1.4.1, could occur over a period of several years.

28 M.7.1.4.3 Individual Response 29 Tree-roosting bats disturbed by day-time noise (including ground vibrations from blasting and 30 demolition) and increased human activity could flush from roost trees, requiring them to expend 31 energy finding other appropriate roost trees. Foraging bats disturbed by night-time noise and 32 increased human activity and lighting may expend energy finding other alternative foraging 33 areas.

34 Gray bats potentially roosting in the five caves in the Grassy Creek Habitat Protection Area 35 during the non-hibernating season may be disturbed by ground vibrations and noise due to 36 blasting and demolition and need to find alternate cave roost sites. Any of the subject bat 37 species potentially hibernating in these caves may be aroused from torpor by this disturbance.

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1 M.7.1.4.4 Interpretation 2 Tree-roosting bats that flush to find other roost trees or that avoid traditional foraging areas in 3 search of foraging habitat elsewhere, because of noise, human activity, and light, would expend 4 energy that could reduce fitness.

5 Gray bats potentially roosting in the five caves in the Grassy Creek Habitat Protection Area 6 during the non-hibernating season may be disturbed and could expend energy finding alternate 7 cave roost sites, which could reduce fitness. Arousal from torpor of any of the five bat species 8 potentially hibernating in these caves could result in depletion of fat reserves needed for the 9 duration of hibernation and spring migration.

10 M.7.1.5 Activity - Collision with Tall Structures 11 Notwithstanding bats ability to echo-locate, they may infrequently suffer mortality from collisions 12 with tall, stationary structures. For example, studies of bat mortality attributable to collision with 13 the Susquehanna Steam Electric Station tall (540 ft) natural draft cooling towers between 1984 14 and 1986 found eight dead bats of three species (little brown bat, eastern red bat [Lasiurus 15 borealis], and big brown bat [Eptesicus fuscus]) (NRC 1996-TN288). TVA proposes to use low 16 stature (65 ft) mechanical draft cooling towers at the CRN Site, which would pose virtually no 17 risk of collision mortality for the subject bat species. Lower structures pose less collision risk to 18 flying animals. The risk of collision mortality posed by stationary tall construction equipment 19 (e.g., cranes) would be low and temporary, reducing the risk even further. Thus, potential 20 effects on the subject bat species due to collision mortality are considered minimal.

21 M.7.1.6 Activity - Changes in Surface-Water Quality 22 Changes in surface-water quality may be caused by sediment (Section M.4.1.3), herbicides 23 (Section M.4.1.6), and other contaminants through erosion and accidental spills during building 24 and operation. Because insects associated with wetland and aquatic habitats make up part of 25 the diet of the Indiana, northern long-eared, little brown, and tri-colored bats (diet also includes 26 terrestrial insects), and the complete diet of gray bats, a change in water quality could affect the 27 local prey base. Decreases in water quality may reduce the availability of aquatic insects and 28 reduce the availability of or quality of drinking water (FWS 2015-TN5312). It is expected that 29 such water-quality impacts would be negligible and temporary because of TVAs use of BMPs 30 (TVA 2012-TN4911) for controlling erosion and in its use of pesticides and herbicides, as well 31 as its intention to implement a pollution prevention plan (Section M.4.1.3). It is therefore 32 anticipated that any minor, temporary reductions in water quality and effects on associated prey 33 (e.g., bioaccumulation of contaminants or prey reduction) would not cause a decrease in the 34 fitness of bats.

35 M.7.1.7 Activity - Transmission Line Corridor Maintenance 36 Transmission line corridor vegetation maintenance (routine use of herbicides along with mowing 37 and hand-clearing of vegetation) would only take place within the relocated section of the 38 161-kV corridor on the CRN Site (Figure M-3) (Section M.5.1.4). Maintenance of this corridor 39 may be beneficial by providing long-term foraging habitat and a potential travel route along the 40 Clinch River for Indiana, northern long-eared, little brown, and tri-colored bats.

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1 M.7.2 Gray Bat 2 As discussed in Section M.6.1.1.4, one gray bat was captured in mist nets in summer on the 3 CRN Site in 2011, and there was a total of 361-381 acoustic recordings (note that multiple 4 recordings may be from one individual) in spring, summer, and fall on the CRN Site and in the 5 BTA in 2013 and 2015 (Hamrick 2015-TN5187; LeGrand et al. 2015-TN5188). No caves are 6 known to be located on the CRN Site or in the BTA. Thus, the species likely uses the CRN Site 7 and BTA for foraging, but does not likely roost there. Rennies Cave and 2-Batteries Cave are 8 located within the Grassy Creek Habitat Protection Area, and there are three additional 9 caves/karst openings near Grassy Creek (LeGrand et al. 2015-TN5188). The five caves noted 10 above have not been surveyed for bats. The CRN Site and BTA may be part of a foraging 11 territory for bats in a maternity or non-maternity cave located somewhere offsite within 1 km of 12 the Clinch River (FWS 1982-TN929), possibly in the caves noted above (Section M.6.1.1.4).

13 There would be no direct effects on gray bats from the activities discussed in Section M.7.1.

14 Indirect effects are discussed below.

15 M.7.2.1 Indirect Adverse Effects 16 All gray bats fly in the protection of forest canopy between caves and foraging areas. Forested 17 areas surrounding caves and between caves and over-water feeding habitat are advantageous 18 for gray bat survival. Gray bat feeding areas have not been found over rivers or reservoirs 19 where adjacent areas of forest have been cleared (FWS 1982-TN929). It is unknown whether 20 and where any maternity or non-maternity caves are located near the proposed site. Thus, 21 routes taken by gray bats in the area of building on the CRN Site to forage along the river and 22 associated wetlands ponds, and streams are unknown. However, notwithstanding the lack of 23 forest in the CRBR footprint, gray bats currently use the nearby river and wetland environment.

24 It is uncertain whether removal of more forest in the northern part of the CRN Site and in the 25 BTA (Figure M-7) would disrupt existing commuting routes to the river and associated wetlands 26 and/or use of these as a foraging area. This could require gray bats to find alternative forested 27 commuting corridors to the same or a more distant foraging area along the river. One factor 28 that may facilitate possible continued use of the river environment in the project area for 29 foraging is that a strip of forest would remain along the river after development of the CRN Site 30 and the BTA (Figure M-7). However, it is uncertain whether this strip of forest is currently used 31 to access the river and wetlands and whether it would be used after building, especially 32 because it would become much narrower in places after site development (Figure M-7).

33 Potential indirect adverse effects on gray bats also include increased noise, human activity, and 34 light levels during nighttime. It is difficult to predict the degree to which bats would be disturbed 35 by noise. Some studies suggest that bats may be able to tolerate loud noises while other 36 studies suggest that bats avoid noisy areas (FWS 2005-TN5382). There is evidence to suggest 37 that increased levels of noise and light may have a negative effect on foraging bats (FWS 2017-38 TN5346). These factors could reduce the quality of remaining forested areas on and around the 39 CRN Site and in the BTA for use as commuting corridors, and/or reduce the quality of the 40 existing foraging areas along the Clinch River and associated wetlands, ponds, and streams.

41 Avoidance could disrupt use of existing commuting routes to the river and associated wetlands 42 and/or use of these as a foraging area, and necessitate finding alternative forested commuting M-104

1 corridors to the same or a more distant foraging area along the river. Depending on the energy 2 expended to find new commuting corridors and/or foraging areas, and the increase in distance 3 between caves and foraging areas, these activities could result in reduced fitness.

4 M.7.2.2 Summary 5 The review team concludes that loss of forest habitat and increased nighttime noise, human 6 activity, and lighting on the CRN Site and in the BTA necessary to build the proposed facilities 7 may adversely affect the gray bat. However, the review team does not believe that these 8 effects could jeopardize the gray bat, because they are not expected to disturb hibernacula or 9 enhance the spread of WNS.

10 M.7.3 Indiana Bat 11 As noted in Section M.6.1.2.4, Indiana bats were not captured with mist nets or detected 12 acoustically in 2011 but were detected acoustically in 2013 both on the CRN Site and in the 13 BTA (17 recordings on the CRN Site and 4 recordings in the BTA) in spring and summer 14 (Hamrick 2015-TN5187; LeGrand et al. 2015-TN5188). The low number of acoustic recordings 15 indicates the CRN Site and BTA are most likely used by males and/or nonreproductive females 16 for spring and summer roosting and foraging. Because the species was only detected in spring 17 and summer but not fall (when swarming in the vicinity of a hibernaculum would occur), either 18 on the CRN Site or in the BTA, a hibernaculum is likely not located in the immediate vicinity 19 (including the five caves in the Grassy Creek area). This assessment is not definitive due to the 20 small size of the acoustic recording data set (note that multiple recordings may be from one 21 individual). Based on the results of the potential roost tree study, forest habitat on the CRN Site 22 and in the BTA provides suitable roosting habitat for the Indiana bat. The species is also known 23 to occur on the ORR, but the nearest known maternity colony and hibernation site are 30 mi 24 from the CRN Site (Section M.6.1.2.4.

25 M.7.3.1 Direct Adverse Effects 26 Potential direct adverse effects on roosting bats by tree removal could include (1) harm (injury 27 or death) if occupied roost trees are felled (there are currently no seasonal tree harvest 28 restrictions) and (2) harassment from tree felling noise resulting in displacement (FWS 2017-29 TN5346). Displaced bats may alter normal behavior patterns (FWS 2017-TN5346) and be 30 forced to locate new roosts in the spring when they are stressed from hibernation and migration, 31 or in the summer or fall, depending on the timing of tree harvest. Depending on the distance 32 bats are required to fly to find suitable alternate roost tree habitats, their energy expenditure 33 could result in reduced fitness. Bats could also encounter increased intra-specific or inter-34 specific competition (e.g., with the NLEB) in locating and establishing alternative roost sites, 35 which could also result in reduced fitness. The roost availability in these areas may be limited 36 by the habitat itself, as well as by competition. The displaced bats may need to increase energy 37 expenditures because new roosting habitat may be more distant from traditional foraging areas.

38 Alternatively, displaced bats may first seek new foraging areas and then new roost trees in 39 association with them, also increasing energy expenditure (addressed in Section M.7.3.2).

40 M-105

1 Increased energy expenditure is anticipated to affect fitness and nutrition (FWS 2005-TN5382).

2 Reduced fitness could result in reduced survivorship and decline in local population abundance 3 and viability.

4 M.7.3.2 Indirect Adverse Effects 5 Potential indirect adverse effects on bats could include (1) removal of foraging habitat and 6 (2) increased noise, human activity, and light levels. Both of these indirect adverse effects may 7 result in a need to find alternative foraging areas.

8 The Indiana bat is dependent upon aquatic and terrestrial insects for forage. Much of the 9 Indiana bat terrestrial prey base (e.g., moths, beetles, wasps, flying ants, leafhoppers, tree 10 hoppers, etc.) are dependent upon a forested environment (FWS 2005-TN5382). Intermittent 11 streams and riparian areas are often preferred foraging habitats for the bat (FWS 2005-12 TN5382). One of the primary effects on the Indiana bat would be the loss of foraging habitat 13 (Section M.7.1.3). The loss of stream habitats, coupled with the loss of associated riparian 14 forested habitats, would possibly eliminate some preferred foraging areas, as well as bat 15 flyways and watering areas. In addition, the loss of riparian forest may greatly reduce the 16 foraging efficiency because riparian forests have been shown to provide a much higher volume 17 of insects (FWS 2005-TN5382). The forested habitat remaining in the Action Area would 18 become more isolated (Figure M-7) and perhaps less suitable to support the Indiana bat.

19 Because Indiana bats likely locate their roost trees within foraging areas or along commuting 20 corridors, any large-scale modification of habitat that includes destruction of foraging areas may 21 be particularly detrimental (FWS 2005-TN5382). Indiana bats may also experience higher rates 22 of predation when searching for new foraging and roosting areas due to loss of the benefits of 23 site familiarity, which include more profitable exploitation of local food resources, and greater 24 awareness of resident predators. Even if there is an ability to relocate, the l increased energy 25 expenditure associated with loss and degradation of terrestrial foraging (and any associated 26 roosting) habitat, riparian foraging habitat, and water sources may result in overall decreased 27 fitness of individuals. Decreased fitness can result in death or injury through predation and 28 starvation. In addition, the feeding habits of Indiana bats are similar to those of the little brown 29 bat, the NLEB, and to a lesser extent the tri-colored bat (FWS 2005-TN5382). Indiana bats 30 could thus also encounter increased intra-specific or inter-specific competition in locating and 31 establishing alternative foraging areas. This could also result in reduced fitness, which may lead 32 to reduced survivorship and decline in local population abundance and viability.

33 Noise (as well as increased human activity and light levels) would result in a decrease in the 34 quality of the remaining habitat on the CRN Site and in the BTA (M.7.2.1). Because noise 35 would be generated day and night, roosting and foraging bats may frequently be disturbed. It is 36 conservative and reasonable to conclude that noise and vibrations related to building and 37 operation activities could result in bats abandoning roosts. Limited data are available about how 38 far away from noise tree-roosting bats need to be for these effects to be avoided (FWS 2005-39 TN5382). In the absence of these data, the review team relies on the standards noted in the 40 introduction to the subsection on noise in Section M.7.1.1. Thus, the review team assumes 41 noise and ground vibrations may affect bats up to 0.5 mi from the CRN Site, BTA, and buried 42 69-kV transmission line. Depending on the distance bats are required to fly to find new habitat M-106

1 in which they could resume roosting or foraging activities in calm conditions, their energy 2 expenditure could result in reduced fitness. This reduced fitness could then result in reduced 3 survivorship and reproduction and a decline in local population abundance.

4 M.7.3.3 Summary 5 The review team concludes that removal of roosting and foraging habitat and project-related 6 noise generation, increased human activity, and lighting on the CRN Site and in the BTA 7 necessary to build the proposed facilities may adversely affect the Indiana bat. However, the 8 review team does not believe that these effects could jeopardize the Indiana bat, because they 9 are not expected to disturb hibernacula or enhance the spread of WNS.

10 M.7.4 Northern Long-Eared Bat 11 As noted in Section M.6.1.3.4, one individual NLEB was captured in mist nets in summer on the 12 CRN Site in 2011 and there was a total of 25 to 32 acoustic recordings (note that multiple 13 recordings may be from one individual) in spring, summer, and fall on the CRN Site and in the 14 BTA in 2013 and 2015 (Hamrick 2015-TN5187; LeGrand et al. 2015-TN5188). Given the low 15 number of captures and acoustic recordings, the CRN Site and BTA are most likely used by 16 males and/or nonreproductive females for spring, summer, and fall roosting and foraging. Roost 17 sites have been documented to occur about 0.04 to 3.0 mi from foraging areas (80 FR 17974 -

18 TN4216). Thus, roost sites may or may not occur on the CRN Site and in the BTA but should 19 be assumed to occur there because of the presence of suitable habitat. The suitable habitat for 20 the Indiana bat on the CRN Site and in the BTA is also suitable for the NLEB for spring, 21 summer, and fall roosting and foraging. Acoustic recordings during fall indicate the possible 22 presence of a hibernaculum in the vicinity (i.e., within about 5 mi). Rennies Cave and 23 2-Batteries Cave located within the Grassy Creek Habitat Protection Area, and the three 24 additional caves/karst openings near Grassy Creek (LeGrand et al. 2015-TN5188) have not 25 been surveyed for bats. A NLEB hibernaculum about 9 mi away was discovered by TVA in 26 January 2014 (LeGrand et al. 2015-TN5188).

27 M.7.4.1 Direct Adverse Effects 28 Potential direct adverse effects on roosting bats by tree removal could include (1) harm (injury 29 or death) if occupied roost trees are felled (there are currently no seasonal tree harvest 30 restrictions) and (2) harassment from tree felling noise resulting in displacement.

31 Habitat loss and fragmentation increases the proportion of forest edge habitat, which correlates 32 with reduced NLEB occupancy. Displaced bats may be forced to locate new roosts in the spring 33 when they are stressed from hibernation and migration, or in the summer or fall, depending on 34 the timing of tree harvest. Depending on the distance bats are required to fly to find suitable 35 alternate roost tree habitats, their energy expenditure could result in reduced fitness. Bats 36 could also encounter increased intra-specific or inter-specific competition (e.g., with the Indiana 37 bat) in locating and establishing alternative roost sites, which could also result in reduced 38 fitness. The roost availability in these areas may be limited by the habitat itself, as well as by 39 competition. However, because NLEBs may roost in younger roost trees (down to 3 in. in 40 DBH), the species may have greater roost tree availability, which could lessen the effects of M-107

1 locating and establishing alternative roost sites relative to the Indiana bat. Timber harvest alone 2 has not to date had significant, population-level effects on the NLEB (80 FR 17974 -TN4216);

3 this has not been the case for the Indiana bat. Thus, unlike the Indiana bat, effects on the 4 fitness, including reproductive fitness or survivorship, of individual bats likely would not rise to 5 the level of affecting population abundance and viability except when overlaid on the effects of 6 WNS (Section M.6.1.3.1).

7 M.7.4.2 Indirect Adverse Effects 8 Potential indirect adverse effects on bats could include (1) removal of foraging habitat and 9 (2) increased noise, human activity, and light levels. Both of these indirect adverse effects may 10 result in a need to find alternative foraging areas.

11 Unlike the Indiana bat, NLEB foraging habitat is largely confined to under the forest canopy.

12 Thus, mature forest habitat not only provides suitable roosting habitat, but is also an important 13 habitat type for foraging NLEBs, because it provides prey that accommodate the gleaning part 14 of the species foraging lifestyle (e.g., snags and downed logs that provide insects) (80 FR 15 17974 -TN4216). Mature forest habitat would remain elsewhere on the CRN Site and in the 16 BTA after building. It also exists offsite, more on the ORR than south of the Clinch River (Parr et 17 al. 2015-TN5151). NLEBs whose foraging areas occur within an affected area of suitable 18 habitat onsite or whose foraging areas would be disconnected (i.e., loss of a suitable travel 19 corridor), may expend an increased amount of energy to establish new commuting patterns to 20 alternate foraging areas, which could decrease fitness. NLEBs may also be subject to 21 increases in inter- and intra-specific competition (Indiana bat, little brown bat, and to a lesser 22 extent the tri-colored bat) if available foraging habitat is limited, which could also result in 23 decreased fitness. Because the foraging habitat preferred by the NLEB is more specialized 24 than that preferred by the Indiana bat, the effects of foraging habitat removal may affect the 25 NLEB more.

26 The indirect impacts of noise (as well as increased human activity and light levels) on the NLEB 27 would be similar to those of the Indiana bat and are thus not repeated here.

28 M.7.4.3 Summary 29 The review team concludes that removal of roosting and foraging habitat as well as project-30 related increase in noise generation, human activity, and lighting on the CRN Site and in the 31 BTA necessary to build the proposed facilities may adversely affect the NLEB. However, the 32 review team does not believe that these effects could jeopardize the NLEB, because they are 33 not expected to disturb hibernacula or enhance the spread of WNS.

34 M.7.5 Tri-Colored Bat 35 As noted in Section M.6.1.4.4, three tri-colored bats were caught in mist nets on the CRN Site in 36 2011 and the species was recorded acoustically on the CRN Site and in the BTA in spring, 37 summer, and fall in 2013 and 2015 (LeGrand et al. 2015-TN5188). The species was the most 38 prevalent species acoustically recorded in the BTA in 2015 (Hamrick 2015-TN5187). The 39 species uses manmade structures or tree cavities for maternity colonies. Non-maternity M-108

1 summer roosts are mainly in tree foliage and occasionally in buildings (NatureServe 2017-2 TN5216). It is possible that the species uses the CRN Site and BTA for roosting and foraging.

3 Recordings of the species in the fall may indicate a possible hibernaculum in the vicinity of the 4 CRN Site or BTA. One tri-colored bat was observed in Rennies Cave in the Grassy Creek 5 Habitat Protection Area by archaeologists in April 2011 (Section M.6.1.4.4).

6 The same general direct and indirect adverse impacts described above for the Indiana bat and 7 NLEB would also apply to the tri-colored bat.

8 The review team concludes that removal of roosting and foraging habitat and project-related 9 noise generation and increased human activity and lighting on the CRN Site and in the BTA 10 necessary to build the proposed facilities may adversely affect the tri-colored bat. However, the 11 review team does not believe that these effects could jeopardize the tri-colored bat, because 12 they are not expected to disturb hibernacula or enhance the spread of WNS.

13 M.7.6 Little Brown Bat 14 As noted in Section M.6.1.5.4, the little brown bat was not captured in mist nets on the CRN Site 15 in 2011 (LeGrand et al. 2015-TN5188), but was recorded acoustically on the CRN Site and in 16 the BTA in spring, summer, and fall in 2013 and 2015 (LeGrand et al. 2015-TN5188; 17 Hamrick 2015-TN5187). Maternity colonies and non-maternity summer roosts are human-made 18 structures or tree cavities (NatureServe 2017-TN5216). Recordings of the species in the fall 19 may indicate a possible hibernaculum in the vicinity of the CRN Site or BTA.

20 The same general direct and indirect adverse impacts described above for the Indiana bat and 21 NLEB would also apply to the little brown bat.

22 The review team concludes that removal of roosting and foraging habitat and project-related 23 noise generation and increased human activity and lighting on the CRN Site and in the BTA 24 necessary to build the proposed facilities may adversely affect the little brown bat. However, 25 the review team does not believe that these effects could jeopardize the little brown bat, 26 because they are not expected to disturb hibernacula or enhance the spread of WNS.

27 M.7.7 Aquatic Species 28 The aquatic species in the Tennessee River system (including Clinch River) have changed 29 considerably as a result of human activities (e.g., impoundment of the river and introduction of 30 invasive non-native species). Historical impoundment of the river below and above the CRN 31 Site has greatly altered the dynamics of river flow. For example, spring floods that once 32 occurred along the river no longer occur, and the expansive rocky or gravel shoal areas that 33 once abounded in the Tennessee River system no longer exist (Etnier and Starnes 1993-34 TN5054). In particular, mussel populations have declined dramatically or have even been 35 extirpated. Similarly, fish species richness and diversity have declined since the introduction of 36 the impoundments on the Clinch River.

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1 M.7.7.1 CRN Site and Vicinity 2 The Action Area for aquatic habitats in the CRN Site and vicinity is the same as the project area 3 described in Section M.3.1 and shown in Figure M-3. Aquatic habitats in the project area of the 4 CRN Site and vicinity include streams and ponds on the CRN Site and in the BTA (TVA 2017-5 TN4921). They also include the streams crossed by the proposed route for the 69-kV 6 underground transmission line and the Clinch River arm of the Watts Bar Reservoir from above 7 the location of the intake at approximately CRM 17.9, on the east side of the CRN Site to 8 approximately CRM 14 just downstream of the barge-unloading facility and approximately 1.5 mi 9 downstream of the discharge (located at approximately CRM 15.5 on the west side of the 10 CRN Site).

11 M.7.7.2 Freshwater Mussels 12 Between September 21 and 26, 2011, TVA conducted a mollusk and habitat survey using semi-13 quantitative and qualitative sampling methods (TRC 2011-TN5168). A total of 74 living native 14 mussels were collected from six different species (TRC 2011-TN5168). Neither the pink mucket 15 nor the sheepnose mussel was found during these surveys. Zebra mussels have invaded the 16 area and were found to be attached to 71 of the 74 living native mussels with an average area 17 coverage of 28 percent (TRC 2011-TN5168). As discussed previously the presence of zebra 18 mussels is detrimental to the survival of native mussels. Zebra mussels affect the growth and 19 reproduction of native mussels by competing for space and food, interfering with the native 20 mussels ability to open and close their shells, impairing movement of the native mussels, and 21 depositing metabolic wastes on the native mussels (FWS 2015-TN5218).

22 The most recent siting of a pink mucket in the Clinch River was in 1984 at CRM 19.1, slightly 23 above the CRN Site. The sheepnose mussel was last observed in 1994 at CRM 21.4 24 downstream of Melton Hill Dam (TWRA 2017-TN5362). No pink muckets or sheepnose 25 mussels either living or as relic shells, were found in the 2011 surveys at the CRN Site.

26 Based on the lack of observed sightings of the pink mucket and sheepnose mussels during 27 surveys within the Action Area, either living or as relic shells, and the degree to which invasive 28 zebra mussels have affected the existing native mussel population, the review team concludes 29 that the endangered pink mucket and sheepnose mussels are unlikely to be present and 30 therefore building and operating the CRN Site may affect but are not likely to adversely affect.

31 M.7.7.3 Spotfin Chub 32 TVA performed sampling studies in 2011 at two sampling locations downstream between CRM 33 14 and 15 and upstream between CRM 18 and 19.8 using electrofishing and gillnetting 34 techniques. Surveys were conducted during the months of February, May, July, and October.

35 The spotfin chub was not found during these surveys, either upstream or downstream.

36 During March 2015, TVA conducted biological surveys on streams inside the CRN Site and the 37 BTA focusing on aquatic communities in pools, riffles, and runs appearing likely to support 38 communities of aquatic biota. The spotfin chub was not identified in any of the surveys 39 (TVA 2017-TN4921).

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1 Based on the lack of observed sightings of the spotfin chub during surveys within the Action 2 Area, the review team concludes that the spotfin chub is unlikely to be present and therefore 3 building and operating the CRN Site may affect but is not likely to adversely affect.

4 M.7.7.4 Hellbender 5 The hellbender prefers habitats with swift running, fairly shallow, highly oxygenated waters.

6 This species finds flat rocks, logs, or other cover in the vicinity of riffle areas, essential for 7 feeding and breeding (Mayasich et al. 2003-TN5179). Its habitat is generally medium to large 8 clear, fast-flowing streams with rocky bottoms, especially riffle areas and upper pool reaches. A 9 hellbender was most recently observed in 1989 in the Clinch River downstream of Jones Island 10 below Melton Hill Dam (TNHP 2017-TN5361). The Clinch River arm of the Watts Bar Reservoir 11 adjacent to the CRN Site lacks the appropriate habitat for the hellbender. However, this species 12 could still exist in the shallower water upstream of the site below Melton Hill Dam.

13 Based on the lack of appropriate habitat (fast-flowing water over rocky bottom with riffle areas) 14 in the Action Area, the review team concludes that the hellbender is unlikely to be present and 15 therefore building and operating the CRN Site may affect but is not likely to adversely affect it.

16 M.7.7.5 Summary of Effects 17 It is unlikely that Federally listed species (specifically the pink mucket, sheepnose mussel and 18 spotfin chub) or the hellbender are present in the Clinch River arm of the Watts Bar Reservoir in 19 the area of the CRN Site or in the streams and ponds on the site and in the BTA. The review 20 team has determined that Federally listed species and the hellbender are not present in the 21 Action Area and that building and operating the proposed project facilities at the CRN Site may 22 affect but is not likely to adversely affect Federally listed species or the hellbender.

23 M.7.8 Transmission Line Upgrades 24 The transmission lines identified by TVA for upgrades are listed in Table M-3 and depicted in 25 Figure M-4, and the descriptions of TVAs upgrade activities are provided in Section M.4.2. The 26 uncertainties surrounding TVAs identification of these transmission lines, the upgrade 27 engineering solutions, and locations and extent of habitat disturbance are described in Section 28 M.4.2. The review team expects, based on the nature of how transmission lines are upgraded, 29 that TVA would limit ground disturbance to upland areas within the existing bounds of 30 established right-of-ways, and thus would not physically disturb aquatic habitats or wetlands or 31 remove mature trees or forest cover (including trees from forested wetlands, stream banks, or 32 reservoir shorelines). Under this assumption, there could be no impacts on fish and mollusk 33 species in Table M-8, Table M-9, and Table M-10 (for all of which NA is accordingly noted), as 34 well as any critical habitat for these species, If TVA submits a project design in a future COL or 35 CP application that reveals potential impacts to aquatic, wetland, or forest area, then it would be 36 necessary at that time to evaluate possible adverse effects to species using those habitats.

37 Note that there is no Action Area for the offsite transmission lines, because the location and 38 extent of habitat disturbance within the upland portions of the 430 mi of corridors is unknown 39 and would likely constitute only a small percentage of their land area (5,327 ac). The bat M-111

1 species, Berry cave salamander, and several plant species listed in Table M-10 could occur in 2 upland areas within the bounds of corridors of transmission lines identified for upgrade 3 (Table M-3) in the counties where the species are known to occur (Table M-8 and Table M-10).

4 The mammals that potentially could be affected include the Virginia big-eared bat (Corynorhinus 5 [=Plecotus] townsendii virginianus), gray bat, NLEB, little brown bat, and Indiana bat. The gray 6 bat, NLEB, little brown bat, and Indiana bat could be affected by reconductoring activities in the 7 corridor of transmission line L5125 in Campbell County, Tennessee. Potential effects would be 8 possible if such activities are actually conducted within this corridor and near Norris Dam cave 9 (Figure M-10) (which occurs in the corridor and is known or assumed to have been used by 10 these species in the past [Table M-9 and Table M-10]) and if the species use Norris Dam cave 11 during the duration of work activities, all of which are currently unknown. The Virginia big-eared 12 bat could possibly be affected by reconductoring activities in the corridor of transmission line 13 L5125 in Whitley County, Kentucky (Table M-10). Potential effects would be possible if suitable 14 cave habitat occurs in this corridor and is inhabited by the species, and if such activities are 15 actually conducted within this corridor and near an inhabited cave during its season of use by 16 the species, all of which are currently unknown.

17 The Berry cave salamander (Gyrinophilus gulolineatus) could possibly be affected by upgrade 18 activities in the corridors of transmission lines L5092 and L5659 in Knox County and L5205, 19 L5235, L5280, and L5743 in Roane County, Tennessee (Table M-3 and Table M-10). Potential 20 effects would be possible if suitable cave habitat occurs in this corridor and is inhabited by the 21 species, and if such activities are actually conducted within this corridor and near an inhabited 22 cave, all of which are currently unknown.

23 Virginia spiraea (Spiraea virginiana) could possibly be affected by uprate activities in the 24 corridor of transmission line L5173 in Rhea County, Tennessee (Table M-3), because this 25 species is known to occur just outside the corridor near Piney Creek (Figure M-11 and 26 Table M-10) and may thus also occur near this creek within the corridor. The species could also 27 be affected by upgrade activities in the corridors of transmission lines in Whitely County, 28 Kentucky, and Bledsoe, Cumberland, Hamilton, Roane, Scott, Sequatchie, VanBuren, and 29 White Counties, Tennessee (transmission lines listed in Table M-10), counties in which the 30 species is known to occur (Table M-8). Potential effects would be possible if suitable habitat 31 occurs in these corridors and is occupied by the species, and if upgrade activities are actually 32 conducted within these corridors and near occupied habitat, all of which are currently unknown.

33 Prices potato-bean (Apios priceana) could be affected by upgrade activities in the corridors of 34 transmission lines L5167 and L5702 in Franklin County, Tennessee (Table M-10), counties in 35 which the species is known to occur (Table M-8). Potential effects would be possible if suitable 36 habitat occurs in these corridors and is occupied by the species, and if upgrade activities are 37 actually conducted within these corridors and near occupied habitat, all of which are currently 38 unknown.

39 Cumberland rosemary (Conradina verticillata) could be affected by upgrade activities in the 40 corridors of transmission lines L5204 and L5205 in Cumberland, L5882 in Scott, and L5173 in 41 White Counties, Tennessee (Table M-10), counties in which the species is known to occur 42 (Table M-8). Potential effects would be possible if suitable habitat occurs in these corridors and M-112

1 is occupied by the species, and if upgrade activities are actually conducted within these 2 corridors and near occupied habitat, all of which are currently unknown.

3 White fringeless orchid (Platanthera integrilabia) could be affected by upgrade activities in the 4 corridors of transmission lines in Whitely County, Kentucky, and Bledsoe, Cumberland, 5 Franklin, Grundy, Hamilton, Roane, Scott, Sequatchie, VanBuren, and Warren Counties, 6 Tennessee (transmission lines listed in Table M-10), counties in which the species is known to 7 occur (Table M-8). Potential effects would be possible if suitable habitat occurs in these 8 corridors and is occupied by the species, and if upgrade activities are actually conducted within 9 these corridors and near occupied habitat, all of which are currently unknown.

10 The Carolina northern flying squirrel, painted tigersnail, spruce-fir moss spider, several plant 11 species, and rock gnome lichen are unlikely to occur in upland areas within the bounds of 12 corridors of transmission lines (Table M-10 [species for which NA is noted]) are likewise unlikely 13 to be adversely affected by transmission line upgrades.

14 The critical habitats for the spruce-fir moss spider and Indiana bat were dismissed from further 15 evaluation in Section M.6.2.

16 At the ESP stage, NRC regulated ground-disturbing activities are not approved. If an applicant 17 later requests a COL or CP relying on the ESP, additional protective measures, if any, would be 18 developed in consultation with other applicable Federal, State, and local agencies at the COL or 19 CP stage.

20 M.8 Cumulative Effects 21 Cumulative effects include the effects of future State, Tribal, local, or private actions (not 22 involving other Federal actions because these would undergo separate Section 7 consultation) 23 that are reasonably certain to occur in the Action Area (FWS and NMFS 1998-TN1031). The 24 Action Area for bats is defined in Section M.7.1.4. It consists of the land area within about 0.5 25 mi from the CRN Site boundary, BTA, and the route of the 69-kV transmission line, which 26 includes land within the Grassy Creek Habitat Protection Area and ORR to the north, as well as 27 to the south of the Clinch River. This Action Area encompasses the area of the direct and 28 indirect effects of habitat loss and the indirect effects of noise, human activity, and lighting.

29 Cumulative impacts may result when the effects of future State, Tribal, local, or private actions 30 are overlaid on those arising from the building and operation activities associated with the CRN 31 Site, BTA, and underground transmission line. Within the Action Area for bats, the future 32 actions that would affect resources used by bats include anticipated continued small-scale 33 development of the ORR as well as small-scale, dispersed agricultural development and forest 34 harvest in non-ORR lands to the south and west. The effects of these small-scale activities 35 alone in the Action Area would be minor in comparison to those associated with building and 36 operating activities at the CRN Site, BTA, and affected underground transmission line area, 37 especially during the period of building activities, and would likely be somewhat offset in the 38 long-term by reversion of abandoned agricultural or timber land back to forest. Thus, the effects 39 of agricultural development and forest harvest on bats would be generally similar to those 40 arising from building and operating activities at the CRN Site, BTA, and affected underground 41 transmission line area.

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1 The Action Area for aquatic species is within the CRN Site and the BTA as well as the adjacent 2 stretch of the Clinch River arm of the Watts Bar Reservoir from the proposed location of the 3 intake at approximately CRM 17.9, on the east side of the CRN Site to approximately CRM 14 4 just downstream of the barge-unloading facility to the barge-unloading facility. Within the Action 5 Area, potential future actions include small-scale, dispersed agricultural development along the 6 opposite shore of the Clinch River arm of the Watts Bar Reservoir from the site. The effects of 7 these activities alone, although similar, would also be minor in comparison to effects of building 8 and operating activities at the CRN Site, BTA, and affected underground transmission line area.

9 Note that because there is no Action Area for the offsite transmission lines (Section M.7.8),

10 there is no corresponding evaluation of cumulative impacts.

11 M.9 Conclusions 12 TVA applied to the NRC for an ESP to address certain siting issues associated with building 13 multiple SMRs at the CRN Site on the Clinch River in the southwest part of the City of Oak 14 Ridge, Tennessee. The CRN Site is presently undeveloped, although a portion of it has a 15 history of disturbance as part of site preparation for the CRBR project discontinued in the early 16 1980s. If the NRC issues an ESP, that action will resolve certain siting issues for up to 20 years 17 but will not actually authorize TVA to construct or operate reactors on the CRN Site. TVA will 18 still have to apply to the NRC in the future for a COL or CP before proceeding to construct the 19 reactors.

20 This BA evaluates the potential effects from building and operating SMRs at the CRN Site on 21 five bat species (the gray bat, Indiana bat, NLEB, tri-colored bat, and little brown bat), two 22 mussel species (pink mucket and sheepnose mussel), one fish species (spotfin chub), and one 23 amphibian species (hellbender). The tri-colored bat, little brown bat, and hellbender are not 24 actually protected under the ESA, but may be listed in the future. The Action Area for bats 25 addressed in the BA encompasses lands within about 0.5 mi from the CRN Site boundary, BTA, 26 and the route of the 69-kV transmission line, which encompasses the area of direct and indirect 27 effects of habitat loss and the indirect effects of noise, human activity, and lighting.

28 The Action Area for aquatic habitats addressed in the BA encompasses the streams and ponds 29 on the CRN site, BTA, and other affected areas as well as adjoining portions of the Clinch River 30 arm of Watts Bar Reservoir. Aquatic habitats on the CRN Site and in the vicinity include 31 multiple streams and ponds (TVA 2017-TN4921). They also include multiple streams crossed 32 by the proposed route for the 69-kV underground transmission line and the Clinch River arm of 33 the Watts Bar Reservoir from above the location of the intake at approximately CRM 17.9, on 34 the east side of the CRN Site to approximately CRM 14 just downstream of the barge-unloading 35 facility and approximately 1.5 mi downstream of the discharge (located at approximately CRM 36 15.5 on the west side of the CRN Site).

37 The BA was prepared by terrestrial and aquatic biologists with NRC and its contractor, PNNL, 38 and the USACE, which is a cooperating agency working under NRCs lead to prepare an EIS for 39 the ESP. The biologists visited the Action Area on and in the vicinity of the site and 40 communicated with the FWS multiple times from 2014 through 2017. This BA evaluates effects 41 based on a PPE representing a conceptual design developed by TVA to support the ESP M-114

1 application submitted to NRC in 2017. If TVA subsequently decides to submit an application for 2 a COL or CP to NRC, it will include with that application an updated, more specific design. The 3 NRC would at that time prepare a subsequent BA that would update this current BA to reflect 4 the updated design, species, and habitats known to potentially occur in the Action Areas at that 5 time, and baseline conditions in the Action Areas at that time.

6 M.9.1 CRN Site, BTA, and Vicinity Including the Affected 69 kV Transmission 7 Line Corridor 8 Effects determinations drawn by the review team at this time are provided in Table M-11 for 9 each of the nine species addressed in this BA for the CRN Site, BTA, and buried 69 kV 10 transmission line. These determinations are predicated on the conceptual project design and 11 PPE that TVA submitted to the NRC when applying for the CRN Site ESP as outlined in Section 12 M.3.3 of this BA and the evaluations of direct and indirect effects on each species presented in 13 Section M.7 of this BA.

14 Table M-11. Effect Determinations for Federally Listed Species and FWS Requested 15 Species from Building and Operating the Proposed SMRs at the CRN Site Common Name Scientific Name Status Determination Gray bat Myotis grisescens E May affect, likely to adversely affect (LAA)

Indiana bat Myotis sodalis E May affect; LAA NLEB Myotis septentrionalis T May affect; LAA Tri-colored bat Perimyotis subflavus May affect, LAA Little brown bat Myotis lucifugus May affect, LAA Pink mucket mussel Lampsilis abrupta E May affect, not likely to adversely affect (NLAA)

Sheepnose mussel Plethobasus cyphyus E May affect, NLAA Spotfin chub Erimonax monachus T May affect, NLAA Hellbender Cryptobranchus May affect, NLAA alleganiensis E = Federal endangered; T = Federal threatened.

Source: USFWS Environmental Conservation Online System (https://ecos.fws.gov/ecp/).

16 The review team concludes that the building and operating activities at the CRN Site, BTA, and 17 affected transmission line areas may affect and are likely to adversely affect (LAA) each of the 18 five bat species addressed. Most of the potential adverse effects would be related to loss of 19 forest habitat and increased daytime and nighttime noise, human activity, and lighting.

20 However, the review team does not believe that the project could jeopardize any of the bat 21 species.

22 The review team concludes that building and operating activities at the CRN Site, BTA, and 23 affected transmission line areas may affect but is not likely to adversely affect (NLAA) any of the 24 aquatic species addressed in this BA. Extensive prior disturbance of once suitable habitats for 25 these species in the Action Area makes their continued presence unlikely. The review team 26 acknowledges the possible presence of hellbenders in the shallows of the Clinch River arm of M-115

1 Watts Bar Reservoir upstream from the CRN Site to Melton Hill Dam, but this portion of the 2 reservoir is unlikely to be affected by building and operating activities at the CRN Site and BTA.

3 M.9.2 Offsite Transmission Line Upgrades 4 As discussed in Section M.7.8, there is no information on the locations and extent of habitat 5 disturbance within the uplands of the offsite transmission line corridors. Consequently, an 6 evaluation of potential impacts to the Federally listed bat species, Berry cave salamander, and 7 several plant species that could occur in the uplands (Table M-10, species without a NA 8 notation) could not be performed (Section M.7.8). Thus, the review team is unable to make 9 impact conclusions for these species at this time. The review teams conclusion for Federally 10 listed Carolina northern flying squirrel, painted tigersnail, spruce-fir moss spider, several plant 11 species, and rock gnome lichen that likely would not occur in the uplands of the offsite 12 transmission line corridors (Table M-10, species with a NA notation) is NLAA. The 13 determination for the critical habitat for the Indiana bat and spruce-fir moss spider is no adverse 14 modification because the critical habitats for the species do no occur within or near the 15 transmission line corridors (Section M.6.2).

16 The review team concludes that the transmission line upgrades would have no effect (NE) on 17 each of the aquatic species (fish and mollusks) in Table M-10. This conclusion reflects the 18 assumption that TVA would not perform any work within rivers, streams, ponds, reservoirs, 19 wetlands, or other surface-water bodies as part of the transmission line upgrades. It also 20 reflects TVAs commitment to implement construction BMPs to prevent sedimentation of 21 waterbodies near areas where work is performed. It also reflects the fact that any work 22 conducted as part of the upgrades would be brief, not involve any widespread grading, and 23 employ construction BMPs to prevent or minimize sedimentation and erosion.

24 TVAs identification of transmission line segments for upgrades is strictly conceptual at this point 25 in time. At the COL or CP stage, TVA or another applicant, would be able to accurately assess 26 the need for transmission line upgrades necessitated by the project and identify specific 27 locations for work required as part of the upgrades. Any subsequent BA prepared as part of a 28 review of a future COL or CP application for the CRN Site would examine any information 29 contained in the future application that may be inconsistent with any of the review teams 30 assumptions at this time. The subsequent BA would also be prepared at a time when TVA has 31 clearer information about exactly where work would have to be performed.

32 M.10 References 33 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 34 Production and Utilization Facilities." Washington, D.C. TN249.

35 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 36 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

37 Washington, D.C. TN250.

38 10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, "Licenses, 39 Certifications, and Approvals for Nuclear Power Plants." Washington, D.C. TN251.

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1 40 CFR Part 125. Code of Federal Regulations, Title 40, Protection of Environment, Part 125, 2 "Criteria and Standards for the National Pollutant Discharge Elimination System." Washington, 3 D.C. TN254.

4 32 FR 4001. March 11, 1967. "Native Fish and Wildlife; Endangered Species." Federal 5 Register, Fish and Wildlife Service, Washington, D.C. TN2750.

6 41 FR 24062. June 14, 1976. Endangered Status for 159 Taxa of Animals. Federal Register, 7 Department of the Interior, Washington, D.C. TN5173.

8 41 FR 41914. September 24, 1976. "Determination of Critical Habitat for American Crocodile, 9 California Condor, Indiana Bat, and Florida Manatee." Federal Register, Fish and Wildlife 10 Service, Washington, D.C. TN275.

11 42 FR 45526. September 9, 1977. "Final Threatened Status and Critical Habitat for Five 12 Species of Southeastern Fishes." Federal Register, Fish and Wildlife Service, Washington, 13 D.C. TN5178.

14 42 FR 47840. September 22, 1977. "Endangered and Threatened Wildlife and Plants:

15 Correction and Augmentation of Public Rulemaking on Critical Habitats." Federal Register, Fish 16 and Wildlife Service, Washington, D.C. TN5355.

17 43 FR 28932. July 3, 1978. "Determination that Seven Eastern U.S. Land Snails are 18 Endangered or Threatened Species." Federal Register, Fish and Wildlife Service, Washington, 19 D.C. TN5374.

20 66 FR 35547. July 6, 2001. "Endangered and Threatened Wildlife and Plants; Designation of 21 Critical Habitat for the Spruce-fir Moss Spider." Federal Register, Fish and Wildlife Service, 22 Washington, D.C. TN5381.

23 66 FR 65256. December 18, 2001. "National Pollutant Discharge Elimination System:

24 Regulations Addressing Cooling Water Intake Structures for New Facilities." Federal Register, 25 Environmental Protection Agency, Washington, D.C. TN243.

26 72 FR 57416. October 9, 2007. "Limited Work Authorizations for Nuclear Power Plants."

27 Federal Register, Nuclear Regulatory Commission, Washington, D.C. TN260.

28 76 FR 38095. June 29, 2011. "Endangered and Threatened Wildlife and Plants; 90-Day 29 Finding on a Petition to List the Eastern Small-Footed Myotis and the Northern Long-Eared Bat 30 as Threatened or Endangered." Federal Register, Fish and Wildlife Service, Washington, D.C.

31 TN1798.

32 77 FR 14914. March 13, 2012. Endangered and Threatened Wildlife and Plants; 33 Determination of Endangered Status for the Sheepnose and Spectaclecase Mussels 34 Throughout Their Range, Final Rule. Federal Register, Department of the Interior, 35 Washington, D.C. TN5177.

36 78 FR 61046. October 2, 2013. "Endangered and Threatened Wildlife and Plants; 12-Month 37 Finding on a Petition To List the Eastern Small-Footed Bat and the Northern Long-Eared Bat as 38 Endangered or Threatened Species; Listing the Northern Long-Eared Bat as an Endangered 39 Species." Federal Register, Fish and Wildlife Service, Washington, D.C. TN3207.

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1 80 FR 17974. April 2, 2015. "Endangered and Threatened Wildlife and Plants; Threatened 2 Species Status for the Northern Long-Eared Bat With 4(d) RuleFinal Rule and Interim Rule 3 with Request for Comments." Federal Register, Fish and Wildlife Service, Washington, D.C.

4 TN4216.

5 81 FR 62826. September 13, 2016. "Endangered and Threatened Wildlife and Plants; 6 Threatened Species Status for Platanthera integrilabia (White Fringeless Orchid)." Federal 7 Register, Fish and Wildlife Service, Washington, D.C. TN5378.

8 82 FR 60362. December 20, 2017. "Endangered and Threatened Wildlife and Plants; 90-Day 9 Findings for Five Species." Federal Register, Fish and Wildlife Service, Washington, D.C.

10 TN5416.

11 80 Stat. 926. 1966. Endangered Species Preservation Act of 1966. Public Law 89-669.

12 TN5344.

13 16 U.S.C. § 1531 et seq. Endangered Species Act of 1973. TN1010.

14 Baranski, M.J. 2011. Aquatic Natural Areas Analysis and Evaluation Oak Ridge Reservation.

15 ORNL/TM-2011/13, Oak Ridge National Laboratory, Oak Ridge, Tennessee. Accession No.

16 ML18019A939. TN5164.

17 BRC (Breeder Reactor Corporation). 1985. The Clinch River Breeder Reactor Plant Project.

18 Final Report, Oak Ridge, Tennessee. Accession No. ML18064A893. TN5245.

19 CBD (Center for Biological Diversity) and DoW (Defenders of Wildlife). 2016. Petition to list the 20 Tricolored Bat Perimyotis subflavus as Threatened or Endangered under the Endangered 21 Species Act. Tucson, Arizona and Washington, D.C. Accession No. ML18019A110. TN5360.

22 Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetlands and 23 Deepwater Habitats of the United States. FWS/OBS-79/31, Fish and Wildlife Service, 24 Washington, D.C. Accession No. ML18019A904. TN5186.

25 Cox, P.B., A.J. Dattilo, and J.T. Baxter, Jr. 2015. Clinch River Small Modular Reactor Site 26 Terrestrial Plant Communities and Botanical Resources Survey Report. Revision 5, Tennessee 27 Valley Authority, Knoxville, Tennessee. Accession No. ML17334A049. TN5193.

28 Currie, R.R. 1993. Recovery Plan for American Hart's-Tongue (Asplenium scolopendrium var.

29 americanum). Southeast Region, U.S. Fish and Wildlife Service, Atlanta, Georgia. Accession 30 No. ML18019A907. TN5306.

31 DOE (U.S. Department of Energy). 1984. Clinch River Breeder Reactor Plant Project Site 32 Redress Plan. Washington, D.C. Accession No. ML18065A004. TN5282.

33 DOE (U.S. Department of Energy). 2017. Oak Ridge Reservation Annual Site Environmental 34 Report 2016. DOE/ORO/251, Oak Ridge, Tennessee. Accession No. ML18019B167. TN5081.

35 DOE (U.S. Department of Energy), TVA (Tennessee Valley Authority), and PMC (Project 36 Management Corporation). 1984. Clinch River Breeder Reactor Plant Site Redress Planning 37 Task Force Report. Washington, D.C., Knoxville Tennessee, and Oak Ridge, Tennessee.

38 Accession No. ML17334A059. TN5221.

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1 EPA (U.S. Environmental Protection Agency). 2004. "Level III and IV Ecoregions of EPA 2 Region 4." Washington, D.C. Accession No. ML18023A339. TN5158.

3 EPA (U.S. Environmental Protection Agency). 2013. "Level III and IV Ecoregions of the 4 Continental United States." Washington, D.C. Accession No. ML18023A341. TN5033.

5 Etnier, D.A. and W.C. Starnes. 1993. The Fishes of Tennessee. University of Tennessee 6 Press, Knoxville, Tennessee. Accessed October 11, 2017, at 7 http://trace.tennessee.edu/utk_utpress/2/. TN5054.

8 FWS (U.S. Fish and Wildlife Service). 1982. Gray Bat Recovery Plan. FWS Reference 9 Service, Denver, Colorado. Accession No. ML18023A169. TN929.

10 FWS (U.S. Fish and Wildlife Service). 1997. "Threatened and Endangered Species, Gray Bat 11 (Myotis grisescens)." Washington, D.C. Accession No. ML18023A170. TN5194.

12 FWS (U.S. Fish and Wildlife Service). 2005. Biological Opinion on the Impacts of the Laxare 13 East & Black Castle Contour Coal Mining Projects on the Indiana Bat. West Virginia Field 14 Office, Elkins, West Virginia. Accession No. ML18059A111. TN5382.

15 FWS (U.S. Fish and Wildlife Service). 2006. "Threatened and Endangered Species: Indiana 16 Bat (Myotis sodalis)." Fort Snelling, Minnesota. Accession No. ML15043A589. TN4167.

17 FWS (U.S. Fish and Wildlife Service). 2007. Indiana Bat (Myotis sodalis) Draft Recovery Plan:

18 First Revision. Great Lakes-Big Rivers Region, Fort Snelling, Minnesota. Accession No.

19 ML14302A612. TN934.

20 FWS (U.S. Fish and Wildlife Service). 2009. Gray Bat (Myotis grisescens) 5-Year Review:

21 Summary and Evaluation. Midwest Region, Columbia, Missouri. Accession No. ML18023A172.

22 TN5330.

23 FWS (U.S. Fish and Wildlife Service). 2009. Indiana Bat (Myotis sodalis) 5-Year Review:

24 Summary and Evaluation. Midwest Region, Region 3, Bloomington, Indiana. Accession No.

25 ML18059A112. TN5356.

26 FWS (U.S. Fish and Wildlife Service). 2014. Northern Long-Eared Bat Interim Conference and 27 Planning Guidance, USFWS Regions 2, 3, 4, 5, & 6. Bloomington, Minnesota. Accession No.

28 ML15043A596. TN4162.

29 FWS (U.S. Fish and Wildlife Service). 2015. "Prices Potato-bean (Apios priceana). Midwest 30 Region, Bloomington, Minnesota. Accession No. ML18059A113. TN5375.

31 FWS (U.S. Fish and Wildlife Service). 2015. "Section 7 Technical Assistance: Summary of 32 Indiana Bat Ecology." Midwest Region, Bloomington, Minnesota. Accession No.

33 ML18023A175. TN5312.

34 FWS (U.S. Fish and Wildlife Service). 2015. Zebra Mussel (Dreissena polymorpha) Ecological 35 Risk Screening Summary. Washington, D.C. Accession No. ML18023A174. TN5218.

M-119

1 FWS (U.S. Fish and Wildlife Service). 2017. Biological Opinion: Office of Surface Mining and 2 Enforcement Approval of Surface Mining at Kopper Glo Mining, LLC, Cooper Ridge Surface 3 Mine, OSMRR Permit Number 3370, Claiborne County, Tennessee. FWS Tennessee 4 Ecological Field Services Office, Cookeville, Tennessee. Accession No. ML18059A114.

5 TN5346.

6 FWS (U.S. Fish and Wildlife Service). 2017. "Fact Sheet: Rusty Patched Bumble Bee."

7 Midwest Region, Bloomington, Minnesota. Accession No. ML18059A119. TN5376.

8 FWS (U.S. Fish and Wildlife Service). 2017. "IPaC Information for Planning and Consultation."

9 ECOS - Environmental Conservation Online System, Fort Collins, Colorado. Accession No.

10 ML18023A181. TN5328.

11 FWS (U.S. Fish and Wildlife Service). 2017. Letter from M.E. Jennings to NRC, dated May 5, 12 2017, regarding "FWS# 2017-I-473. U.S. Nuclear Regulatory Commission - Requests for 13 Participation in the Environmental Scoping Process and a List of Federally Protected Species 14 Within the Area Under Evaluation for the Proposed Clinch River Nuclear Site Located in Oak 15 Ridge, Roane County, Tennessee." Cookeville, Tennessee. Accession No. ML17205A341.

16 TN5090.

17 FWS (U.S. Fish and Wildlife Service). 2017. Letter from M.E. Jennings to NRC, dated July 20, 18 2017, regarding "FWS# 2017-I-473. U.S. Nuclear Regulatory Commission (NRC) - Updated 19 List of Federally Threatened and Endangered Species that Potentially Occur near the Proposed 20 Clinch River Small Modular Nuclear Reactor Facility in Oak Ridge, Roane County, Tennessee."

21 Cookeville, Tennessee. Accession No. ML17205A342. TN5091.

22 FWS (U.S. Fish and Wildlife Service). 2017. "National Wetlands Inventory: Wetlands Mapper."

23 Madison, Wisconsin. Available at https://www.fws.gov/wetlands/data/mapper.html. TN5327.

24 FWS (U.S. Fish and Wildlife Service). 2017. "Species Profile for Hellbender (Cryptobranchus 25 alleganiensis)." ECOS-Environmental Conservation Online System, Fort Collins, Colorado.

26 Accession No. ML18059A116. TN5365.

27 FWS (U.S. Fish and Wildlife Service). 2017. "Species Profile for Indiana Bat (Myotis sodalis).

28 ECOS-Environmental Conservation Online System, Fort Collins, Colorado. Accession No.

29 ML18059A115. TN5357.

30 FWS (U.S. Fish and Wildlife Service). 2017. "Species Profile for Morefield's Leather Flower 31 (Clematis morefieldii). ECOS-Environmental Conservation Online System, Fort Collins, 32 Colorado. Accession No. ML18059A120. TN5411.

33 FWS (U.S. Fish and Wildlife Service). 2017. "Species Profile for Pink Mucket (Pearlymussel) 34 (Lampsilis abrupta)." ECOS-Environmental Conservation Online System, Fort Collins, 35 Colorado. Accession No. ML18059A117. TN5370.

36 FWS (U.S. Fish and Wildlife Service). 2017. "Species Profile for Sheepnose Mussel 37 (Plethobasus cyphyus)." ECOS-Environmental Conservation Online System, Fort Collins, 38 Colorado. Accession No. ML18059A118. TN5371.

39 FWS (U.S. Fish and Wildlife Service). 2017. "Species Profile for Spotfin Chub (Eriminax 40 monachus)." Washington, D.C. Accession No. ML18023A178. TN5219.

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1 FWS (U.S. Fish and Wildlife Service) and NMFS (National Marine Fisheries Service). 1998.

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4 GDNR (Georgia Department of Natural Resources). 2017. Email from A. Yellin to J. Becker, 5 PNNL, dated September 24, 2017, regarding "Environmental Review for Georgia Portion of the 6 Proposed Transmission Line." Atlanta, Georgia. Accession No. ML18012A441. TN5397.

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20 Humphries, W.J. and T.K. Pauley. 2004. "Life History of the Hellbender, Cryptobranchus 21 alleganiensis, in a West Virginia Stream." American Midland Naturalist 154:135-142, Notre 22 Dame, Indiana. TN5363.

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34 Kunz, T.D. and J.D. Reichard. 2010. Status Review of the Little Brown Myotis (Myotis 35 lucifugus) and Determination that Immediate Listing under the Endangered Species Act is 36 Scientifically and Legally Warranted. Boston University's Center for Ecology and Conservation 37 Biology, Boston, Massachusetts. Accessed January 12, 2018, at 38 https://www.bu.edu/cecb/files/2010/12/Final-Status-Review.pdf. TN5373.

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13 McKerrow, A. 1996. Recovery Plan for Cumberland Sandwort (Arenaria cumberlandensis).

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25 Middleton, G. 2016. Acoustic Monitoring of Bats on the ORR 2015 (Draft). Tennessee 26 Department of Environment & Conservation, Oak Ridge, Tennessee. Accession No.

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31 Murdock, N.A. 1993. Recovery Plan for Spreading Avens (Guem radiatum). U.S. Fish and 32 Wildlife Service Southeast Region, Atlanta Georgia. Accession No. ML18059A123. TN5377.

33 Murdock, N.A. and K. Langdon. 1997. Recovery Plan for Rock Gnome Lichen (Gymnoderma 34 lineare) (Evans) Yoshimura and Sharp. U.S. Fish and Wildlife Service Southeast Region, 35 Atlanta, Georgia. Accession No. ML18059A122. TN5380.

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9 Norquist, C. 1994. Morefields Leather Flower Clematis morefleidii Recovery Plan. U.S. Fish 10 and Wildlife Service, Jackson, Mississippi. Accession No. ML18059A124. TN939.

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20 2, Washington, D.C. Accession Nos. ML13144A092, ML13144A093. TN5165.

21 NRC (U.S. Nuclear Regulatory Commission). 2017. Letter from A.H. Fetter to U.S. Fish and 22 Wildlife Service, dated April 20, 2017, regarding "Request for Participation in the Environmental 23 Scoping Process and a List of Protected Species Within the Area Under Evaluation for the 24 Proposed Clinch River Nuclear Site Early Site Permit Application Review." Washington, D.C.

25 Accession No. ML17069A249. TN5089.

26 NRC (U.S. Nuclear Regulatory Commission). 2018. Clinch River Nuclear Site Early Site Permit 27 Application Environmental Audit Summary Report. Washington, D.C. Accession No.

28 ML17226A020. TN5386.

29 Ogle, D.W. 1992. Virginia Spiraea (Spiraea virginiana Britton) Recovery Plan. U.S. Fish and 30 Wildlife Service Region Five, Newton Corner, Massachusetts. Accession No. ML18059A125.

31 TN5379.

32 ORNL (Oak Ridge National Laboratory). 2017. Email from K. McCracken to J. Becker, PNNL, 33 dated September 18, 2017, regarding "Fish Population Data for Ish Creek." Oak Ridge, 34 Tennessee. Accession No. ML18016A334. TN5358.

35 OSMRE (Office of Surface Mining Reclamation and Enforcement). 2017. "ARblast: All 36 Resources on Blasting. Rules, Regulations, Research, and Resources." Washington, D.C.

37 Accession No. ML18059A126. TN5353.

38 Parmalee, P.W. and A.E. Bogan. 1998. Freshwater Mussels of Tennessee. University of 39 Tennessee Press, Knoxville, Tennessee. Accession No. ML042800060. TN5166.

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4 Accession No. ML18023A329. TN5151.

5 Pilarski-Hall, K. 2015. Clinch River Small Modular Reactor Site: Technical Report Natural 6 Areas (Managed Areas & Sites). Revision 2, Tennessee Valley Authority, Knoxville, 7 Tennessee. Accession No. ML17334A050. TN5185.

8 Pilarski-Hall, K. and B.P. Lees. 2015. Clinch River Small Modular Reactor Site Wetland Survey 9 Report. Revision 4, Tennessee Valley Authority, Knoxville, Tennessee. Accession No.

10 ML18036A352. TN5299.

11 Pilarski-Hall, K. and R.A. Kennon. 2015. Clinch River Small Modular Reactor Site 12 Supplemental Wetland Survey Report Barge/Traffic Area. Revision 1, Tennessee Valley 13 Authority, Knoxville, Tennessee. Accession No. ML18036A351. TN5290.

14 PNNL (Pacific Northwest National Laboratory). 2017. Summary of Notes from Telephone 15 Conference Call with U.S. Fish and Wildlife Service on October 24, 2017 with Additional Notes 16 from Dustin Boles, FWS, Telephone Call to Jim Becker, PNNL, on October 23, 2017. Richland, 17 Washington. Accession No. ML18040A429. TN5384.

18 Rakes, P.L., J.R. Shute, and P.W. Shute. 1999. "Reproductive Behavior, Captive Breeding, 19 and Restoration Ecology of Endangered Fishes." Environmental Biology of Fishes 55:31-42, 20 Netherlands. TN5367.

21 Shea, A.B. and T.H. Roulston. 1996. Recovery Plan for Cumberland Rosemary (Conradina 22 verticillata). Southeast Region, U.S. Fish and Wildlife Service, Atlanta, Georgia. Accession No.

23 ML18023A336. TN5303.

24 Shute, J.R., P.L. Rakes, and P.W. Shute. 2005. "Reintroduction of Four Imperiled Fishes in 25 Abrams Creek, Tennessee." Southeastern Naturalist 4(1):93-110, Steuben, Maine. TN5366.

26 TDEC (Tennessee Department of Environment & Conservation). 2014. Environmental 27 Monitoring Report, January through December 2013. Nashville, Tennessee. Accession No.

28 ML18023A358. TN5288.

29 TDEC (Tennessee Department of Environment & Conservation). 2016. "Contaminants in Fish."

30 Knoxville, Tennessee. Accession No. ML18023A307. TN5172.

31 TDEC (Tennessee Department of Environment & Conservation). 2016. Environmental 32 Monitoring Report 2015. Nashville, Tennessee. Accession No. ML18059A132. TN5350.

33 TDEC (Tennessee Department of Environment & Conservation). 2017. "Rare Species by 34 County, Roane County." Nashville, Tennessee. Accession No. ML18023A318. TN5217.

35 TNBWG (Tennessee Bat Working Group). 2017. "Gray Bat." Nashville, Tennessee.

36 Accession No. ML18026A607. TN5329.

37 TNBWG (Tennessee Bat Working Group). 2017. "Tri-Colored Bat." Nashville, Tennessee.

38 Accession No. ML18059A137. TN5359.

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1 TNC (The Nature Conservancy). 2003. The Cumberlands and Southern Ridge & Valley 2 Ecoregion: A Plan for Biodiversity Conservation. Arlington, Virginia. Available at 3 https://www.conservationgateway.org/ConservationPlanning/SettingPriorities/EcoregionalReport 4 s/Documents/CSRVPlan.pdf. TN5036.

5 TNHP (Tennessee Natural Heritage Program). 2017. Email from S. Williams to J. Becker, 6 PNNL, dated September 11, 2017, regarding "Map Package for TN NHP." Nashville, 7 Tennessee. Accession No. ML18026A552. TN5361.

8 TNSOS (Tennessee Secretary of State). 2017. "Effective Rules and Regulations of the State of 9 Tennessee: 0400 Rules of the Tennessee Department of Environment and Conservation, 10 Division of Water Resources Water Pollution Control." Nashville, Tennessee. Accessed 11 January 23, 2017, at http://share.tn.gov/sos/rules/0400/0400-40/0400-40.htm. TN5071.

12 TRC (ThirdRock Consultants, LLC). 2010. Mollusk Survey of the Tennessee River Near Watts 13 Bar Nuclear Plant (Rhea County, Tennessee). Lexington, Kentucky, Accession No.

14 ML18026A610. TN5175.

15 TRC (ThirdRock Consultants, LLC). 2011. Evaluation of Freshwater Mollusk and Habitat, 16 Clinch River, CRM 15.0 - 19.0, Roane County, Tennessee. Lexington, Kentucky. Accession 17 No. ML17334A055. TN5168.

18 Tucci, P. 1992. Hydrology of Melton Valley at Oak Ridge National Laboratory, Tennessee.

19 Water-Resources Investigations Report 92-4131, U.S. Geological Survey, Nashville, 20 Tennessee. Accession No. ML18026A611. TN5034.

21 TVA (Tennessee Valley Authority). 2012. A Guide for Environmental Protection and Best 22 Management Practices for Tennessee Valley Authority Transmission Construction and 23 Maintenance Activities. Revision 2.1-2012, Chattanooga, Tennessee. Accession No.

24 ML18036A929. TN4911.

25 TVA (Tennessee Valley Authority). 2013. Biological Monitoring to Characterize the Aquatic 26 Community near the Site of the Proposed Clinch River Small Modular Reactor 2011.

27 Chattanooga, Tennessee. Accession No. ML17334A058. TN5167.

28 TVA (Tennessee Valley Authority). 2016. "Clinch River Nuclear Site Early Site Permit 29 Application, Part 02Site Safety Analysis Report (Revision 0)." Chattanooga, Tennessee.

30 Accession No. ML16144A074. TN5018.

31 TVA (Tennessee Valley Authority). 2016. Letter from J.W. Shea to NRC, dated May 12, 2016, 32 regarding "Application for Early Site Permit for Clinch River Nuclear Site." CNL-16-081, Oak 33 Ridge, Tennessee. Accession No. ML16139A752. TN5002.

34 TVA (Tennessee Valley Authority). 2016. Letter from J.W. Shea to NRC, dated December 13, 35 2016, regarding "Submittal of Supplemental Information Regarding Terrestrial Ecology in 36 Support of Early Site Permit Application for Clinch River Nuclear Site." CNL-16-200, 37 Chattanooga, Tennessee. Accession No. ML16348A552. TN5145.

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5 TVA (Tennessee Valley Authority). 2017. "Clinch River Nuclear Site Early Site Permit 6 Application, Part 03Environmental Report (Revision 1)." Chattanooga, Tennessee.

7 Accession No. ML18003A471. TN4921.

8 TVA (Tennessee Valley Authority). 2017. Letter from J.W. Shea to NRC, dated July 7, 2017, 9 regarding "Submittal of Supplemental Information Related to the Environmental Audit in Support 10 of Early Site Permit Application for Clinch River Nuclear Site." CNL-17-088, Chattanooga, 11 Tennessee. Accession No. ML17206A091. TN4920.

12 TVA (Tennessee Valley Authority). 2017. Letter from J.W. Shea to NRC, dated August 1, 13 2017, regarding "Submittal of Supplemental Information Related to the Environmental Audit in 14 Support of Early Site Permit Application for Clinch River Nuclear Site." CNL-17-097, 15 Chattanooga, Tennessee. Accession No. ML17234A003. TN4922.

16 TVA (Tennessee Valley Authority). 2017. Letter from J.W. Shea to NRC, dated September 5, 17 2017, regarding "Supplemental Information Related to Environmental Report Figures in Support 18 of Early Site Permit Application for Clinch River Nuclear Site." CNL-17-118, Chattanooga, 19 Tennessee. Accession No. ML17346B286. TN5226.

20 TWRA (Tennessee Wildlife Resources Agency). 2017. Email from B. Flock to J. Becker, 21 PNNL, dated November 3, 2017, regarding "Clinch River Small Modular Nuclear Reactor 22 Project." Nashville, Tennessee. Accession No. ML18064A895. TN5362.

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26 USACE (U.S. Army Corps of Engineers). 2010. Interim Regional Supplement to the Corps of 27 Engineers Wetland Delineation Manual: Eastern Mountains and Piedmont Region. ERDC/EL 28 TR-10-9, Engineer Research and Development Center, Vicksburg, Mississippi. Accession No.

29 ML18026B233. TN5325.

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34 Accession No. ML18026B253. TN5159.

35 USGS (U.S. Geological Survey). 2016. "Land Cover Trends Project: Ridge and Valley."

36 Denver, Colorado. Accession No. ML18026B254. TN5035.

37 von Oettingen, S.L. 1992. Small Whorled Pogonia (Isotria medeoloides) Recovery Plan.

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39 ML18026B260. TN5307.

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1 Williams, J.D., A.E. Bogan, and J.T. Garner. 2008. Freshwater Mussels of Alabama and the 2 Mobile Basin in Georgia, Mississippi, and Tennessee. University of Alabama Press, 3 Tuscaloosa, Alabama. TN5372.

4 Williams, J.D., M.L. Warren, Jr., K.S. Cummings, J.L. Harris, and R.J. Neves. 1993.

5 "Conservation Status of Freshwater Mussels of the United States and Canada." Fisheries 6 18(9):6-22, Abingdon, Oxford, England. TN5369.

7 Woods, A.J., J.M. Omernik, and D.D. Brown. 1999. Level III and Level IV Ecoregions of 8 Delaware, Maryland, Pennsylvania, Virginia, and West Virginia. U.S. Environmental Protection 9 Agency, Corvallis, Oregon. Accession No. ML083220457. TN1805.

10 Woods, A.J., J.M. Omernik, and D.D. Brown. 2003. "Map of Level III and Level IV Ecoregions 11 of EPA Region 3." U.S. Environmental Protection Agency, Corvallis, Oregon. Accession No.

12 ML14252A897. TN1806.

13 WSDOT (Washington State Department of Transportation). 2017. "Construction Noise Impact 14 Assessment." Chapter 7 in Biological Assessment Preparation for Transportation Projects -

15 Advanced Training Manual. Olympia, Washington. Accessed December 15, 2017, at 16 https://www.wsdot.wa.gov/Environment/Biology/BA/BAguidance.htm. TN5313.

17 M.11 List of Contributors Name Affiliation Credentials Role J. Peyton US Nuclear 30 Years of Experience in Wetland Delineation and Technical Doub Regulatory Mitigation, Forest Surveys, Species Surveys, Reviewer Commission, Ecological Risk Assessment, and NEPA Office of New Certified Environmental Professional (CEP)

Reactors Professional Wetland Scientist (PWS)

M.S., Plant Physiology, University of California at Davis, 1984 B.S., Plant Sciences, Cornell University, 1982 James PNNL 26 Years of Experience in Wildlife and Plant Terrestrial Becker Sciences, NEPA, ESA, Species Surveys, and Ecology Ecological Risk Assessment M.S. Wildlife Science, University of Washington, 1989 B.S. Botany and Range Science, Brigham Young University, 1987 Rebekah PNNL 15 years of experience as an aquatic ecologist with Aquatic Krieg 20 years of NEPA experience in Aquatic Ecology. Ecology M.S. in Fisheries and Oceanographic Science from the University of Washington, BS in Biology from Washington State University.

Stephanie PNNL 8 years of Experience in Fisheries and Aquatic Aquatic and Liss Ecology, with 3 years of NEPA Experience in Aquatic Terrestrial and Terrestrial Ecology, Noise, and Human Health Ecology And Safety.

M.Sc. Natural Resources and Environmental Sciences, University of Illinois at Urbana-Champaign, 2013.

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Name Affiliation Credentials Role B.Sc. Natural Resources and Environmental Sciences, University of Illinois at Urbana-Champaign, 2010.

Joanne PNNL 8 Years SharePoint Reference Database Technical Duncan Administrator and Document Bibliography Editing Coordinator/Manager B.A., Biology, Hood College, 1979 Cary PNNL 45 Years of Experience at PNNL in Research, Technical Counts Contracts, and Technical Communications Editing B.S., Ceramic Engineering, Clemson University, 1964 M.S., Environmental Systems Engineering, Clemson University, 1972.

1 M-128

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (12-2010) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, if any.)

BIBLIOGRAPHIC DATA SHEET NUREG-2226 (See instructions on the reverse) Volume 2 Draft

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED Environmental Impact Statement for an Early Site Permit (ESP) at the Clinch River Nuclear Site MONTH YEAR Draft Report for Comment April 2018

4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT See Appendix A Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address; if contractor, provide name and mailing address.)

Division of New Reactor Licensing Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address.)

Same as above

10. SUPPLEMENTARY NOTES Docket 52-047

11. ABSTRACT (200 words or less)

This environmental impact statement (EIS) has been prepared in response to an application to the U.S. Nuclear Regulatory Commission (NRC) by Tennessee Valley Authority (TVA) for an early site permit (ESP). The U.S. Army Corps of Engineers (USACE) is a cooperating agency on this EIS. This EIS includes the analysis by the NRC and USACE staff, which considers and weighs the environmental impacts of building, operating and decommissioning two or more SMRs at the CRN Site.

After considering the environmental impacts of the proposed NRC action, the NRC staff's preliminary recommendation to the Commission is that the ESP be issued as requested. The recommendation is based on (1) the application and supplemental information submitted by TVA, including Revision 1 of the Environmental Report (ER); (2) consultation with Federal, State, Tribal and local agencies; (3) the staff's independent review; (4) the staff's consideration of comments related to the environmental review that were received during the public scoping process; and (5) the assessments summarized in the EIS, including the potential mitigation measures identified in the ER and this EIS.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT Clinch River Nuclear Site Early Site Permit unlimited Clinch River Nuclear Site Environmental Review 14. SECURITY CLASSIFICATION Clinch River Nuclear Small Modular Reactor Project (This Page)

Draft Environmental Impact Statement, DEIS unclassified National Environmental Policy Act, NEPA (This Report)

NUREG-2226 unclassified

15. NUMBER OF PAGES

16. PRICE NRC FORM 335 (12-2010)

NUREG-2226, Vol 2 Environmental Impact Statement for an Early Site Permit (ESP) at the Clinch River Nuclear Site April 2018 Draft Report for Comment

ML18100A223

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SUMMARY

1.0 INTRODUCTION

10.0 CONCLUSION

11.0 REFERENCES

SUMMARY

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