ML19346E417

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NRC-2019-000246 - Resp 2 - Final, Agency Records Subject to the Request Are Enclosed. Part 5 of 19
ML19346E417
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Issue date: 12/05/2019
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NRC-2019-000246, FOIA
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ATIACHMENT 5 TO HOLTEC LETTER 5025040 ENVIRONMENTAL REPORT on The HI-STORE CIS FACILITY by Holtec International Holtec Center One Holtec Drive Marlton, NJ 08053, USA (holtecinternational.com)

USNRC Docket# 72-1051 Holtec Project 5025 Holtec Report# HI-2167521 January 2019 CE OF PROPRIETARY & COPYRIGHTED ST This document is a copyng

  • tellectual properly of Holte national. All rights reserved.

Proprietary information in this documen * *

  • hi* y gray shading. Excerpting any part of thi document, except for public doc *
  • tton inc erein, by any per on or entity except the USNRC, a Holtec roup (HUG) member company, or a
  • n regulatory authority with jw-isd *
  • over a Holtec client's nuclear facility is unlawful without wr* nsent of oltec International 1 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Table of Content Summary of Revisions:

Revision 0: Initial Issue Revi ion 1: Revi ed to include re pone to NRC RSI . All above change and editorial changes are shown by revision bars in the right margin.

Revision 2: Added appendices F and G for "data call' references.

Revision 3: Revised to include respon es to NRC RAis. All chang sand editorial changes are shown by revi ion bars in th right margin.

Revision 4: Revised Section 4.11 to include annual and total volume e timates for low-level radioactive waste and nonhazardou olid wa tes.

HOLTEC INTERNATIONAL COPYR[GHTED MATERIAL HI-2167521 I Rev. 4 Page ii of xrn 2 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Faci lity Environmental Report Table of Content TABLE OF CONTENTS SECTION Table of Contents ... .... .. ...... .... ...... ... ... .... ...... ... .. ....... .... ...... .. ... ..... ........... ...... .......... ........ .... ...... iii Acronyms and Abbreviation ....... ... ... ..... ....... .. .............. .. .. ........................ ..... ... ... ..... ..... .. .. .... viii Conversion Chart ....... .. ...... .... ... ... ....... .......... ...... ... ............. ..... ..... ...... ....... .......... ....... .... .. .. ..... xii CHAPTER 1: INTRODUCTION 1.0 Introduction ...................................................................................................................... 1 1.1 History and Background ....................................... ...... ................................................. ...... 4 1.2 Purpose and Need for the Propo, ed Action ... ...... ...... ...... ...... ..... ...... ...... ...... .... ...... .... ...... ..6 1.3 The Propos d Action ......................................................................................................... 7 1.4 Applicable Regulatory Requirements, Permits, and Required Consultations .................... 11 1.4.1 United States Gove111ment .................................................................................... 1J 1.4.2 State of New Mexico ..... ...... .......... ...... ..... ........... ...... ........................... ....... ... .. .... 13 CHAPTER 2: ALTERNATIVES 2.0 Introduction ...................................................................................................................... 1 2.1 No Action Alternative ..... .......... ...... ......................................................... ........ ................. 1 2.2 Pro po ed A.ct ion .. ......................... ............. .... ..... ..... ......... .................. ........ .... .. ...... .. ......... 3 2.2.1 Description of the Proposed Site ............................................................................ 3 2.2.2 De cription of the Facility .............................. ... ....... ................ .... .............. ... ........ .4 2.3 Site Selection Proces ..................................................................................................... 14 2.4 Alternatives Considered but El iminated ... .. .... .... ...... .... .. ....... .... ...... .... .... .. ..... ....... .......... 17 2.4.1 Design Alternative ................................ ..... ............ ................................................. 17 2.4.2 Location Alt rnatives ............................................................................................. 17 2.4.3 CTSF Layout Alternatives ..................................... ...... .......... ...... ............... ......... .. .. 18 2.5 Summary Comparison of the Environmental impacts of the Alternatives ......................... 19 CHAPTER 3: AFFECTED ENVIRONMENT 3.0 Introduction .................................................................................................................. 1 3.1 Land Use ...................................................................................................................... 1 3.1.1 Onsite Land U e ................................... ................................................................. 1 3.1.2 Surrounding Land Use .. ..... ... .... .. .......... ..................................... ............................ 2 3.2 Visual and Scenic Resources ......... ........................ ............... .......................... ...... ....... .7 3.2. J Scenic Quality ........................................ ... ............................................................ 8 3.2.2 Sen itivity Level Analysis ...... ........... ..... ....... ..... ..... ..... ...... ..... ........... ..... ........... ... 8 3.2.3 Delineation of Distance Zones ...... ...... ............ .... ... .... .... ...... ...... ...... .... ........ ...... ....8 3.2.4 Visual R source Management Cla ses ................................................................... 8 3.3 Geology and Soil ... .. ...... ............ ... ............ .... ............ ........... ...... ..... ........... ....... .. .. ..... 11 3.3. l Regional and Site Specific Geo logy .... .. ............ .......... .. ... ... ... .. .............. .............. 11 3.3.2 Seismic Information ..... ...... .... ...... ...... ...... .... ...... .... ........ .... .... .. ......... ........ .... ...... 13 3.3.3 Salt Di olution and Sink Holes ..... ........ ... ... ... ... ........ ... ......... .... .... ... .......... .... ..... 14 HOLTEC INTERNATIONAL COPYR[GHT ED MAT ERIAL HI-2167521 I Rev. 4 Page ii of xrn 3 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Faci lity Environmental Report Table of Content 3.3.4 So ils .................................................................................................................... 15 3 .4 Ecological Resources ............... ............. ........ ........ ............... .... .................... .. ............. 24 3 .4.1 Ecological Sy tetn ............................... ............ .... ............ .......... ......... .. ...... .... .. .. 24 3.4.2 Vegetation ...... ..... ............ ...... ... .............. .... ...... ... .. ... .... .. .. ....... ............... ...... ... .. ..26 3.4.3 Wildlife ..... .... ..... .... ... ... ...... .... ... .. ....... .... ... ... .. .. .. .... ...... ....... ...... .. ........ ... .. ..... .... .. 28 3.4.4 Aquatic Sy terns ... ..... ... ... ............................. ..... .... .......... .. ... ................ ... .... .. ...... 29 3.4.5 Recent Ecological Survey .. ......... ... ... ......... ...... ... ... ......... .... ....... .. .. ...... ................ 30 3.5 Water Resources ... ........... .. .. ..... ....... .. ... .... .. .......................................... ............... ... .... 38 3.5.1 Surface Water Resources ...... ... .... ...... .. .................... .......... ... .... .......... .. .. ......... .. .. 38 3.5.2 Groundwater.. .............. .... ...... ... ........................................................................... 39 3.5.3 Wetlands .................. ..... .. ........ .. .... .. ......... ...... ........... ..... .. ......... ...... ................ .... 41 3.5.4 Floodplains .... .... ... ...... .. ..... ...... ... ....... ............ ..... ...... .. ... ...... ..... ... .......... ...... ... .... .41 3.6 Climatology, Meteorology, Air Quality, and Noise ........ .... .. .. .... .. .. .... .. ..... .. .. .. .... ....... .49 3.6.1 Regional Climatology and Meteorology .. ................... ....... ........ ........ ....... ... ..... ... 49 3.6.2 Air Quality .... ..................................................................................... ... .............. 51 3.6.3 No i e .. ...... .. ... ......... ........ ........ .... .. .. ........ ...... ..... ...... .... ...... ...... .... .. ............. .. ... .... 53 3.7 Cu ltura l Re ource ................. .......... .. .. ..... ... ...... .... .. .. ............. .......... .. ... ....... ... ... .. .... .. 72

3. 7 .1 Background ... ......... ..... .. ... ...... ... ............. ... ....... .... ....... .... ... .. ... .... ....... .. ... ........... . 72 3.7.2 Cultural Setting .. ........ ..... ... .... .... ... ..... .. .. ................ .. ................ ....... .. .. ................ 72 3.7.3 Analyses ............................... ............................................................................... 73 3.7.4 Record Searcb .... .. ... .............. ........ ........ .............. .. ........... .. ... ..... .. ..... ... .. ..... ..... .. 73 3.7.5 Pedestrian Survey ................................................................................................ 73 3.7.6 Hi toric Propertie .......................................... ................ .... ... .... ................ .. ........ 74 3 .8 Socioecono1nics ......... ....... ... ... ... .... ... ......... .... .... .. ... ... ...... .. ... ........ ..... ......... ... ....... ... ... 82 3.8.1 Population Characteristics .. ............ ................ .... ....... .... ..... ....... .... .. ... ................. 82 3.8.2 Ho using Characteristics .... ...... .... ....... ....... ................... .. ........ ........ ...... .......... .... .. 83 3.8.3 Co1n1nunity baracteristic ...... ..... ..... ........................... ....... .............. .. ......... ....... 83 3.8.4 Economic Characteristics ............... ................................. ........ ......... .... .. ......... .. .. 84 3.8.5 Envirorunental Justice .......................................................................................... 85 3.9 Transpo11ation ...... .................................................................................................... 104 3.9 . .I Road ............ ........... .. ... ... .. ........ .............. ........ ................................................. 104 3.9.2 Railroads ....... .................................... ................................................................ 105 3 .10 Infrastructure .............................. ... ............................... ............................................ 107 3.10.1 Water ... .. ... ..... .... .. ................ .. .............. ............................ ................ ..... ...... .. .... 107 3.10.2 E lectricity ...... .... ... ... ... .. ..... ... .... ............ ...... .. ............... .. ..... ... .. .......................... 107 3 .11 Waste Manage1nent ....... ... .. .. .. ................................. ............... .................................. 108
3. L2 Public and Occupational Health and Safety .... ... ...... ..... ........ ..... ...... ..... .... ............... .. 108 3.12. l Radio logica l Exposure .... .... ............ ................. .. .. ......... ............ ......................... 109 3 .12.2 Public and Occupational Dose Limits ...... ...... ......... .. ...... ..... ..... ... ....... ......... ... ... 109 3.12.3 Health Effects Studies ... .. .... ....... ... ..... ......... ... ............. ... .......... ...... ................... 110 CHAPTER 4: ENVIRONMENTAL IMPACTS 4.0 Introduction .......... ..... .... .... ................ .. ...... .............. ..... .......... ...... .... .. .......... ... ... .......... 1 4.1 Land Use ... ... ... ..... .. ...... .. .. ........ ........ .. .. ... .... .. ... ............ .. ... .. ........... ... ... ................... ...... J HOLT EC INT ERNATIONAL COPYR[GHTED MAT ERIAL HI-2167521 I Rev. 4 Page iii of xiii 4 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Faci lity Environmental Report Table of Content 4.1.1 Construction (Phase I) ................ ........................................................................... 1 4.1.2 Concunent Operation and Additional Construction (Phases 2-20) .......................... 2

4. J.3 Operation .. ............................... ... .. ..... .... ..... ..... ..... ....... .... .. ... ... ... ......... .. ......... .. ... .. 2 4.1.4 Comparable NRC Land Use Analysi .................................................................... 3
4. L.5 Decontamination and Deco mm is ioning .... .. ..... .. .... ..... .... ... ..... .... ...... ........ .... .... ....3 4.2 Visual and Scenic Re ource ......................................................................................... 3 4.2.1 Con truction (Pha e 1) .. ............................................................... ... ....................... 3 4.2.2 Concurrent Operation and Additional Construction (Phases 2-20) ......................... .4 4.2.3 Operation .. ...... ..... ............. ... ... ... .... ... ..... ...... .... ..... ...... ................ ..................... ...... 4 4.2.4 omparable NRC Vi ual and Scenic R source Analysi ....................................... 5 4.2.5 Decontamination and Decommissioning ................................................................ 5 4.3 Geo logy and Soils .... ...... ...... .... ...... ....... ... ...... ...... ...... ...... ..... ...... ...... ...... .... ...... .... ...... ..5 4.3.l Construction (Phase 1) .. .......... ...... .... ...... ....... .......... ...... .. ........ ...... ..... ... .... ...... ..... .5 4.3.2 Concurrent Operation and Additional Construction (Phases 2-20) .......................... 6 4.3.3 Operation ....... ......................................... ............................................................... 6 4.3.4 Comparable NRC Geology and Soils Analysis ..... .... ...... ...... .... ...... ...... ............ .... ..7 4.3.5 Decontamination and Decommi ioning ................................................................ 8 4.4 Ecological Resources ................................ ..... ...... .... .... ............. ...... .... ....... ................... 8 4.4.1 Construction (Phase 1) ........................................................................................... 8 4.4.2 Concurrent Operation and Additional Construction (Pha es 2-20) .......................... 9 4.4.3 Operation .......................... ............. .... ..... ............................................................... 9 4.4.4 Threatened and Endangered Species ................. ................................................... 10 4.4.5 Con ultations with Agencies ......................... ............................ ............. .... .. .... .. .. 10 4.4.6 Comparable NRC Ecological Analy i ..................................... ............. ... ............ 10 4.4. 7 Decontamination and Decommissioning ....... ...... ...... .... ...... ... ........ ..... ....... .......... 10 4.5 Water Resources .................. ...................................... ................................................. 10 4.5.1 Con truction Impact (Pha e 1) .......... ... .. ................ .. .... ....... ............... ... ... ........... 11 4.5.2 Concurrent Operation and Additional Construction (Phases 2-20) ........................ 12 4.5.3 Operation ............................................................................................................. 12 4.5.4 Comparable NRC Infrastructure Analysis ............................................................ 13 4.5.5 Decontamination and Deco mm is ioning ... ........................................................... 13 4.6 Air Quality and oise .. ............. ... .... ......... .... .............. ..... .. ........ ... ............. ... .. ............ 14 4.6.1 Air Quality Iinpacts .............................................................................................. 14 4.6.2 Noise .... .. ....... ....... .. .............. .. .............. .. ...................... ....... .. .... ....... ... .. ...... .... .. .. l 7
4. 7 Cultural Resources .... ... .......... .......... ............ .......... ............... ............ .......................... 25
4. 7 .1 Construction .... ....... .... ..... ....... .... ............ .... .. ... ... ........... .. ..... ......................... .... .. 25 4.7 .2 Operations (Including Concurrent Operation and Construction) .............. ........... .. 26 4.7.3 Comparable NRC Cultural Analyse .................................................................... 26 4.7.4 Decontamination and Decommissioning ......... .... ... ... ...... .... ... ... ...... .. ... ........ ........26 4.7.5 Agency Consultation ............................................................................................ 26 4.8 Socioeconomic and Environmental Justice ............. ................ ........... ...................... ..27 4.8.1 Construction (Phase I) ..... ... .. .. ........ .... .. ....... .......... .. ..... ......... .. ...... ........ .......... .... 27 4.8.2 Concurrent Operation and Additional Construction (Pha es 2-20) .. ................ ...... 28 4.8.3 Operation .. ..... ....... .. .. .. ......................................................................................... 28 HOLTEC INTERNATIONAL COPYR[GHTED MAT ERIAL HI-2167521 I Rev. 4 Page iv of xiii 5 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Faci lity Environmental Report Table of Content 4.8.4 Envi.ron1nenta l Ju tice .......................................................................................... 29 4.8.5 Comparable NR Socioeconomics and Environmental Justice Analysis .. .......... .. 29 4.8.6 Decontamination and Decommi ioning ........ .. ..... ............ ....... ... ......... .. ...... .... .. .. 29 4.9 Transportation ............................................................................................................. 30 4.9.l Construction(Phase l) .. .... ...... ... .. ........... ... .... .... ..... ..... .. .... ...... .... ...... ........ .... ...... 30 4.9.2 Concurrent Operation and Additional Con truction (Pha e 2-20) ...................... 30 4.9.3 Operations ................... ............................... .............. ................... .. ...................... 31 4.9.4 Comparable NRC Transportation Analy e .. .... ... ...... .......... ... ... ... .. ..... .... ...... ... .. .. 34 4.9.5 Decontamination and Decommissioning ...... .... ..... ... .. ... ... ........... ..................... ... . 36 4.10 Infra tructure ........................................................................................................... 41 4.10.1 Construction (Phase J) ...... ......................... .. ..................................................... .... 41 4.10.2 Concurrent Operation and Additional Construction (Pha es 2-20) ....... ...... .... ..... .41 4.10.3 Operation .............................................. ............ ........... ................ ........................ 42 4.10.4 Comparable NRC Infrastructure Analysis .. .... .......... ... ............... .. .. ..... ....... .. .... .... 42 4.10.5 Decontamination and Decommissioning ............................................................. .42 4.11 Waste Management .... ........ ........ ........ .............. ...... ..................... ........ ................ ... .43 4.11.1 Construction (Pha e I) .......................... .............................................................. .43 4.11.2 Concurrent Operations and Additional Construction (Phases 2-20) ..................... .44 4.11.3 Operations ........................................................................................................... 44 4.11.4 Comparable NRC Waste Management Analyses .................... ................ ............. .45 4.11.5 Decontamination and Decommi ioning ............................................................. .45 4.12 Public and Occupational Health from Normal Operations .............................. .. ..... ...45 4.12.1 Non-Radiological Impact ............... ................ .. ......... ................ .. .............. ... ... .. ..46 4.12.2 Radiological Impacts from Normal Operations ....... ...... ......................... .. ......... .. ..48 4.12.3 Summary of Environmental Monitoring Program ....... .... ...... ...... .... ...... ...... .......... 51 4.12.4 Decontamination and Decommissioning .............................................................. 52 4 . .13 Off-Normal Operation and Accidents ... ...... ...... .... .... ... ........ ... ..... ........ ... ......... ... ... .57 4.13.1 Estimated Doses from Off-Normal Operations ..................................................... 57 4.13.2 Estinrnted Doses fromAccidents ...................... ................. ..... ..... ...... ..... .............. 57 4.13.3 Comparable Analyses .......................................................................................... 58 4.13.4 Decontamination and Deco mm is ioning .. ......... .. ...................... .......... ............ .... . 59 4.14 No Action Alternative Impacts ................................................................................ 59 CHAPTER 5: CUMULATIVE IMPACTS 5.0 Introduction ..... ................ .......... .......... ............ ....................................... .......................... 1 5.1 Current and Reasonably Foreseeable Actions .................................................................... 1 5.1. l Nuclear Activities in the Project Area ................................................................ .... 1 5.1.2 Non-Nuclear Activity in the Project Area ............................................................... 2 5.2 Potential Cumulative Impacts ... ...... .......... ...... ........ ...... ... ...... .... ... ... ...... ..... .. ... ........ ..........2 CHAPTER 6: MITIGATION MEASURES 6.0 Introduction ......... ............ ................................ .......... ..... .. .. ...... ........ .. .... .......... .......... ...... 1 6.1 Land U e ..... .................. .... ...... ...... ...... ...... .... ...... ... ...... ............ ............ ...... .................... .. l 6.2 Vi ual and Scenic Re ource .............. ... ... .. ..... .... .... ... ... ....... ... ... ...... ................................ J HOLTEC INTERNATIONAL COPYR[GHT ED MAT ERIAL HI-2167521 I Rev. 4 Page v of xiii 6 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Faci lity Environmental Report Table of Content 6.3 Geology and Soils ................. ................ ........................................................................... 2 6.4 Eco logical Resources ........................................................................................................ 2 6.5 Water Re ource .. ............................ ................ ................................. ................ ............ .. .. 3 6.6 Meteorology C limatology, Air Quality, and Noi e .... .. ...... .... ........................................... 3

6. 7 Cu ltural Resources .. ...... ................ .... ....... .. ... .... ...... .... .... ... ... .. .... ........ ... ...... .............. .. .... 4 6.8 Socioeconomics and Environmental Ju tice ............. ............................................... .. ....... .4 6.9 Transportation ... ....... ... .............. .. .............................................. .... ......... .. ...... .................. 5 6.10 Infrastructw*e ........................................... ... ......... .... ........ ........ ................. ... .......... .. ... ...... 5 6 .11 Waste Manage1nent ... ....... .............. ... ................... ........... ........... ................ ........... .. ... .. .... 5 6.12 Public and Occupational Health- Normal Operations ...................................................... 6 6.13 Off-Norma I Events and Accidents .................................................................................... 7 CHAPTER 7: MONITORING 7 .0 Introduction ...................................................................................................................... l 7.1 Regulatory Basis For Radiological Monitoring ................................................................ 1 7.2 Environmental Pathways .......... .... ............ .... .... ....... ... .. ...... ........................... ............ ...... 1 7.3 Radiological Environmental Monitoring Program ......................................................... ... 2 7.4 Compliance With Regulatory Requirements .................................................................... 3 7.5 Quality Assurance ........................................................................................................... 3 7.6 Reporting Procedure ...................................................................................................... 4 7.7 Phy iochemical Monitoring ............................................ ....... ......... ... ...... ........................ 5 7.8 Ecological Monitoring ..................................................................................................... 5 CHAPTER 8:

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES 8.0 Introduction ....... ...... ...... .......... ....... ......... ... ............... .. .. ........... ...... .......... .. .... ................ .. l 8.1 Unavoidable Adverse Environmental Impacts ................................................................... 1 8.1 . l Land Use ............................................................................................................... 1

8. 1.2 Visual and Scenic Resources ......... ... ................... .... ....... ... ............. ... ............. ....... . 1 8.1.3 Geology and Soils .................................................................................................. !

8.1.4 Ecological R . ource ............................................................................................. l 8.1.5 Water Resource .................................................................................................... 2

8. l .6 Meteorology, Climatology, Air Quality, and Noise ................................................ 2 8.1.7 Historic and Cultural Resources ............................................................................. 2 8.1.8 Socioeconomics and Environmental Justice ........................................................... 2 8.1.9 Transpo1tation ....... ................ ...... .. ........ ......... ........................... ......................... .... 2 8.1.10 Infrastructure ............................................ .......... ........... ........................................ 2 8.1.11 Wa tes ................................................................................................................... 3
8. 1.1 2 Hun1anHealth .... ......................................... ..... ...................................................... 3 8.2 Irreversible and Irretrievable Commitments of Resources .. ........ .... .. .......... .... .. ...... ..... ... ....3 8.3 Short-term Use of the Environment and the Maintenance and Enhancement of Long-Tenn Productivity ....... .... ... ..... ..... ...... .... ..... ...... ................ .... ....... ................ ...... .... 4 CHAPTER 9: COST BENEFIT ANALYSIS 9 .0 Introduction .... ... .. ........ ... ....... ...... ........ .. ...... ... .. ... ....... ... .. .. ... .. .............. ... .............. ..... ..... . l HOLTEC INTERNATIONAL COPYR[GHTED MATERIAL HI-2167521 I Rev. 4 Page vi of xiii 7 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Table of Content 9.1 Scope of this Cost-Benefit Analysi .................................................................................. 2 9.2 Results ... .................. .. ............................. .. ....... .... ............................................... .. ........ ..5 9 .2.1 No-Action Alternative o t ......... ........ ............ .... ....... .......... ...... .......... ...... ...... .... 5 9.2.2 Proposed Action Costs ... .. ......... ... ........... ........ .. ...... ..... ... .. ............ .......... .... .. ... ..... .6 9.2.3 Discu sion of Results .......... .... ............ ............ .............. ... .. .... ... .. .. .... ....... .. .... .... .. ..7 9.2.4 No-Action Alternative Co ts ........................... ...................... ..... ........... ..... .. .. .... .... 7 9.2.5 Other Co ts ..... .. ... ... ....... ............. .. .... .................. ..... ...... ....... ....... ........ .................. 8 9.2.6 Comparison with Other Ana lyes .... .. ........... ... ............................................. .. .... ..... 8 CHAPTER 10: REFERENCES .......................................................................................... 1-13 CHAPTER 11: GLOSSARY ................................................................................................... 1 CHAPTER 12: LIST OF PREPARERS 12.0 List of Preparers ...... ...................................................................................... ....... ............ 1

12. l Tetra Tech, lnc . .. .. ............ ................ .. ............................ .. ......... .................................... 1 12.2 Stati tical Research, Inc ................................................................................................ 2 LIST OF APPENDICES APPENDIX P GE Appendix A: Data Sources ...... .. ............................................... .. ...... ... .. ............ ......... ...... ... . A- 1 Appendix B: Eco lo gica I Survey Results ... .............. .. ........... ............ .... ......... ......... .... .... .. ...... B-1 Appendix C: Cultural Re ource Communication and Survey Re ult . .... ..... ...... ..... ..... .. .... . -1 Appendix D: Additional Soi l Data ...................................... ................ .................................. D-1 Appendix E: Annual Wind Rose Data . ... .... .. ......... ... ... .......... ........ ... .... ..... ...... ..... E- 1 App ndix F: Data Call for the ClS Environm ntal Report September 2016 . . . . . . .. . .. . . .. . . . F-1 Appendix G: Data Call for the CIS Environmental Report January 2017 ....................... G-1 HOLTEC INTERNATIONAL COPYR[GHTED MAT ERIAL HI-2167521 I Rev. 4 Page vii of xiii 8 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Table of Content ACRONYMS AND ABBREVIATIONS op degrees Fahrenheit AADT annual average daily traffic ACEC Area of Critical Environmental Concern ACHP Advi ory Council on Hi toric Preservation ALARA as low as reasonably achievable ams ! above mean sea level APE Area of Potential Effects ARMS Archaeological Record Management Section BISON Biota Information System of ew Mexico BLM Bureau of Land Management BLS Bureau of Labor Statistics BMP best management practice BNSF Bw-lington Northern-Santa Fe AA Clean Air Act CEC Cavity Enclosure Containers CEDE committed effective dose equivalent CESQG Conditionally Exempt Small Quantity Generator CFO Carlsbad Field Office FR Code of Federal Regulation CISF Conso lidated Interim Storage Facility CLSM Controlled Low Strength Material co carbon monoxide 02 carbon dioxide equival nt CoC Certificate of Compliance CWA Clean Water Act D&D decontamination and decommissioning dB decibel units dBA A-w ighted decibels D do e equivalent DOE U.S. Department of Energy DOI U .S. Department of the Interior DOT U.S . Department of Transportation EDE effective dose equivalent EIS nvironm ntal Impact Statem nt ELEA Eddy-Lea Energy Alliance EMS Emergency Medical Service EMT Emergency Medical Technician HOLTEC INTERNATIONAL COPYR[GHTED MATERIAL HI-2167521 I Rev. 4 Page vi ii of xiii 9 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Table of Content EPA U.S. Environmental Protection Agency ER Environmental Report FEIS Final Environmental Impact Statement FEMA Federal Emergency Management Agency FEP/D P Fluorine Extraction Proce and Depleted Uranium De-conver ion Plant FLMPA Federal Land Policy and Management Act FR F deral R gist r FSAR Final Safi ty Analy i Report GCR Geological Characterization Report GHG Greenhouse Ga GNEP Global Nuclear Energy Partnership GPS Global Po itioning Sy tern I-STORM UMAX I-Ioltec International Storage Module Underground MAXimum Capacity HLW High-Level Waste Holtec Holtec International HPD Hi toric Pre ervation Divisjon HUD Department of Hou ing and Urban Development JCRP International Commission on Radiation Protection IlFP International Isotopes Fluorine Production IO Isolated Occurrences ISCORS Interagency Steering Committe on Radiation Standards ISFST Independent Spent Fuel Storage Installation LLRW Low-Level Radioactive Wa te MDC Minimum Detectable Concentration MEI maximally exposed individual MN Mid sa and Wink fine andy Loams MOA memorandum of agreement MPC Multi-Purpose Canister mph miles per hour 1m*em millirem MRS Monitor d Retri vable Storage In tallation MTU metric ton of uranium MU Mixed alluvial land MW Mobeetie-Potter association NAAQS National Ambient Air Quality Standards NAC NA International NBS National Bureau of Standard Handbook HOLTEC INTERNATIONAL COPYR[GHTED MAT ERIAL HI-2167521 I Rev. 4 Page ix of xiii 10 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Faci lity Environmental Report Table of Content NEF National Enrichment Fac ility NEPA National Environmental Policy Act NHPA National istoric Preservation Act NMAAQS New Mexico Ambient Air Quality Standard NM RJS New Mexico Cultural Re ource Information Sy tem NMDOT New Mexico Department of Transportation NMED New Mexico Environmental Department NMHPD New Mexico Historic Preservation Division NMWQB New Mexico Water Quality Bureau NMRPTC New Mexico Rare Plant Technical Counci l NOT Notice ofintent NOx oxide of njtrogen NPDES National Pollutant Discharge Elimination System NRC U.S. Nuclear Regulatory Commission NRCS Natural Re ource Con ervation Service NRHP National Register of Historic P laces NUREG U.S. Nuclear Regulatory Commission Regu lation NWS National Weather Service NWPA Nuclear Waste Policy Act 03 ozon OCD Oil Con ervation Divi ion OSHA Occupational Safety and Health Administration OSL optically timu lated luminescence Pb lead PFS P rivate Fuel Storage PGA P ak Horizontal Ground Acceleration PM particulate matter PMlO particulate matter less than or equal to 10 microns PM2.5 particulate matter less than or equal to 2.5 microns PPH pounds per hour PRA probabi li tic risk assessment QA qua lity a urance QC quality control RBE relative biological effect RCRA R sourc Cons rvation and R covery Act REMP Radiological Environmental Monitoring Program ROI region of influence ROW rights-of-way RPA Registered Professional Archaeologist HOLTEC INTERNATIONAL COPYR[GHTED MATERIAL HI-2167521 I Rev. 4 Page x of xiii 11 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Table of Content SAR Safety Analysi Report SDWA Safe Drinking Water Act s Simona fine sandy loam SES Self-Hardening Engineering Subgrade SFP Support Foundation Pad SHPO State Historic Preservation Officer Site Proposed CISF Site SNF Spent Nuclear Fuel S02 sulfur dioxide ONGS San Onofre Nuc lear Generating Station SPCC Spill Prevention, Control, and Countermeasure Plan SR Simona-Upton association SRI Statistical Research, Inc.

SWAT Special Weapons and Tactic SWPP Stormwater Pollution Prevention Plan T&E threatened and endangered TEDE total effective dose equivalent TLD thermoluminescent dosin1eters TNMR Texas-New Mexico Raih-oad TPY tons p r year TPWD Texa Park and Wildlife Department TRU transuranic TSP total suspended particulates U.S. United State USACE U.S. Army Corp ofEngineers USDA U.S. Department of Agriculture USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey USTs Underground Storage Tanks UWB U nd rground Water Basin VCT Vertical Cask Transporter voes volatile organic compounds VRM Visual Resource Management VVM Vertical Ventilated Modules WCS Wa te Control Speciali t WIPP Wa te Isolation Pilot Plant WRCC We tern Regional Climate Center HOLTEC INTERNATIONAL COPYR[GHTED MATERIAL HI-2167521 I Rev. 4 Page xi of xiii 12 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Table of Content CONVERSION CHART TO CONVERT FROM U.S. CUSTOMARY INTO TO CONVERT FROM METRlC INTO .s.

l\fETRrC U TOMARY If you know Multiply by To get If you know Multiply by To get Length inches 2.540 centimeters centimeters 0.393 7 inches feet 30.48 centimeters centimeters 0.03281 feet fe I 0.3048 meter meter 3.281 feet yards 0.9144 meters meters 1.094 yards miles 1.609 kilometers ki lorneters 0.62 14 miles Area square square quare inches 6.452 0.1550 square inches centimeter centimeter square feet 0.09290 square meters square meters 10.76 square feet square yards 0.8361 square meters square meters 1.196 square yards acre 0.4047 hectare hectares 2.471 acre quare quare quar miles 2.590 0.386 1 squar miles kilometers kilometers Volume fluid ounces 29.57 miUiliters miUiliters 0.03381 fluid ounces gallons 3.785 liters liters 0. 2642 gallons cubic feet 0.02832 cubic meters cubic meters 35.3 1 cubic feet cubic yards 0.7646 cubic meters cubic meters 1.308 cubic yards Weight ounces 28.35 grams gram 0.03527 ounces pound 0.4536 kilograms kilogram 2.205 pounds short ton s 0.9072 metric tons metri c tons 1. 102 short tons Temperature subtract 32, multiply by Fahrenheit Celsiu Celsius Fahrenheit then multiply 9/5 then add

("F) coq coq (OF) by 5/9 32 Kelvin subtract Celsius Celsius Kelvin add 273.15 (K) 273. 15 (OC) co ) (K)

Note: I siev rt = 100 rem HOLTEC INTERNATIONAL COPYR[GHTED MATERIAL HI-2167521 I Rev. 4 Page xji of xiii 13 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction CHAPTER 1: INTRODUCTION

1.0 INTRODUCTION

oltec International (Holtec) has prepared a license application for a Consolidated Interim Storage (CIS) Facility for approval by the United States (U.S.) Nuclear Regulatory Commi sion (NRC) pursuant to the requirements specified in Title 10 of the Code of Federal Regulations (C R), Part 72 Licen ing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste. The proposed site (hereafter, 'Site") for the CIS Facility is located in southeastern New Mexico in Lea County, 32 mile eat of Carl bad, New Mexico, and 34 mil wet of Hobb , New Mexico (Figur 1.0.1).

Holt c has prepared this Env ironmental Report (ER) to eva luate the potential radiological and non-radiological impacts associated with the construction and operation of the CIS Facility for Spent Nuclear Fuel (SNF) and Reactor-Related Greater than Class C Low-Level Radioactive Waste (LLR W) (h reafter, r :fi rred to coll ctively a "SNF") in Lea ounty, New Mexico. Holtec i proposing to construct and operate Phase 1 of the CIS Facility within an approximate ly 1,040 acre parcel. Holtec is cmrently requesting authorization to pos ess and store 500 canisters of SNF containing 8,680 metric tons of uranium (MTUs), which include sp nt uranium-ha d fu I from commercial nuclear reactors a well a a mall quantity of spent mixed-oxide fuel. If the reque t d license is issued by the NRC, Holtec anticipates subsequently requesting an amendment to the license to request authorization to possess and store SNF containing additional 500 canisters for each of 19 sub qu nt expat1 ion pha e to be compl t dover th cour of20 year . Ultimat ly, Holtec anticipates that approximately 10,000 canisters of SNF would be stored at the CJS Facility upon completion of20 phases. In total, this ER analyzes the environmental impacts of possession and storage of SNF containing 100,000 MTUs (each canister typ contains different design basis MTU ).

Thi ER was prepared to upport a License Application for review and approval by the NRC pussuant to the requirements specified in 10 CFR Part 72.34 and in 10 CFR Part 51.61, Environmental Report- Independent Spent Fuel Storage In tallation (ISFSI) or Monitored Retrievable Storage Installation (MRS) license. oltec prepared thi ER con i tent with the guidance provided in two regulatory documents:

Regulatory Guide 3.50, Standard Format and Content/or A Specific License Application for an independent Spent Fuel Storage Installation or Monitored Retrievable Storage Facility (NRC 2014a);

U.S. Nuclear Regulatory Commission Regulation (NUREG)-1748, Environmental Review Guidance for Licen ing Action As ociated with NMSS Program (NRC 2003).

Holtec antic ipates that the NRC would issue the Final Environmental Impact Statement (FEJS) and License in 2019. Phase l construction would begin after issuance of the license and after Holtec ucces fully enter into a contract for storage with the U.S. Department of Energy (DOE) or utility. on tmctioo on Pha e 1 i expected to begin in the fir t quarter of 2020 and be complete within 1.5 year . After preoperational testing, Phase 1 of the CIS Facility i expected to be operational in early 2022. In this ER, Holtec has assumed that SNF could be stored at the CIS Facility for approximately 120 year (40 year for initial licen ing plu 80 year for life extension ). That storage period could be reduced if a final geologic repository is licensed and HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2 167521 I Rev. 4 1-1 14 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 1: Introduction operating in accordance with the Nuclear Waste Policy Act (NWP A) of 1982, as amended (Holtec 2016a).

HOLTEC INT ERNATIONAL COPYRIGHTED MATERIAL HI-2167521 I Rev. 4 1-2 15 of 558

ATIACHMENT 5 TO HOLTEC LETT ER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction

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New Mexico Site Gaines County New Mexico Lea County Tex as -

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  • CISF Site Stats Boundary A

rLrLJ-----iM lles County Boundary 0 2 4 8 Figure 1.0.1: LOCATION OF PROPOSED CIS FACILITY HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-216752 1 I Rev. 4 1-3 16 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction 1.1 HISTORY AND BACKGROUND The U.S . Congre s enacted the NWPA of 1982 a signing DOE the task of developing a geologic repo itory for the di po al of SNF generated by commercial nuclear power plants located throughout the U.S. In 1987, Congress amended the NWP A to streamline and focus SNF management on developing the geologic reposit01y at Yucca Mountain, located in Nye County, Nevada. Pursuant to the NWP A, DOE was re pon ible for obtaining required licenses for Yucca Mountain with operations to begin on January 31 , 1998.

On July 23, 2002, President Bush approved Congressional legislation designating Yucca Mountain as the final geologic repo itory intended for the disposal of commercial SNF and high-level waste (HLW) generated by the Federal government. DOE ubmitted a licen e application to the NRC for authorization to con truct and operate Yucca Mountain. The NRC reviewed the license application and issued a series of Safety Evaluation Reports addressing the long-term environmental performance of Yucca Mountain. However, much w1ce1tainty remains as to whether or not the facility will open and begin accepting commercial SNF or HLW for di po *al. In January 2010 President Obama established the Blue Ribbon Commission on America ' s Nuclear Future. The Com.mis ion was directed by the Secretary of Energy to conduct a comprehensive review of policies for managing the back nd of th nuclear fuel cycle and to recommend a new strategy. On January 26, 2012, the Blue Ribbon Commi sion i ued a final report consi. ting of eight key recommendations. Of paramount importance to this licensing action was the Blue Ribbon Commi ion' recommendation to adopt a new con ent-based approach to iting future nuclear wa te management facilities in order to initiate prompt effort to develop one or more con olidated storage facilities (BRC 2012 Chapter 6).

Con istent with the Blue Ribbon Commission's recommendation, on December 23, 2015, DOE announced that it would implement a consent-based siting process to establi h an integrated waste management system to transport, tore, and dispo e of SNF and ILW. Tn a cons nt-based iting approach, DOE would work with communities, tribal governments and states across the country that express interest in hosting any of the facilities identified as part of an integrated waste management y tern. As part of this proces , DOE olicit d public comments and ho ted a seri of public meeting ' to engage communities and discu s the development of a consent-ba ed approach to managing SNF and HLW (80 Federal Register [FR] 79872).

Although the consent-based approach applies to Federal proposals, that approach is indirectly applicable to private proposals such as Holtec ' s. For example, it i possible that DOE would evaluate proposals uch as Holtec' for consi tency with the Federal con ent-ba ed approach. To that end, Holtec's proposal has been vetted and discussed publicly botb at the local and state-level, as discussed below and in Section 2.3 (Site Selection Process).

Development ofHoltec ' s CIS Facility has support from the state, regional, and local communities located in southeastern New Mexico. In an April 10, 2015 letter, New Mexico Governor Martinez wrote to Energy Secretary Ernest Moniz urging the administration to look to outhea tern New Mexico to store the SNF. "Time and time again, the citizens of southeastern New Mexico have impres ed me with their bard work ethic and willingnes to tackle national problem that many other con ider to be unsolvable " Martinez wrote. "In one of the mo t remote area of the tate, they have had the ingenuity and fortitude to carve out a niche in the nuclear indu try to broaden HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 1-4 17 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction their economic base. They understand the benefits not only to their local economy, but also to our country" (Martinez 2015).

In February 2016, the New Mexico Senate Conservation Committee approved a nonbinding mea ure to signal upport for the dev lopment of the CIS Facility. Although the mea ure does not hold any legal weight, supporters of the CIS Facility view it as an endorsement from the State Legislature that would help in what is likely to be a competitive process as the Federal government weighs proposals for storing SNF (ALBQ Journal 2016).

In April 2016, Holtec and the Eddy-Lea Energy Alliance 1 ( LEA) announced the signing of a memorandum of agreement (MOA) covering the design, hcen ing, con truction and operation of the CIS Facility. Among other things, that MOA provides the means by which Ho !tee could purcha e the Site propo ed for the IS Facility (ELEA 2016). On July 19, 2016, the New Mexico Board of Finance approved the ale of the Site to Holtec (NMBF 2016).

With regard to pr viou ffort to licen a private to rage facility for SNF, in Dec mb r 2001 , the NRC previously prepared the Final Environmental Impact Statement (EIS) for the Construction and Operation of an Independent Spent Fuel Storage installation on the Reservation of the Skull Valley Band of the Goshute Indians and Related Transportation Facility in Tooele County, Utah ,

NUREG-1714 (NRC 2001). The subject of that EIS, a faci lity referred to as the "Private Fuel Storage" (PFS) facility," wa designed and licensed to store up to 40,000 MTUs of SNF in sealed metal casks (approximately 4 ,000 storage casks) for a term of20 years. The PFS facility was never licensed or constructed.

More recently, th NRC directed taffto develop a wa te confidence deci ion and promu lgated the Continued Storage Rule to be supported by an environmental impact statement (SRM-COMSECY-12-0016) (NRC 2012a). As such, the NR completed a Generic Environmental Impact Statement for Continued Storage ofSpent Nuclear Fuel (NUREG-2157) (NRC 2014b) that addressed the impacts attributable to continued storage of SNF. The report wa needed by the NRC to folfill its responsibilities under the National Environmental Policy Act (NEPA). The environmental impacts evaluated in NUREG-2157 include those related to shoit-term (60 years),

Jong-term (an additional 100 year ), and indefinite storage of SNF at exi ting commercial nuclear power plants, as well as at an "away-from-reactor" storage facility.

In developing NUREG-2157 NRC referred to the previous environmental analyses that supported issuance of the FEIS for the PFS facility in Tooele, Utah. The NRC concluded that implementation of the Preferred Alternative to issue a license to the PFS authorizing construction and operation of an ISFSI in Tooele County, Utah would generally be mall (NRC 2014b Table ES-4).

Thi ER con titute a ite-specific analy is of the propo ed CTS Faci lity at the southea tern New Mexico Site in Lea County. This ER incorporates relevant information and analyses from NUREG-2157 as appropriate, for purpose of completene . For example, for most resources analyzed in hapter 4 of this ER, there is a high-level compari on of the ite-specific impact conclusions presented in this ER to the generic impact conclusions contained in NUREG-2157.

1 The Eddy-Lea Energy Alliance is a li mited liability company owned by the cities of arlsbad and Hobbs, and Eddy ounty and Lea ounty .

HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 1-5 18 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction 1.2 PURPOSE AND NEED FOR THE PROPOSED ACTION DO bas not yet dev lop d a p rman nt geologic r pository to allow for the dispo al of commercial SNF at Yucca Mountain in Nye County, Nevada as required under the NWPA. DOE was required to open the repository and begin accepting SNF for disposal at Yucca Mountain on January 31, 1998. However, the earliest estimated time by which a permanent geologic repo itory could be licensed and operational is 2048 (DOE 2013 , pg. 7). The only alternative currently available to the commercial nuclear power utilitie (whether currently operational or decommissioned and non-operational are to either continue to store SNF in onsite ISFSls or at an "away-from-reactor" torage facility. I owev r, there are currently no licen ed away-from-reactor storage facilities for accepting SNF from commercial reactor .

At the time this ER was prepared, three nuclear power plant have been hut down and are in the process of being decommissioned and nine nuclear power plants across the U.S. have been deconunissioned (hereafter referred to as the 'decommissioned shutdown sites") to levels that would allow for unrestricted relea e of the site in accordance with the NRC' Licen e Termination Rule (10 CFR 20, Subpart E). Even though in some cases the nuclear power plants, including the SNF pools, have been dismantled and deco1mnissioned, the SNF remains and continues to be stored in onsit ISFSis. Many policymakers and stak hold rs in the communiti s that host shutdown reactors want to have the SNF removed to complete decommi ioning of the site and to allow for more beneficial uses of the land.

While decommis ioning activities have been completed at nine locations across the U.S. ( except for removing the SNF from dry ca k storage), other financial pre ure are expected to cau e utilitie to hut down and begin decommis ioning other commercial nuclear reactors. A CIS Facility is needed to ensure that the SNF at these commercial reactor sites can be safely removed so that the remaining lands can be returned to Greenfield status. Thi point is further underscored with the announcement by other electric utilitie of their pJans to shut down and decommi ion additional commercial reactors located throughout the U.S.

The nuclear power utilities continue to remain respon ible for the urveillance, maintenance, emergency preparedness, and physical secw-ity of the SNF stored at their ISFSI ( unless otherwise ex mpted by the NRC). Th se activities are e timated to co t each of the utilitie at the decommi si.oned shutdown sites an estimated $4.5-8 mi Iii.on per year (BRC 2012, Section 5.2.1 ).

Developing a CIS Facility in Lea County, New Mexico, in the most timely manner possible, serves a national strategic need by providing for an orderly tran fer of SNF from the decommissioned hutdown ites to a safer and more secure centralized storage location (NR 2003). In addition to serving the needs of the deconunissioned shutdown sites, a CIS Facility also serves the needs of the existing operating commercial nuclear reactors in the U.S. , until a permanent repository become available. A CIS Facility alleviate th need to construct new or xpanded ISFSI at these operating ite .

There are only two reasonable alternatives that would meet the purpo e and need described in thi section; (1) the o Action Alternative, described in Section 2.1 and (2) the Proposed Action, de cribed in Section 2.2. Chapter 4 di cu e the impact a ociated with the two rea onable alternatives. Section 2.4 discus e alternatives that were con idered but eliminated from detailed study, and explains why those alternatives were not reasonable.

HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 1-6 19 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction 1.3 THE PROPOSED ACTION Pursuant to th requir ments specifi d in Title 10 of CFR Part 72, Holtec i requesting a license from the NRC for authorization to con truct and operate a CIS Fac ility in Lea County, New Mexico, 32 miles east of Carlsbad, New Mexico, and 34 mjles west of Hobbs, New Mexico (Figure 1.3.1). Accounting for the Protected Area (i.e., the ar a within the security fence containing the ISFSJ Pads and the Ca k Transfer Building), Phase 1 con truction would disturb approximately 119.4 acres. Of this disturbance, 6.2 acre would be associated with constructing the Site access road and relocating the existing road that currently runs through the Site; 39.4 acres would be a ociated with con tructing a railroad spur; and 1.4 acre would be associated with con tructing the Security Building, Admini trative Building, Parking Lot, and the concrete batch plant/laydown area. Holtec is reque ting a license to store up to 8,680 MTUs in Phase L, but has analyzed the environmental impacts of toring up to 100,000 MTUs at the CIS Faci lity.

Construction of Phases 2-20 would occur over approximately 20 years and would require an additional 210.6 acres of land. Such construction would occur adjacent to operational areas previously constructed. At full build-out, the CJS Facility would be constructed on approximately 330 acres. The Protected Area, which encloses the ISFSI Pads, would account for 283 acres of this total. Within the Protect d Area, approximat ly 110 acr would b di turbed by th ISFSJ Pads.

There would be a buffer of more than 270 acres between the Protected Area boundary and the ISFSI Pads. All SNF stored within the Protected Area would be more than 500 feet from the Protected Area boundary and more than 1,000 feet from the property boundary. Pha e J provides a bounding e timate for any construction impact due to the as ociated support tructures for the e subsequent phases. The construction phases will be performed in sequence. Table J .3 shows approximate durations for construction of phases 1-20 with the cumulative MTUs completed for each phase.

The major benefit of the Pro po ed Action i to authorize the receipt of the SNF currently in storage at the decommissioned shutdown sites, thus enabling the land at these sites to be returned to Greenfield status. After the land has been returned to Greenfield status, the communities that host d the commercial reactor plant gain additional benefits as the land could pot ntially be redeveloped for other purpo es. The Propo ed Action also provide a regu latory path fo1ward to receive SNF from other commercial reactors that may be decommissioned in the future, as well from operating commercial r actors prior to decommissioning. A IS Facility erves as an interim storage facility until a geo logic repository can be opened.

The propo ed CIS Facility utilizes the technology licen d in Holtec's generic ertificate of Compliance for the Holtec International Storage Module Underground MAXimum Capacity (HI-STORM UMAX) Storage System, NRC docket number 72-1040. HI-STORM UMAX tore the canister containing SNF entire ly below-ground to erve as a ' ecurity-friend ly" torage facili ty, providing a clear, unobstrncted view of the entire CIS Facility from any locat ion and the closure lid is a massive steel weldment filled with concrete, virtually eliminating the storage contents as a target for malevolent acts. The CIS Facility doe not require any utiliti s (wat r, compress d air, or electric power) for it operation po t emplacement, eliminating any elements of vuln rability to terrorism. The subterranean stored contents emit a very small direct radiation dose to the facility workers and surrounding environment. See Section 2.2 of this ER for a detailed description of the CIS Faci lity. The only pathway for public exposur to radiation from routin operations at th CIS Facility is external exposure at the uncontrolled boundary from the SNF casks stored at the ISFSI.

HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 1-7 20 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Faci lity Environmental Report Chapter 1: Introduction There is no air pathway because the cask are sealed by being welded shut. There is no potential for a liquid pathway because the SNF contains no liquid component and the casks are sealed to prevent any liquids from contacting the SNF assemblie . Chapter 7 provide detail regarding monitoring requirements for the CIS Facility.

The HI-STORM UMAX Storage System technology to be employed at the CJS Facility is currently licensed by the NRC in accordance with IO CFR Part 72 and therefore complies with the NRC requirements for the independent storage ofSNF. Holtec anticipate the SNF could be stored at the CJS Facility for up to 120 years, or until a permanent geologic repository is opened consi.stent with the NR 's Continued Storage Rule. The CJS Facility would be decommissioned at the end of facility life in accordance with 10 CFR 20, Subpart E.

Below is the anticipated schedule for the con truction and operation of the proposed ClS Facility:

  • Submit License Application in March 2017;
  • Receive license 2019;
  • Construction of Phase I of the CIS Facility begins in first quarter of 2020;
  • Holtec CIS Facility commences operations in 2022.

HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 1-8 21 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction Table 1.3 APPROXTMA TE SCHEDULE OF ALL PROPOSED CONSTRUCTION PHASES FOR THE CIS FACILITY CJS Facility Total Capacity Once Phase Phase Construction Phase of Construction Completed ( number of Duration (Years) canisters) l 2 500 2 I 1,000 3 I 1,500 4 I 2,000 5 1 2,500 6 I 3,000 7 I 3,500 8 I 4,000 9 I 4,500 10 l 5,000 11 l 5,500 12 I 6,000 13 I 6,500 14 1 7,000 15 l 7,500 16 l 8,000 17 l 8,500 18 I 9,000 19 l 9,500 20 I 10,000 HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 1-9 22 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 1: Introduction I

Figure 1.3.1: CIS FACILITY SITE BOUNDARIES HOL TEC INTERNATIONAL COPYRlGHTED MATERIAL HI-2167521 I Rev. 4 1-10 23 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction 1.4 APPLICABLE REGULA TORY REQUIREMENTS, PERMITS, AND REQUIRED CONSULTATIONS This ection provides a summary of the Federal, state, and local law and regulations applicable the proposed CTS Facility. For each applicable law or regulation, the Site is evaluated to determine whether the available Site environmental characteristics support the regulatory requirements with respect to successfully licensing and permitting the facilitie . This section also identifie any legislative or regulatory prohibitions that might prevent siting and permitting the CIS Facility at the Site. The role of the Federal, tate, and local agencies involved with the licen ing and permitting of the CIS Facility is also discussed . A list of pertinent Federal, state, and local authorizations and consultations applicable to th ClS Fac ility at the Sit is provid d in Table 1.4.1.

1.4.J United States Government The following i a summary of Federal ag ncie involved in the environm ntal approval and con ultation process for resources in their jurisdiction for the CIS Facility project construction and operations activities proposed by Holtec.

1.4.1.1 U.S. Nuclear Regulatory Commission The Atomic Energy Act of 1954 as amended, gives the NRC regulatory jurisdiction over the design, construction, operation, and decommissioning of the facility specifically with r gard to a surance of public health and afety. The NRC would p rform periodic urveillance of con truction, operation and maintenance of the proposed facility. The NRC establishes standards for protection against radiation hazards arising out of licensed activities. The NRC licenses are i ued pursuant to the Atomic Energy Act of l 954, a amended, and the nergy Organization Act of 1974. The regulation apply to all per ons who receive, posse , use or tran fer licensed materials.

The NRC is responsible for the review and licensing of SNF storage facilities in accordance with 10 CFR Part 72. Submittal of a comprehensive licen e application, including, among other things, a Safety Analy is Report (SAR) and an ER that addres afety and environmental i ues, i required pursuant to 10 CFR Part 72. This ER and other required plan /documents are being submitted concurrently to the NRC for its review and approval. As part of the licensing proces for the propo ed faci lities, tbe NRC will prepare an IS in accordance with NEPA requirement and NRC regulations (10 CFR Part 51) for implementing NEPA. Other applicable NRC regulations include: Appendix B of 10 CFR Part 50 for Quality Assurance and 10 CFR Part 73 for physical protection.

Seven categories of NRC licens es are required to report annually on individual xposure in accordance with Title IO of the Code of Federal Regulations (IO CFR 20.2206, "Reports of Individual Monitoring"). These categories include independent spent fuel storage installations.

The data submitted by licensees con ist of radiation exposure records for each monitored individual. Th data ar ana lyzed and r ported annua lly by th NRC in terms of collect ive dose and the distribution of dose among the monitored individuals (NRC 2016, Appendix A Table Al) .

The limits for exposures are discussed in Section 3.12.2.1.

HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 1-11 24 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction 1.4.1.2 U.S. Environmental Protection Agency (EPA)

The EPA ha primary authodty relating to compliance with the Clean Air Act (CAA), Clean Water Act (CW A), Safe Drinking Water Act (SDW A), and Resource Conservation and Recovery Act (RCRA). EPA Region 6 has delegated regulatory jurisdiction to the N w Mexico nvironmental Department (NMED) for nearly all aspects of permitting, monitoring and reporting activities relating to these statutes and associated programs. Consequently, compliance activities associated with these statutes are presented in Section 1.4.2.

The EPA has promulgated standards for a number of hazardous air pollutants, including rad ionuclid . Emi sion Standards for NRC Licen d Facilities (40 CFR 61 Subpart I) tabli he limits on em ission ofradionuclides to air such that the public would not receive an effect ive dose equivalent exceeding 10 millirem/year. Becau e the CIS Facility will not emit radionuclide to the air during op rations, this standard will not be exceeded.

1.4.1.3 U.S. Department of Transportation (DOT)

The transportation of SNF from a conunercial nuclear power plant to the CIS Facility r quires a tran portation package that is approved and certified by the NRC in accordance with IO CFR Part

71. The Certificate of Compliance (CoC) ensure the transport packages are designed to maintain confinement of the SNF during shipping and ensure there will not be any radiological release caused by hypothetical severe accident scenarios.

Th tran port r of SNF must submit application to th NRC for review and approval of a transpo1tation package in accordance with l O CFR Parts 72 and 71 , re pectively. Upon approval of such applications, the NRC issues a CoC for the specific designs.

Transp01tation of SNF is regulated under 49 CFR Part 173, Shippers - General Requirements for Shipments and Packagings. Other requirements pertaining to the tran portation of material to the propo ed CIS Facility are:

  • 49 CFR Part 171 , General Information, Regulation , and Definition *
  • 49 CFR Part l 72, Hazardous Materials Tables, Special Provi *ions, Hazardous Mat erial Communication, Emergency Respon e Information, and Training Requirements;
  • 49 CFR Part 177, Carriage by Public Highway:
  • 49 FR Part 107 Subpart G (regi tration/fee to DOT a a person who offers or transports hazardous materials).

All provision of these enabling regulation are met prior to the transport of any SNF, LLRW, mixed waste, or hazardous material.

1.4.1.4 Occupational Safety and Health Administration (OSHA)

The Occupational Safety and Health Act of 1970 is designed to increase the safety of workers in the workplace. It provide that the Department of Labor i expected to recognize the dangers that may exist in workplaces and e tabli h employee afety and health tandard . Applicable regulations are found in 29 CFR 1910 for general indu stry and 29 CPR 1926 for construction activities. OSHA regulates mitigation requirements and mandate proper training and equipment for worker . A Memorandum of Under tanding between OSHA and NRC allow NR to identify HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2 167521 I Rev. 4 1-12 25 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction any violations to the licensee (in this case, Holtec) for correction, if correction does not occur, then NRC will notify the regional Federal OSHA office.

1.4.1.5 U.S. Department of Interior, U.S. Fish and Wildlife Service (USFWS)

The USFWS is responsible for the protection of threatened and endangered species. There are thr e Federally- Ii ted pecies known to occur within Lea County, New Mexico. These include the Interior Least Tern (Sternula antillarum athalassos), the Northern Aplomado Falcon (Falco femoralis septentrionalis), and the Yellow-Billed Cuckoo (Coccyzus americanus). Additionally, the Le ser Prairie- hicken (Tympanuchus pallidicinctus) is also currently under review for listing consideration. A biological resource urv y of the Sit was completed in October 2016 and no significant biological resources were identified within the area surveyed (see Appendix B). As discu sed in Section 3.4 of this ER, these specie have not been located within the Site and r gulatory revi ws and fi Id in p ctions do not support th b lief that they ar pre nt within the CJS Fac ility Site. There is no de ignated or proposed critical habitat within Lea County.

In 2008, the Bureau of Land Management (BLM) e tabli bed a Le er Prairie-Chicken Habitat Preservation Area of Critical Environmental Concern (ACEC) to protect and enhance 58,000 acres of habitat for the species. The nearest ACEC straddles Lea and Eddy Counties and is about 58 mile from the Site (BLM 2008, Appendix 3).

1.4.1.6 U.S. Department of Interior, Bureau of Land Management (BLM)

Almo tall of th land immediat ly urrounding th Sit is owned and managed by the BLM. A de cribed in Section 2.2. 1 and hown on Figure 2.2.1 , Holtec i proposing to con trnct an acce s road and railroad spur to the Site. The road and railroad pur would necessarily cross BLM land and would require BLM to i sue rights-of-way (ROW) authorization to construct and operate the road and railroad pur, in accordance with Federal Land Policy and Management Act of 1976 (FLPMA) and the Mineral Leasing Act of 1920.

1.4.2 State of New Mexico At the state level the environmental permitting of the CIS Facility, which would be located on land owned by Holtec, is primarily governed by the NMED. NMED is charged with responsibility to manage and protect human health and the environment in the State of New Mexico. The NMED consi t of evera l divi ion that ha ve responsibility for various permits and environmental programs. The following is a summary of environmental permitting activities to be undertaken withNMEO.

1.4.2.1 Surface Water Protection In order to protect jurisdictional waters from pollutants that could be conveyed in construction-r lated stormwater runoff, a PDES Construction Stormwater Permit is required b cause construction of the CIS Facility involves the grubbing, clearing, grading or excavat ion of more than 1 acre of land. Various land clearing activities such as a borrow pit for fill material may also be covered under thi genera l permit.

As part of this permitting process, a Stormwat r Pollution Prevention Plan (SWPPP) is developed and a Notice of Intent (NOJ) filed with the NMEO Water Quality Bureau prior to th commencement of construction act ivities. Implementation of the SWPPP requirements occurs prior to any discharge and continue until permit tennination. Within the SWPPP, there are HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 1-13 26 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction provisions outlining ero ion and ediment controls soi l stabilization practices structural controls and other best management practices (BMPs) employed during construction to protect offsite water from adver e impacts from con truction-related activities and mitigate any storm water runoff The SWPPP also outlines maintenance and inspection requirements and identify BMPs for the effective management of storm water runoff.

Once construction has been completed, a NPDES General Permit for Industrial Stormwater is required for point source discharge of stormwater runoff :from industrial or commercial facilities to the water of the state. Commonly, a general permit is available to almost any industry, but there is also an option to obtain an individual NPDES permit for the CIS Facility. The CIS Facility does not di charge proce s wastewater, and there are no potable surface water resources within the vicinity oftbe Site.

A Spill Prevention, Control, and Countermeasures Plan (SPCC) may need to be developed because all diesel fuel storage tanks at the CIS Facility are placed above the ground.

The NMED Water Quality Bureau requires that facilities that discharge an aggregate wa te water of more than 2,000 gallons per day septic systems apply for and su bmit a groundwater discharge permit and plan.

1.4.2.2 Drinking Water and Groundwater Protection No potable groundwater is known to exist in the immediate vicinity of the Site. The CIS Facility doe not use Site groundwater or urface water upplies; rather, Holtec propose to obtain potable water for the CIS Facility from the City of Hobbs Water Department.

Sanitary wastewater generation during CIS Facility construction is not expected as the use of portable toilets is likely, although use of sewage collection tanks, as planned for the operations phase, is anoth r option. During CIS Facility operation, Holtec expects to dispose of sanitary wastewater u ing ewage coJlection tank and underground dige tion tanks imilar to eptic tank but with no leach field. After testing the waste in the collection tanks to ensure release criteria are met, the sewage is disposed of at an off- ite treatment facil ity.

1.4.2.3 Preservation of Air Quality As discussed in Section 4.6 of this ER, construction and operation of the CIS Facility does not have any mea urable impact on the local air quality, and no significant crit ria or hazardous air pollution emission occur. Any potential air quality-related impacts associated with construction of the CIS Facility result from gaseous pollutant emissions from diesel-powered construction equipment and from fugitive dust emis ions from excavation activities and construction equipment. An on ite concrete batch plant during con truction and operation require a permit.

To minimize fugitive du t emi ion , a BMP Emi ion Control Plan provide a w*ance that fugitive dust emi sions are effectively managed and minimized throughout all construction phases.

This BMP Emission Control Plan includes du t control techniques, such as watering and/or chemical stabilization of pot ntial du st sow-ces.

During operations, gas ous crit ria pollutant mission at the CIS acility ar limit d to mall propane space heating furnace , a tandby emergency die el generator, a fire pump die el engine, heavy haul trucks, cask transporters, and workers' private vehicles. Refrigerants used for air HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2 167521 I Rev. 4 1-14 27 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report Chapter 1: Introduction conditioning at the CIS Fac ility consist of Class II refrigera nts (i.e., non-ozone depleting sub tances).

The NMED Air Quality Bureau Permitting Section processe permit applications for industries that emit pollutant to th air. New Mexico Statute Annotated Chapter 74 "Environmental Improvement," Article 2, "Air Pollution," and implementing regu lation in NMAC Title 20 Environmental Protection, Chapter 2, "Air Quality," establishes air-quality standards and permit requirements prior to construction or modification of an air-contaminant source. These regulation also define requirements for an operating permit for major producers of air pollutants and imposes emission standards for hazardous air pollutants. Holtec intends to obtain any required air permits to support construction and operations at the CIS Faci lity from the NMED. Because there are no airborne ffluents of radionuclide from normal operation at the CIS Faci lity, airborne fflu nt monitoring is not expected to be required.

1.4.2.4 Pollution Prevention and Waste Management The CIS Facility project i committed to pollution prevention practice . Non-bazardou wa tes from construction are disposed of appropriately at off-site facilities . As discussed in Section 4.11 of thi ER, during operations, mall quantities of LLRW, mixed waste, and hazardous wastes are generated.

The NMED Hazardou Wa te Bureau mis ion is to provide regulatory oversight and technical guidance to New Mexico hazardou wa *te generator and treatment, storage, and dispo al facilities as required by the New Mexico Hazardous Waste Act (HWA; Chapter 74, Article 4) and regulations promulgated under the Act. In gen ral, the regulation promulgated pur uant to the Hazardou Wa te Act incorporate the federa l requirements under RCRA 40 CFR 260-283, by reference. The Bureau issues hazardous waste permits for all phases, quantities and degrees of hazardou wa te management including treating, toring and di po ing of listed or hazardous rnater.ia 1 .

The small quantiti s ofhazardou wa. te generat dare expected to b less than 220 pounds/month.

Thus, the CIS Facility qualifies as a Conditionally Exempt Small Quantity Generator (CESQG).

All hazardous wastes generated are identified, stored, and disposed of in accordance with state and Federal requirement app licable to CESQGs. Because the CIS Facility design doe not include Underground Storage Tank (UST ), UST regi tration with NMED i not required. Any LLRW and mixed wa te is disposed of at licensed dispo al facilities.

1.4.2.5 Historic and Archeological Resources The National Historic Preservation Act (NHPA) was enacted to create a national historic preservation program, including the National Register of Historic Places and the Advisory Council on Hi toric Preservation (ACHP). Section 106 of the NHP A requires Federal agencie (in the ca e of licen ing the CIS Facility, the NRC) to take into account the effect of their undertakings on historic properties.

Cultural properties, including prehistoric and historic archaeological sites, historic buildings and other tructure , and traditional cultural propertie located on tate land in New Mexico are protected by the Cultural Properties Act. It i unlawful for any per on to excavate, injure, destroy, or remove any cultural property or artifact on state land without a permit. It is also unlawful for any person to intent ionally excavate any unmarked human burial, and any material object or HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2 167521 I Rev. 4 1-15 28 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 1: Introduction artifact interred with the remains, located on any non-Federal or non-Indian land in New Mexico without a permit.

Coordination with the New Mexico Historic Preservation Division (HPD) and New Mexico State Historic Preservation Officer (SHPO) is being conducted for the CIS Facility. Historical and cultural resources near and within the Site are described in Section 3.7 of this ER. A cultural resource smvey of the Site was completed in December 2016 and no significant cultural resources were identified within the area surveyed (see Appendix C). No issues were identified to preclude licensing and permitting the proposed CIS Fac ility.

1.4.2.6 Site Access Holtec and Lea County intend to obtain a permit from the New Mexico Department of Transportation (NMDOT) for constructing an access road and railroad spur to the Site. The permit, once issued, would st ipulate any safety enhancements necessary.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-2167521 I Rev. 4 1-16 29 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 1: Introduction Table 1.4.1:

FEDERAL, STATE, AND LOCAL AUTHORIZATIONS, PERMITS, AND CONSULTATIONS Activity Covered A2eocy Status/Comments Federal License Application NRC Tbe CIS Facility, ou ld be Licensed by tbe NRC. The license application wa submitted to NRC in March 20 l 7.

Land U e Permit BLM Land use permit required for access road and railroad spur across BLM land. Permit would be applied for during the NEPA process.

Endangered Species Act USFWS Surveys completed and informal consultation conducted (see Appendix B). RC would conduct formal consultation as part ofNRC NEPA process.

State ational J-1.istoric Preservation Act ew Mexico State Surveys completed and informal consultation conducted (see Appendix C). NRC would Hi toric conduct formal consultation as part ofNRC NEPA proces .

Preservation Office Access Permit NMDOT Holtec and Lea County would coord inate to obtain approva l for a new ite acces road. The permit, once issued, would tipulate any afety enJ, ancements neces ary to tbe highway. Penuit would be aoolied for prior to construction.

Air Quali ty Permits NMED An onsite concrete batch plant during construction and operation would require a permit. Tf die el generators are u ed during con truction and operation, a permit may be required. Permit would be applied for prior to con !ruction . Air Operation Pennit requirement will be detem,ined once design infonnation on the facility is developed and emission rates quantified.

Groundwater Discharge Permit/Plan NMED A permit is required for facilitie that discharge an aggregate waste water of more than 2,000 gallons per day to eptic systems. A pennit may also be required for di charges to surface impoundments such as evaporative basins. Permit would be aoolied for prior to construction.

National Pollutant Di charge Elimination NMED The CIS Facility wou ld be covered under a Multi-Sector General Permit or obtain individual Svstem (NPDES) l.ndustrial Stormwater (note I) NPDES permit. Permit would be app lied for prior to construction.

NPDES Construction Stormwater Penn.it NMED The CIS Facility would be covered under the General Construction Pem1it for all construction (note I) activitie onsite. Holtec would develop a SWPPP and file a Notice ofintent at lea t two day prior to construction commencement.

Hazardous Waste Generation and Storage NMED Holtec would be a CESQG under NMED regulations. Holtec will obtain any necessary permits from NMED for the storage of accumulated wastes until they are shipped off-site for disposal.

Permit would be applied for prior to construction.

Environmenta l Protection Agency (EPA) NMED This identification number is required for the off-site shi pment of hazardous waste. Holtec otification of Hazardous Waste Activity would apply for an identification number prior to the generation of waste during fac il ity to obtain an EPA Identification Number construction and operation.

Petroleum Storage Tank Registration NMED Holtec would relrister petroleum storage tanks, as required.

Local - there are no add-itjonal permitting requirements related to the CJS Facility beyond Federal and State requirements (Lea County 2016).

ote 1: NMED has assumed NPDES permitting authority from EPA Region 6.

HOL TEC INTERNATIONAL COPYRlGHTED MATERIAL HI-2167521 I Rev. 4 1-17 30 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative CHAPTER 2: ALTERNATIVES

2.0 INTRODUCTION

This chapter describe the two alternative analyzed in detail in this Environmental Report (ER):

( 1) the No Action Alternative and (2) the Proposed Action. The No Action Alternative which is described in Section 2.1 , would occur if th proposed on olidated Interim Storage Facility (CIS Facility) is not con tructed and operated. Section 2.2 de cribe the Propo ed Action and provide information related to constmction and operation of the CIS Facility. Section 2.3 describe the site selection process that was employed for the Holtec CIS Facility, and Section 2.4 identifies other alternative to the Propo ed Action and explain why tho e other alternative were eliminated from detailed analysis. Lastly, Section 2.5 pre ents a sunm1ary comparison of the No Action Alternative and the Proposed Action, based on the analysis contained in Chapter 4 of this ER.

2.1 NO ACTION ALTERNATIVE Under the No Action Alternative, Holtec would not construct and operate the JS Facility and spent nuclear fuel (SNF) would continue to be stored at commercial reactor sites in accordance with current management objectives. Because there are no cu1Tently licensed away-from-reactor facilities for accepting SNF from commercial reactors, the No Action Alternative assumes that onsite storage would continue until another away-from-reactor facility is available or a permanent geologic repository is ultimately licensed, constmcted, and operating. It is estimated that the earliest time by which a geological repository could become available for permanent disposal of SNF would be 2048 (DOE 2013 , pg. 7).

In the hort-term under the No Action Alternative the decommi sioned shutdown ite and the existing commercial nuclear reactor sites would continue to store SNF in existing pools or at-reactor Independent Spent Fuel Storage Installation (ISFSls). At all sites, SNF would continue to be stored onsite in accordance with regulatory and licens requirements and maintain a phy ical security program to ensure the SNF remains adequately protected. In the long-term all operating sites would require existing ISFSis to be expanded or new lSFSis to be constructed. The potential impacts of expanding ISFSls or constructing new IS Sls are pre ent din Section 4.14 of this R.

Additionally, under the No Action Alternative the decommissioned hutdown ite would not be returned to a Greenfield condition and the land could not be further developed in a manner that would b most ben ficial to the local communities. These local conununities would b requir d to host the torage of SNF even if such action wa not the prefi rence of community memb rs. A listing of the currently decommissioned shutdown sites is provided in Table 2.1. l.

The No Action Alternative would not be supportive of the Nuclear Regulatory Commission's (NRC) rulemaking on the Continued Storage of SNF and the recommendations from the Blue Ribbon ommis ion on America' Nuclear Future to promot efforts to d v lop one or more consolidated storage facilities in the United State (U.S .). The No Action alternative would not meet the purpose of and need for the Proposed Action (BRC 2012, Chapter 5).

HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-1 31 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative Table 2.1.1:

DECOMMISSIONED SHUTDOWN SITES Site Countv State Big Rock Point Charlevoix County Michigan Connecticut Yankee Middlesex County Connecticut Crysta I River Citrus County Florida Kewaunee Kewaunee County Wisconsin Lacrosse Vemon Count-y Wisconsin Maine Yankee Lincoln County Maine Humboldt Bay Humboldt County California Rancho Seco Sacramento County California San Onofre San Diego California Trojan Columbia Cowlly Oregon Yankee Rowe Franklin County Massachusetts Zion Lake County 111 inois HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-2 32 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative 2.2 PROPOSED ACTION As describ d in Section 1.2, the Proposed Action is the iss.uance of an NRC license und r JO CFR 72 authorizing the construction and operation of a CIS Facility on approximately I 040 acres of land controlled by Holtec in Lea County, New Mexico. Tbe CIS Facility would receive, possess, and store S F containing up to 100,000 metric tons of manium (MTU ) of SNF.

2.2.1 Description of the Proposed Site The center of the proposed CIS Facility site (hereafter, "Site") is at latitude 32.583 north and longitude 103.708 west, in Lea County, 32 miles ea t of Carlsbad, New Mexico, and 34 mile west of Hobbs, New Mexico. Larger population centers are Ro well, New Mexico 74 miles to the northwest; Odessa, Texas, 92 miles to the southeast; and Midland, Texas, also to the southeast at 103 miles. The nearest international airport is Located between Midland and Odessa, Texas 98 miles to the southea t. The Site, which would be purchased by Holtec from the Eddy-Lea Energy Alliance (ELEA), i bordered by Federal and tate lands on aU sides (ELEA 2007, Section 2.1).

The Site which is situated 0.52 mile north of U.S. Highway 62/ 180, consists of mostly undeveloped land used for cattle grazing with the only boundary being a four-strand barb wire fi nee along the outh ide of the property until it near Laguna Ga tuna wh re it tmn outb to the highway. This fence i the boundary between two grazing allotment admini tered by the Bureau of Land Management (BLM). The majority of allotments are grazed year-round with some type of rotational grazing (ELEA 2007, Section 2.1 ).

As shown on Figure 3.1.3, the following facilities are situated on the Site:

  • A communication tower in the outhwe t corner of the Site;
  • A former producing gas and distillate well with associated tank battery is located near the communications tower;
  • A mall water drinker (live tock) i located along tbe aqueduct in th northern half of the Site;
  • Oil recovery facility (abandoned) that till ba tank and a ociated hardware left in place in the northeast comer;
  • An oil recovery facility with tanks and associated hardware still in place in the far southeast corner (ELEA 2007, Section 2.1 ).

No water wells are located on the Site. However, the Site has been associated with oil and gas exploration and development with at lea t 18 plugg d and abandoned oil and gas wells located on the property. However, none of the e plugged and abandoned oil and ga well are located within the area where the ISFSI would be located or where any land would be disturbed and they are not expected to affect the construction and operation of the CIS Facility. The plugged wells are e ti.mated to be 30-70 years old. It is po ible that hydrocarbon contamination exi t at the Site as a re ult of these past practice (ELBA 2007, Appendix 2G). There are no active well on tbe Site and there are no plans to use any oftbe plugged and abandoned wells on the Site.

Land uses in the area are limited to oil and gas exploration and production, oil and gas related services industries, livestock grazing, and limited recreational activity. The only nearby residents HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-3 33 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative are ranchers that occupy several ranches as close as 1.5 miles away. A larger transient population exists in the form of potash mine workers, oil field workers, employees of an oil field waste treatment facility and an industrial landfill. One restaurant is nearby (3.5 miles) that serves travelers on U.S. Highway 62/ 180. The nearest population center is the village of Loving, New Mexico, 30 miles to the southwest (ELEA 2007, Section 2.1).

Lands within 5 miles of the Site are privately owned, state lands, or BLM lands. Land use within 5 miles of the Site falls into two categories; livestock grazing and mineral extraction. The nearest re idence to the Site i located at the Salt Lake Ranch 1.5 miles north of the Site. There are additional residences at the Bingham Ranch, 2 mile to the south, and near the Controlled Recovery Inc. complex, 3 miles to the southwest. There is an average population of less than 20 residents among five ranche within a five mile radiu . Thi i a population den ity ofle than five re ident per quare mile (ELEA 2007 Section 2. J).

Within 50 mile of the Site, except for the communities located in the area, the land use and ownership is essentially the same as within the 5 mile radius. Along with the mining, grazing, and oil/gas activity, agricultur is a major activity (ELEA 2007, Section 2.1 ).

An industrial railroad lies 3.8 mil s to the west and a spur would have to be construct d to serve th Site. The railroad cwTently s rv s local potash mines by tran po,ting ore to r fineries and finished product to markets, refineries and the agricultural sector. Con truction would be across BLM lands. Construction of a railroad spur would not be inconsistent with agency land use, although additional National Environrn ntal Policy Act (NEPA) analysis would likely b requir d for a right-of-way (ROW) on Federal lands. The con truction route would be relatively level and would not have to cross major highways. Similarly, a new roadway of approximately one mile in length i propos d to be constructed to the Site from U.S. Highway 62/180. Construction would be aero BLM land and would not be incon i tent with agency land u e, although additional NEPA analysis would like ly be required for a ROW on Federal lands (ELEA 2007 Section 2.1).

Electric power is available from both the north and south. Power lines and a substation would be needed to serve the Site. The lines would be expected to be brought in from the outh a distance of one mile to the center of the Site. There are everal exi ting ROW on the Site. The e existing ROW include pipelines road well pad , power lines a telephone line, and a communications tower (ELEA 2007 Section 2.1).

The major roads in the area consist of county and state roads interconnecting the various population centers. U.S. Route 285 runs south to 1101th along the Peco River. U.S. Highway 62/180 run southwest to the northeast through Carlsbad and Hobb , New Mexico. U.S. Route 82 travels west to east from Artesia through Lovington, ew Mexico. U.S. Route 380 traverses west to east from Roswell through Tatum, New Mexico (ELEA 2007, Section 2.1).

2.2.2 Description of the Facility The CIS Facility would utilize the Holtec International Storage Module Underground MAXimum Capacity (HI-STORM UMAX) t chnology (c rtifi d in NRC docket number 72-1040), which i a dry, in-ground torage ystem that store a hermetically-sealed cani ter 1 containing SNF in any 1 Throughout this ER, the term "canister means an all-welded vessel containing SNF that has been qualified to erve a a confinement boundary under the rules of IO FR 72. The more general term *'canister" is generally used herein in pl ace of the terms "multi-purpose canistc1"' ("MP ") and "d1y storage canister" ( D "). A cask, which also provides shielding, can also be p Iace ct 11110

  • a WM HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-4 34 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative number of Vertical Ventilated Modules (VVM). At full build-out, the CIS Facility would contain 10,000 VVMs that would be constructed in 20 phases over approximately 20 years, with a total disturbance of approximately 330 acres of land. Figure 2 .2.1 pre ents an aerial view of the CIS Facility. The IS Facility includes:

  • ill-STORM UMAX SNF torage unit licensed under IO CFR 72;
  • Ca k Tran fer Building where ca ks would be brought in and pr pared for canister placement in permanent storage in the HI-STORM UMAX VVMs;
  • Security Building;
  • Administration Building;
  • Railroad spur and Site access road* and
  • Construction laydown area that would contain an equ ipment storage building and a concrete batch plant.

Figure 2.2.2 pre ents the CIS Facility layout and Figure 2.2.3 presents details of the building layout on the Site. More detailed descriptions of the facility component , as well as additional de ign featmes, can be found in Chapter 1 of the SAR (Holtec 2017).

2.2.2.1 ID-STORM UMAX SNF Storage System Currently, the NRC ha licen ed and approved SNF torage ystems owned by Holtec, AREVA, NAC International (NAC) and EnergySolutions. Each of these sy tem is engineered to safely store spent fuel for periods of up to 50 years or longer and this time can be extended almost indefinitely through rigorous inspections, aging management programs, maintenance, and re-licen ing. SNF i stored horizontally in the AREVA sy tern and vertically in the Holtec, NA , and EnergySolutions systems The HI-STORM UMAX (illustrated in Figure 2.2.4) ha all the safety attributes that are attributed to in-ground storage, such as enhanced protection from incident projectiles and threats from extreme environmental phenomena such as hurricane , tornado borne mis ile , earthquakes, t unami fires, and explo sions. The HI-STORM UMAX has been engineered to :

  • minimize the extent of handling of the SNF;
  • minimjze do e to operator during loading and handling;
  • r quire minimal ongoing surveillance and maintenance by plant staff;
  • facilitate SNF transfer of tbe loaded cani ter to a compatible transport ov rpack for transpottation (Holtec 2017, Section 1.2.1).

The HJ-STORM UMAX i designed to be fully compatible with all HT-TRAC tran fer casks and canisters previously certified for storage by the NRC. The proposed Holtec H1-STORM UMAX Storage System at the CIS Facility would be capable of storing the SNF :from all existing SNF storage sy tern , and would be the only licens d technology with thi univer al capability (Holtec 2017, Section 1.2. 1). Because the storage cavity of HI-STORM UMAX is sufficiently large to accommodate every canister type in use in the United State at this time, utilizing the Holtec HI-HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-5 35 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative STORM UMAX Storage System wou ld allow removal of any SNF from existing reactor sites as well as the decommissioned shutdown sites per the Department of Energy's (DOE's) goal presented in Strategy for the Management and Disposal of Used Nuclear Fuel and High Level Radioactive Wa te (DOE 2013, pg. 6).

Tbe CIS Fac ility, when complete ly fin ished, would contain approximately 10 000 VVMs that would eacb store one canister of SNF. Each pbase wou ld consist of constructing 500 units witb concrete approach aprons that surround two individual 250 units HI-STORM UMAX ISFS1 Pads.

The HI-STORM UMAX y tern wou ld tore the SNF underground, to a total depth of approximate ly 22.5 feet ( ee Figure l.2.2(a) in the SAR [Holtec 20 17]). The tran fer cask is required for shielding and protection of the SNF during loading and closure of the canister.

2.2.2.2 Support Foundation Pad The Support Foundation Pad (SFP) is the underground pad w hich supports the HI-STORM UMAX VVM (Figure 2.2.5). The SFP on which the VVM re t mu t be de igned to minimize long-term settlement and mu t have sufficient strength to upport the weight of all the loaded VVM during long-term torage and eatthquake cond itions. Becau e of its und ergro und staging in HI-STORM UMAX, tip-over of the VVM in storage is not possible. To exploit the biological shielding provided by the urrounding oil ubgrade, the cani ter i entirely ituated well below the top-of-grade level (Ho ltec 2017, Section 1.2.3). The open plenum above the cani ter also acts to boost the ventilation act ion of the coolant air. Because the VVM is rendered into an integral part of the subgrade, it cannot be located to ai1other ISFSI ite. It al o cannot be lifted and, therefore, is not subject to the potential for a handling accident (Holtec 2016b ection l. 2.3).

Steel, concrete, and the subgrade are the principal hie lding material in the HI-STORM UMAX.

The stee l and concrete shielding materials in the clo ure lid provide add it iona l gamma and neutron attenuation to reduce dose rates. Steel and lead are the principal shie lding materials in the HI-TRAC transfer cask. The combination of these shielding materials ensures that the radiation and expo ure objective of 10 CFR 72.106 and "a low a rea onably achievable" (ALARA) are met (Ho ltec 2016b, Section 1.2.3.1).

2.2.2.3 Cask Transfer Building The Ca k Tran fe r Building i where ca k would be brought in and prepared for permanent storage in the VVMs. The building, which would be approximately 400 feet long by 150 feet wide ai1d wo uld have a height of approximate ly 60 feet, would be south of the SFPs inside the Protected Area ( ee Figw*e 2.2.2 and 2.2.3). The Ca k Tran fer Building would likely contain two bay in a single building, but there is a pos ibility that the final de ign could contain multiple bays in multiple buildings for contingency or increased operational capacity. In either event, the foo tprint oftb Cask Transfer Building would not be expected to chang . The ask Transfer Building would be the tallest structure at the CIS Facility (Holtec 20 16a). The Cask Transfer Building would contain a service crane and gantry crane, which would run a long independent rails. OnJy the gantry crane would be used to move ca ks.

Rail cars would nter the east side of the building and casks would be unloaded by the gantry crane. After unloading, rail car would xit the Ca k Tran fer Building on the ea t ide of the building. Along the rail line, inside the Cask Transfer Building, wo uld be space fo r ca k staging HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-6 36 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative and transpo1ter loading. Once the transporter is loaded, it would exit the building and proceed to the appropriate storage module at the HI-STORM UMAX ISFSI Pad.

Preventative maintenance would be performed on a regular basis on the cranes, transfer equipment, shipping ca k , and other equipment in thi building. Additional torage would be provided for temporary stag ing of impact limiters and ca k *, as well as storage for maintenance tools and supplies. The Cask Tran fer Building would also include waste management areas and chemical storage areas for cleaning supp lies needed to support activities at the CIS Facility. A small storage building (55 feet by 75 feet) would be located northwest of the Ca k Transfer Building inside the Protected Area.

2.2.2.4 Security Building and Administration Building The Security Building would be located ea t of the Cask Tran fer Building and would be pa,t of the Protected Area (see F igure 2.2.2 and 2.2.3). The single-story building would be approximately 100 feet long by 100 feet wide. Included in ide the building would be the surveillance and monitoring station for the Central Alarm Station, access control, and the armory. Security per onnel would monitor sen ors and intru ion alarms, control employee access, proce s visitors into the CIS Facility, and control rail and vehicle access t o the CIS Facility facilities. A parking lot would be located east of the Security Building outside the Protected Area.

Th ingle- tory Administration Building, approximat ly 100 fe t long by 100 feet wid , would be outside the Protected Area, east of the parking lot (see Figures 2.2 .2 and 2.2.3). It wou ld contain offices for operations, maintenance, and material control personnel; administrative functions related to proces ing hipments; emergency equipment and operations; communication and tracking center/facility; training and vi itor center; health physic area; records torage; conference room; break room; and restroom facilities.

2.2.2.5 Railroad Spur and Site Access Road The CIS Fac ility would be serviced by a railroad pur and acce s road as discussed in Section 2.2.1 and as shown on Figure 2.2.1.

2.2.2.6 Concrete Batch Plant Holtec intends to construct a concrete batch plant to facilitate storage module construction and future expansion of the Site. An onsite batch plant would provide operational efficiencies by producing caner t onsit , rather than transporting it to the Sit . The batch plant would b located north of the parking lot outside of the Protected Area ( ee Figures 2.2.2 and 2.2.3).

2.2.2.7 Waste Management The CIS Facility would be designed to minimize the volumes ofradiological and non-radiological waste generated during operation . Disposal plans, waste minimization practices, and related environmental in1pact are discus ed in Section 4.13 of this ER.

2.2.2.8 Construction Process for CIS Facility A summary of the construction process is described below. A more detailed explanation, including drawings, are provided in the SAR (Holtec 2017) .

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative The location for the Phase 1 ISFSJ would be prepared by excavating a pit that would house the SNF canisters in the VVMs. Once the excavation pit is completed, the subsurface would be compacted/proof-rolled to en ure a stable surface for concrete pours. After surface preparation, a mud mat (or leveling lab approximately 3 inches in thickness) would be poured to en ure there is an even surface to pour the HI-STORM UMAX SFP. Fonnwork would then be erected and reinforcing steel would be staged for the SFP concr te pour, follow d by the actual concr t pour it elf ( o ltec 2016a).

Once the SFP i poured, the avity oclosure Cootaioer (CEC) would be taged and leveled u ing de igned leveling bolts. Upon completion of the CEC leveling proce , formwork would be erected to grout the CEC baseplates in place, followed by the actual grouting process itself. The Self-Hardenjng Engineering Subgrade (SES) Layer, compo ed of Engineered Backfill, Controlled Low Strength Material (CLSM) or Lean Concrete, would be installed to the appropriate elevation and the top smface would be prepped for the top slab or ISFSI Pad. After the concrete is poured for the ISFSI Pad, the HI-STORM UMAX y tem would be complete (Holtec 2016a).

Each HI-STORM UMAX ISFSI Pad would be surrounded on up to four sides by an Approach Apron, which would be a concrete pathway approximately 35 to 40 feet in width. The Approach Apron would allow the Vertical Cask Transporter (VCT) to rotate appropriately and navigate the HI-STORM UMAX CECs and download the SNF canisters in each CEC (Holtec 2016a).

2.2.2.9 Operation of the CIS Facility A high-level detail of the operational process is described below. A more detailed explanation, including drawing , i provided in the SAR (Holtec 2017).

Shipping casks containing canisters would arrive via rail car, or possibly heavy haul trailer, and operations would be similar for either tran po11 system. Upon arrival, ecurity per onnel would perform an initial receipt inspection of the cask prior to transport into the Protected Area. The shipping cask would then be transported into the Cask Transfer Building and a receipt inspection of the cask by radiological per onnel would be conducted. The in pection would include initial radiological surveys and an examination of the integrity of the shipping container. The cask would then be transferred to a receiving pad using the movable gantry crane. The shipping cask lid would be removed in the Ca k Service Area.

In what follows, th acronym VCT (for vertical cask transporter) is used to denote the hauling machinery (Holtec 2016a). (Note: a ID-PORT, which i a Holtec trade name for an engineered Low-Profile Transporter, could al o be used to transpo11 the cask to the ISFSI pad).

The cask would be transported to the ISFSI storage pad using the VCT. The cask would be aligned with the storage location, the lower lid of the shipping cask would be removed, and the cask would be lowered onto the torage pad u ing the rai ing/lowering capability of the VCT and the canister would be lowered into the VVM. The hipping ca k would be di connected and removed from the storage site and the lid and other necessary components on the storage pad would be installed using the VCT. Finally, the VCT, with the shipping cask, would be returned to the Cask Transfer Building (Holtec 2016a). Figme 1.2.3 in the SAR (Holtec 2017) illu trate the proce of loading a cani ter it1to the VVM.

HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-8 38 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 2: Alternatives Source : Hol tec 2017 Figure 2.2.1 : AERIAL VIEW OF CIS FACILITY (FULL BUILD-OUT)

HOL TEC INTERNATIONAL COPYRlGHTED MATERIAL HI-2 167521 I Rev. 4 2-9 39 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative

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Figure 2.2.2: HI-STORE CIS FACILITY LAYOUT HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2- 10 40 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 2: Alternatives I

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative Source : Holtec 20 17.

Figure 2.2.4: ILLUSTRATION OF ARRAY OF HI-STORM UMAX SYSTEM HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2 167521 I Rev. 4 2-12 42 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative Support Foundation Pad Source: Holtec 20 17.

Figure 2.2.5: HI-STORM UMAX ISFSI IN PARTIAL CUT-AW AY VIEW HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2 167521 I Rev. 4 2- 13 43 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative 2.3 Site Selection Process The process of identifying a site for the CIS Facility i rooted in a process that began in March 2006, when then-Secretary of Energy, Samuel W. Bodman, announced that DOE was seeking expressions of interest from the public and private sectors to propose and evaluate sites su itable for activitie under the Global Nuclear Energy Partnership (GNEP). GNEP was intended to clo e the nuclear fuel cycle by developing facilities to recycle SNF and reuse the usable constituents of the SNF to fuel other reactors and produce electricity. Under DOE's plan, communities and privat -public conso1tia w re encouraged to consider participation in th GNEP t chnology demon tration and submit ideas on how DOE hould best sol icit, evaluate and award site evaluation study contracts for the program (ELEA 2007, Appendix 2C).

In response, county officials in the southeastern New Mexico counties of Eddy and Lea, became awar of this oppo1tunity and aft r educating local lead rs and gaining community upport they dete1mined to pursue this opportunity. Both counties are home to sites which host complimentary facilitie , the Waste Isolation Pilot Plant (WIPP) site in Eddy County, and the National Enrichment Facility (NEF) which was being constructed in Lea County (BLEA 2007, Appendix 2 ).

The countie realized they would have a better chance to be se lected in this process if th y joined together and submitt d a response with a more r giona l persp ctive. In ord r to acl1iev this goal the counties formed a legal entity, ELEA, which could support the site study. ELEA had to determine which area in the region would be ideal to host the GNEP nuclear facilities. In order to do thi , ELEA d veloped a set of scr eni ng crit ria to apply to the prosp ctive sit s (ELEA 2007, Appendix 2C).

Site election for the GNEP nuclear facilitie was ba ed on the following minimum criteria specified by DOE:

  • Size: The area and linear dimensions of the site must accommodate one or both GNEP facilities. The proposed site must not be less than 300 contiguous acres for siting one faci lity and 500 contiguou acre for siting both facilitie .
  • Hydrology: The site mu t be ufficient to allow iting of the anticipated facilities above the I00-year flood plain.
  • Electricity Capability: There must be an e lectrical transmi ion line able to provide 13kV available within l O miles of the proposed site.
  • Population: The population density, including weighted transient population, averaged over any radial distance out to 20 miles ( cumulative population at a distance divided by the area at that di tance), doe not exceed 500 per on per quare mile.
  • Zoning: l f zoning regulation app ly to th propo ed site, the site mu t be zoned for heavy industrial/indu trial use. Alternatively, the applicant must demonstrate that the area could be zoned for heavy industrial/industrial use.
  • Road Access: The proposed site must be within 5 miles of a highway capable of supporting a load of 80,000 pound Gross Vehicle Weight.
  • Seismic Stability: The proposed site must be free ofrisk from significant seismic events.

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative

  • Water Availability: The proposed ite must have access to reliable upplie of water (BLEA 2007, Appendix 2C).

In developing the Proposed Action addressed in this ER, Holtec reviewed the eight criteria that were developed for the GNEP nuclear facilities and determined that electricity capacity and water availability were not as important as the other ix criteria becau e the CIS Facility would not require significant quantities of electricity or water. Ho ltec determined that the remaining six criteria were appropriate criteria to apply to siting the proposed CIS Facility. Holtec also determined that no additiona l criteria w r n cessary to apply to siting th proposed CIS Faci lity.

During the GNEP site election proce s the eight criteria were tran lated into 31 pecific ite screening factors that required evaluation in order to select the site that best meet all of the criteria.

The 31 specific screening factors are listed in Appendix 2C of reference ELEA 2007, which contains details regarding the site creening proces . Six sites were offered by ELEA for evaluation (see Figure 2.3.1) (BLEA 2007, Appendix 2C).

Four of the six site ranked about equally. Of these, Site l was selected because of the following favorable factors.

  • Private ownership of the land was considered to be an advantage from the standpoint of acqu isition for construction of the facilities .
  • Equal distance between the cities of Hobbs and Carlsbad optimizes access for housing, job , supplies and oth r upport.
  • Proximity to U.S. Highway 62/180 provide an advantage for tran porting nuclear material since thi highway i part of the tran portation route developed for hauling waste to the WIPP.
  • Federal lands south of Site 1 may be available for expansion of the facilities if needed (ELEA 2007, Appendix 2C).

Neither electricity capacity nor water availability were factor that affected the election of Site 1 for the GNEP nuclear facilitie .

On June 29, 2009, DOE announced the GNEP program wa cancelled because of a change in policy to no longer pursue domestic commercial SNF reprocessing, which was the primary focus of the prior Administration's domestic GNEP program (74 FR 31017). The cancellation was not the result of any site election-related reasons.

In considering the mo t appropriate site for the propo ed CIS Facility Ho ltec reviewed the ite select ion process and outcome described above for the GNEP nuclear facilities and determined that the selected site in the process (Site 1) would also be the best site for the CIS Facility (Holtec 2016a). onsequently, Holtec is proposing to locate the CIS Facility at that ite.

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ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 2: Alternatives LEGENO r-=*-..

I 1..- . -J I

POTENIAL PROJECTS S Source: ELEA 2007, Appendix 2C Figure 2.3.1: POTENTIAL SITES EVALUATED BY ELEA HOL TEC INTERNATIONAL COPYRlGHTED MATERIAL HI-2167521 I Rev. 4 2-16 46 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative 2.4 ALTERNATIVES CONSIDERED BUT ELIMINATED Alternatives to the propo ed de ign that alt r th de ign or the location or layout of the project were identified. Ultimately none were carried forward for detailed analy is. The range of reasonable design, location, and layout alternatives considered and the reasons for eliminating them from detailed analysis are presented here.

2.4.1 Design Alternative Currently, the NRC has licensed and approved SNF storage ystems owned by Holtec, AREVA, NAC, and En rgySolutions. Holt c has propos d to us its propri tary system to store SNF at the CJS Facility and use of its system is analyzed as part of the Proposed Action. A potential design alternative would be to use the AREVA, NAC, and EnergySolutions systems. Holtec considered this alternative, but rejected these y tem because Holtec's proprietary design is the only licen ed technology with the universal capability to store all SNF from a ll commercial reactor .

Consequently, a design alternative utilizing a different SNF storage system was not carried forward for detailed analy is.

2.4.2 Location Alternatives The site proposed for the CIS Facility in Lea County, New Mexico was identified through the process describ din S ction 2.3. Holtec supports the Blue Ribbon Commission's r commendation to only ite a CIS Facility in a state and community willing to host uch a facility. ELEA's succes in proposing the Lea County site for the GNEP program was predicated on the tremendous support provided by N w Mexico, the r gional and local communities in south ast rn New Mexico and Eddy and Lea counties. Holtec agree with the finding of the Blu Ribbon Comm is ion (BRC 2012, Chapter 6) that many of the failures to site nuclear and radioactive waste disposal facilities, including the proposed repository at Yucca Mountain, Nevada, are directly attributable to the failure to garner tbe upport of the host state and local communitie . Accordingly, Holtec adopted a site selection proce s geared to identify a ROI focu ed upon states and communitie that have expressed their willingness to host nuclear facilities.

As an indication of the community support for a project like the proposed CIS Facility in southea tern New Mexico, Holtec recognize the following nuclear facilities located within the general proposed area: WIPP, NEF, and the International Isotope Fluorine Production (IJFP) facility. All three of these facilities are located in southeastern New Mexico within approximately 40 miles of the proposed CIS Facility site.

The proposed CIS Facility site has the following attributes that lead to the conclusion that it is suitable for it intended purpose:

  • The topography of th land is relativ ly flat lending to effective intrusion det ction by camera survei !lance*
  • The water table i ufftciently below the bottom of the ubterranean HI-STORM UMAX system to preclude the possibility ofany groundwater intrnsion in the storage cavity spaces;
  • The land is fallow with limited vegetation to support cattl.e herds ;
  • The annual rainfall is meager requiring a modest water drainage infrastructure; HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-17 47 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Faci lity Environmental Report hapter 2: Alternative

  • The tornadic activity in the region is infrequent. The trength of the tornadoes is bounded by the national meteorological tomadic data which has been used to define the Design Ba is Mi iles for both the HI-STORM FW system and the I I-STORM UMAX y t m.

Therefore, the torage 'ystem's ability to withstand the site pecific tornados i axiomatically satisfied;

  • There are no active volcanoes in the area;
  • The area has a stable tectonic plate profile. As a result, the 10,000 year-return earthquake for the site is quite modest and well below the range for which HI-STORM UMAX as lie n ed in Dock t 72-1040;
  • There are no chemical plant in the area that would pew aggre ive pecie into the environment. As a re ult, the ambient air i non-aggres ive and a long service life of the stored stainless-steel canisters can be predicted with confidence;
  • There is no air force base or a major civilian airport in the vicinity of the site and the area is osten ibly not u ed for any aerial training exercises by the U.S. military;
  • The local area has a well-developed rail road infrastructure. The length of additional rail spur required for the site in less than l O mile ; and
  • By agre 111 nt with th applicable third parties, the oil drilling and pho phat xtraction activities have been proscribed at and around the site and would not affect the activities at the site.

In addition to the community support for the proposed CIS Facility, there is a significant amount of data associated with the proposed ite that was dev loped as part of the GNEP program.

Pursuing a different site alternative could increa e costs unreasonably and could re ult in delays to the licensing, constmction and operation of the proposed CIS Facility, thus preventing Holtec from achieving the stated purpose and need. Consequently, the proposed site in Lea County is con idered to be the uperior ite location and no other location could rea onably erve a the location for the CIS Facility site. Thus, other alternative site locations were eliminated from detailed analysis.

2.4.3 CIS Facility Layout Alternatives Tbe layout of the CIS Faci lity on the Site was influenced by the following factors: (J) Site access (2) regulatory requirements, (3) operational efficiencies, and (4) environmental, safety, and security consideration . These factors affected the layout of the CIS Faci lity as fo !lows:

  • Site ace s con iderations (for both workers, material , and SNF deliverie ) dictated that supp01t faci lities (i.e. , Security Building Admini tration Building, and the Ca k Transfer Building) be located on the southern boundary of the Site.
  • Regulatory requirements (10 CFR 72.106) required any faci lity or storage location for SNF to be no closer than l 00 meters from the Protected Area boundary.
  • Operational efficiencies and worker dose consideration dictated that the ISFSI Pad be located in clo e proximity to the Cask Transfer Building. Additionally, Pha e 1 storage locations for SNF were located at the no1theastern most point of the ISFSI Pad in order that HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-18 48 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE IS Facility Environmental Report hapter 2: Alternative subsequent phases of construction would have minimal interference with ongoing operations.

  • Environmental, safety, and security considerations dictated that the ISFSI Pad be a compact design to minimiz infrastructure requirement , with minimal land disturbance with.in the Protected Area, and with clear ight lines around the perimeter. A compact de ign would also minimize any potential impacts related to ecological and cultural resources, and would minimize ground disturbance and air quality impacts.

Based on these factors, the layout presented in Figure 2.2.2 was developed and was deemed to repre ent the optimum configuration for th CIS Facility (Holt c 2016a).

2.5

SUMMARY

COMPARISON OF THE ENVIRONMENTAL IMPACTS OF THE ALTERNATIVES Thi comparison of potential environmental impacts is based on the information in Chapter 3, Affected Environment, and analyses in Chapter 4, Environmental Impacts. Its purpose i to pre ent the impacts of the alternative in comparative form. Table 2.5. l present the compari on ummary of the environmental impacts for the Proposed Action and the No Action Alternative.

HOLTEC INTERNATIONAL COPYRIGHTED MATER1AL Hl-2167521 I Rev. 4 2-19 49 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 2: Alternatives Ta ble 2.5.1:

SUMMARY

COMPARISO OF THE ALTERNATIVES Resource Proposed Action o Action Alternative*

Land Use Land disturbance of 330 acres during construction of the full Short-term continued at-reactor storage in a S F or lSFSI would (10,000 cani ter) CIS Facility, with an in ignificant los of not requ.i re di turbance of any new land or re ult in operational or grazing area. Land u es would remain compatible with maintenance activitie that would change land use. Any surrounding area and land use plan . o impacts on offi ite land construction required for long-tenn torage would impact a mall u e. fraction of the land committed for a nuclear ower lant.

Visual and Scenic The Hl-STORM UMAX i a particularly low-visibility SNF No change to the visual profile are likely to occur as a result of Resource storage sy tern compared to aboveground y tern . CTS Facility the continued operation and maintenance of the exi ting SNF pool would be vi ible only from fairly clo e vantage point and would and at-reactor TSFST. In the long-tem1, periodic construction, re ult in an insignificant impact to vi ual and cenic re ources. replacement, and operation activities would not significantly alter The most vi ible tructure would be the Ca k Tran fer Building. the land cape of an TSFSI.

o chan

  • e to visua l resource mana ement (VRM) classification.

Geology and Soils Minimal impact limited to soil disturbance and a temporary Impact to oi l from mall spill and leak during operation and increase in oi l erosion at the CIS Faci lity. maintenance ofISFSis would be minor because of monitoring and environmental protection regulations. o new land would be di turbed for continued operation ofSNF pool and ISFSTs. Any construction required for long-term storage would have minimal impacts to soils on the small fraction of land committed for the facilities .

Ecological Minimal impacts would include a loss of grazing area and open Normal operations and replacement of ISFSI facilities would not Resources area for wildlife. There are no habitats for threatened and significantly affect the area available for terrestrial wildlife, and endangered species on the land proposed for the CIS Facility. would not adversely impact terrestrial en vironments or their associated !ant and animal s ecies.

Water Resources o impacts to surface water or groundwater. Proposed Site has Potential impact to urface water quality and consumptive use no floodplains or jurisdictional wetlands. from the continued operation of S F pools and ISFSis would be less than for normal plant operations. Continued storage ofS F could result in non-radiological and radiological impact to groundwater quality. Potential consumptive-use and water quality impacts from construction and operation of an ISFSI would be less intense than assumed for initial construction of these facilities.

HOL TEC INTERNATIONAL COPYRlGHTED MATERIAL HI-2167521 I Rev. 4 2-20 50 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 2: Alternatives Table 2.5.1:

S MMARY COMPARISO OF THE ALTERNATIVES Resource Proposed Action o Action Alternative*

Climatology, Temporary increases in hydrocarbons, particulate matter. and Air emission impacts from S activitie from spent fuel pools Meteorology, fugitive dust due to vehicle emissions, concrete batch plant and ISFSis during short-tenn torage would be substantially Air Quality, and operations, and ground disturbance. o substantial impacts smaller than air emissions during power generation. Any oise would occur and visibility would not be impacted. There are no construction required for long-term storage would result in minor sensiti e receptor (e.g., ho pita! , churches, and school ) within and temporary air emi sions. ormal operation and replacement 10 miles of the Site. oi e level would increa e during ofTSFST facilities would not generate signifi cant noise.

construction and during operation, but not to a level that would cause si ni ficant im act to nearb resident .

Cultural Re ource Minimal cultural resources were identifi ed during the ite- Becau e no ground-di. turbing activities are anticipated during the specific survey and potential impact are con idered low. To hort-tenn torage timeframe, impacts to cultural resources minimize any potential impact on cultural re ources accidental as ociated with continued operation and maintenance would be di covery procedures would be in place. mall. If construction ofa replacement of the 1SFST occurs in an area with no cultural resource present or con truction occur in a previously disturbed area that allow avoidance of cultural r ources then impacts would be small. By contra t a moderate or large impact could result if cultural resources are present at a site and, because they cannot be avoided, are impacted by ground-disturbin activities durin the Ion -term timeframe.

Socioeconomics Construction and operation would resu lt in positive direct and A small number of workers would be required to maintain and and Environmental indirect economic benefits with.in the ROJ. There would be monitor spent fuel pools and an at-reactor ISFSI, tax payments to Justice minimal demands on local social resources and infrastructure to local jurisdictions would continue, and there would be no meet housing and other social infrastructure needs. With regard increased demand for housing and public ser ices. Any to environmental justice, no significant disproportionate impacts construction required for long-term storage would be small and to low-income or minority persons are anticipated. there would be no increased demand for housing and public services. Minority and low-income populations are not expected to experience disproportionately high and adverse human health and environmental effects from the continued storaoe of SNF.

Transportation Increase in traffic from heavy haul vehicles and construction A low volume of traffic and shipping activities is expected with (Non-radiologica l) workers would not change traffic patterns. Operational work the continued storage of S F in pools and at-reactor ISFSls. There force of less than 40 personnel and 15 security personnel would ould be sma ll workforce requirements for continued storage and not change traffic on area roads. aging management activities (relative to the power plant workforce.

HOL TEC INTERNATIONAL COPYRlGHTED MATERIAL HI-2167521 I Rev. 4 2-21 51 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 2: Alternatives Ta ble 2.5.1:

S MMARY COMPARISO OF THE ALTERNATIVES Resource Proposed Action o Action Alternative*

Transportation Transportation would result in 172 person-rem dose annually A low volume of traffic and shipping activities is expected, ith (Radiological) during normal operations. The radiological accident risks to the the continued storage of S in pools and at-reactor ISFSis. There population would be approx.imately 5.9 person-rem, which is would be small worktorce requirements for continued storage and small. The larger impact would be as ociated with potential aging management activities (relati e to the power plant traffic fatalities. Stati tic-ally, 2.9 fatalitie from traffic accidents workforce) and a low frequency of upply shipments and would be expected over the 20-year tran portation period. shipments oflow-level radiological waste (LLRW) from activiti ,

Becau e the ri k are for the entire population of individual continued dry cask st rage operation , and ISFSI replacement along the transportation routes the ri k to any ingle individua l activitie .

would be sma ll.

Infra tructure o notable impact on infra tructure re ources* existing Not evaluated in NUREG-2175 but continued SNF storage is not infra tructure provider of potable water and electricity have expected to result in any additional infra tructure demands.

ade uate ca aci to u ort the CIS Facili .

Waste CIS Facility would generate only minimal amount of hazardous Continued at-reactor torage ofSNF would generate much less Management wa te and a mall amount of LLRW from contamination survey LLRW mixed, and nonradioactive waste than an operating rags, anti -contamination garments, and other health physics facility and licen ee would continue to implement Federal an d materials. With regard to non -hazardous waste wa te generated State regulation and requirements regarding proper management would be commensurate with typical office/personnel waste and disposal of\l astes. The replacement of the ISFSI, repackaging generation rates. of SNF canisters and construction, operation and replacement of the ISFSI would generate a fraction of the LLRW generated durin reactor decommissionin .

Human Health As presented in ection 4.12.1, there would be no chemical Not evaluated in UREG-2175, but continued SNF storage is not ormal Operations substances, airborne particulates, or gases or liquid effluents that expected to result in any additional non-radiological impact to (Non-radiological) could contribute to offsite exposures. Worker impacts were health. Any construction required for long-term storage would be estimated as follows: 0.007 fatalities and 1.8 non-fatal injuries expected to have similar impacts as presented for the Holtec CIS annually during construction; and 0.005 fatalities and 1.3 non- Facility.

fatal in *uries annual! durin o erations.

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ATTACHMENT 5 TO HOL TEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 2: Alternatives Ta ble 2.5.1:

S MMARY COMPARISO OF THE ALTERNATIVES Resource Proposed Action o Action Alternative*

Human Health, As pre ented in ection 4.12.2, potential impacts to the public Annual public and occupational doses would be maintained below ormal Operations and workers would be small. The dose to the MEI would be 2.5 the annual dose limits established by 10 CFR Part 72 for the (Radiological) rnrem/year. The average exposure for the construction and public and IO CFR Part 20 for occupational personnel. Licensed operations workforces would be 0.25 rem/year and the exposure facilities would also be required by these regulations to maintain for the high-expo ure workers i estimated to be le than 0.5 an ALARA program to en ure radiation doses are maintained a rem/year. Thi maximwn dose of0.5 rem/year i a factor often low a is rea onably achievable.

below the 5 rem/year total effective dose regulatory limit s ecified in 10 CFR 20. I 20 I a for occu ational ex osure.

Human Health The po tulated design basi accident include hazards from The po tulated design basi accident include hazards from natural (Accident ) natural phenomena, uch a earthquakes floods, tornadoe , and phenomena such as earthquakes, floods tomadoe and hurricane ; and fuel handling-related accident . The results hurricanes* hazards from activities in the nearby facilities; and fuel demon trate that the Ht-STORM UMAX torage *y tern can handling-related accident . The environmental impact of these withstand the effects of all credible and hypothetical accident po tulated accidents involvi ng continued storage of SNF are mall conditions and natural phenomena without affecting its afety because all important afety tructures, systems and component function . There are no credible mechani ms (either from off- involved with the SNF storage are de igned to withstand these nonnal operation or from hypothetica l accidents) that would design basi accidents without compromising the afety function .

re ult in the release of radioactive S F contents, including The probability-weighted environmental impact of severe airborne radioactive material, into the environment. accidents is also small because of the low probability that such events would occur.

a The No Action Alternative impacts are summarized from REG-2157 (NRC 2014b ). In that document, NRC evaluated the continued storage of SNF for: (I) a short-term period (e.g., 60 years after the end of a reactor's licensed life for operation); (2) a long-term period,~ hich NRC defined as "an additional I00 years after the hort-term timeframe for a total of 160 years after the end of a reactor ' licen ed Ii fe for operation"; and (3) indefinite storage. For purposes of this ER, the short-term and long-term torage impacts would best match the 120 years storage period for the proposed Holtec CIS Facility. Consequently, tl1e impacts of short-term and long-term storage are included.

HOL TEC INTERNATIONAL COPYRlGHTED MATERIAL HI-2167521 I Rev. 4 2-23 53 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 CHAPTER 3: AFFECTED ENVIRONMENT

3.0 INTRODUCTION

This chapter provides the context for understanding the environmenta l consequences described in Chapter 4 of this Environmental Repo11 (ER). The affected environment serve as a baseline from which any environmental changes that wou ld result from implementing the alternatives can be evaluated. The baseline conditions are the currently existing condition . The affected environment at the proposed Consolidated Interim Storage (CIS) Facility site is described for the following area : land use; visual and scenic resources; geology and soils; water resources; ecological r ources; c limato logy, meteorology air quality and noise* cu ltura l resources; socioeconomics and environmental justice* transpottation; site infrastructure; waste management; and public and occupational health and safety. This chapter accurately reflects the current conditions at the site and it SlUTOund i.ng . Data ource u ed are generally Jes than 4 year old

  • ju tifications for older sources can be found in Appendix A.

3.1 LAND USE This section describes the physical location and characteristics of the proposed CIS Facility site and the current land u es. The s ction also discu ses land u es of off-site areas and th reg ional setting. The Site for the CIS Facility is located in so utheastern New Mexico in Lea County, 32 miles ea t of Carlsbad, New Mexico, and 34 miles west of Hobbs, New Mexico (Figure 3.1. l ).

Lea County is approximately 2.8 million acres in size. Property ownership is 17 percent Federal government, 3 l percent tate government, and 52 percent private. The Federally-owned land is primarily located in the southwestern portion of the county, the state-owned land is predominately located throughout the middle, and the privately owned land primarily extends from north to south in the county' s ea tern portion. Large tracts of land in Lea County are privately owned by farmers rancher , oil, gas, and mining companies. Urbanized area near cities and towns include ownership of smaller tract of land for residential municipal, and commercial purposes. Approximately 93 percent of Lea County is used as range land for grazing, and approximately 4 percent is used for crop farming. Urban area and the roadway y tern account for the remaining land u e. Mo t of the land actively farmed in Lea County is irrigated (UFP 2009 , Section 3.1.1 ).

The CIS Fac ility would large ly be constructed and operated on an approximately 119.4-acre initial footprint within an approximately 1,040-acre parcel within United States (U.S.) Depaitment of Interior (DOI), Bureau of Land Management (BLM) Section 13. As hown on igure 3.1. 2, almost all of the land immediately surround ing the Site i owned and managed by the BLM. Larger population centers are Roswell, New Mexico, 74 mjles to the northwest; Odessa, Texas, 92 miles to the southeast; and Mid land, Texas, also to the southeast at 103 miles. The nearest internat ional airport i located between Midland and Ode a Texa 98 mile to the outhea t.

3.J .1 Onsite Land Use The CIS Facility proposed ite con i t of mo tly undeveloped land (See Figure 3.1.3) primarily u ed for cattle grazing with the only boundary being a four- trand barb wire fence along the outb HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-1 54 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 side of the property until it nears Laguna Ga tuna where it tmn south to the highway (ELEA 2007, Section 2.1.1.1 ). This undeveloped land contains sparse crub-brush vegetation with a relatively flat topograp hy, that gradually slope to the north (GEi 2017, Section 2.1).

This fence i th bow1dary betwe n two grazing allotments administered by the DOI, BLM. The majority of allotments are grazed year-round with some type of rotational grazing. The Site is comprised of 1,040 acres of patented land spread across three sections of land running west to east.

Rangelands comprise a substantial portion of the CIS Facility proposed site and provide forage for liv stock. Pastm*e rotation, with som of the pa tures being rested for a least a p01tion of th growing sea on, is tandard management practice for grazing allotments. Vegetative monitoring studies to collect data on the utilization of the land, and the amount of precipitation by pasture from each study allotment are conducted annually on Federal land to compare production with con umption. Current ly the BLM permit nine animal unit month per 640 acres (ELBA 2007, Section 2.1.2.4). An animal unit month is one cow and one calf for one month. Becau e the Site i privately held, it does not fall under the BLM range management rules, although the rules apply to mo t of the adjacent land that are managed by the ame rancher. The entire Site i used for grazing (ELEA 2007, Section 2.1 .2.4).

With regard to potential future driUing on the Site, Ho ltec has an agreement with Intrepid Mining LLC (Intrepid) such that Holtec controls the mineral rights on the Site and Intrepid will not conduct any pota h mining on the Site. Additionally, any futme oil drilling or fracking beneath the Site wou ld occur at greater than 5,000 feet depth, which en ure there would be no ubsidence concern (Ho ltec 20 16a).

3.1.2 Surrounding Land Use Surrounding the Site are BLM lands and two small parcels of state land . The surface estate i privately owned (ELBA 2007, Section 2.1.1.1 ), and the ubsurface minerals are owned by the state of New Mexico. Mineral rights available for leasing are potash and oil/ga . There are severa l existing rights-of ways (ROW ) in th Site. Th se existing ROWs include pip lines, road well pad , power lines, telephone lines, and a communications tower (ELEA 2007, Section 2.1.1 . 1).

The oil and gas industry is well establfahed in the area surrounding the Site, with producing oil and gas fields, support services, and compressor stations. Nearly all phases of oil and gas activities have occurred in the locality .. These pha e include ei mic exploration, exploratory drilling, field development (compri ed of production and injection well ) and other undry activities a sociated with hydrocarbon extraction. One gas well is present on the Site along with numerous plugged and abandoned w lls. Further oil and gas development is not allow d by the New Mexico Oil Conservation Divi ion (OCD) due to the pres nee of potash or on the Site.

Land within 6 mile of the Site are privately owned tate land , or BLM land . Landu e within 6 miles of the Site falls into two categories: livestock grazing and mineral extraction. Only one small area is not being leased to grazing (potash tailings dam). There are five ranch headquarters located in the area which are associated with five of the grazing allotments.

Mineral extraction in the area con i ts of w1derground pota h mining and oil/gas extraction. Both indu tries upport major facilities on the surface, although mining surface facilities are confined to a fairly small area. Intrepid owns both mines located within 6 miles of the Site. The Intrepid HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-2 55 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 North mine, located to the west, is no longer actively mining potash underground. However, the surface facilities are still being used in the manufacture of potash products. The Intrepid East facility is still mining its underground potash ore (ELEA 2007, Section 2.1.2.1 ).

The nearest residents to the proposed CIS Facility site are located at the Salt Lake Ranch, 1.5 miles north of the Site. There are additional residences at the Bingham Ranch, 2 miles to the south and at the Controlled Recovery Inc. complex, three miles to the southwest.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HJ-2167521 I Rev. 4 3-3 56 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 CISF Site Sour c: BLEA 2007, Section 2.1 .1.

Figure 3.1.1: LOCATION OF CIS FACILITY PROPOSED SITE HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-4 57 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040

00) IIOI oc, lDI 001 008 009 011 o,, 001 OOI I

011 016 018 011 020S ,..,.,

032E =---t 021 021 019 020 011 OJII 027 OJO 028 /

OD 03" Ill! 032

- R.. llM -M1,'tdlotl1

~HI Road f.ttvlll* D 111,1 rowi*'upt

- E.tf11,gPl~tM,t $1,t11 n ~WSl'@O

- r*1tp~on1un1 C ] 11j,j_Cwn1t, C£HMM ELlASlt t 11.H

-=--=--

U ,,

-== = - -Mitt Source: CEl-lMM 2016.

Figure 3.1.2: SURFACE LAND OWNERSillP CN THE VICINITY OF THE CIS FACILITY PROPOSED SITE HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2 16752 1 I Rev. 4 3-5 58 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 0

ote: 'orth-South distance of Site is appro=tely l COIIIWlllll oo Tower .5,JBO feet. East-West dislallCe is approximately i 11 870 fee -~-

Cl Ptoduczig Well / Oil RKancy Faalily

. ~

CJ Oli b=or Fllolhy (AbGndaood)

  • Waltr DnDktr (1.1\..Stoa)

Source : EL A 2007, ection 2. 1.1.1.

Figure 3.1.3: CIS FACILITY SITE BOUNDARIES HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2 16752 1 I Rev. 4 3-6 59 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 3.2 Visual and Scenic Resources The proposed CIS Facility site exhibits a very nonde cript appearance with open, vacant land. This is common for areas in the Querecho Plains of southeastern New Mexico. Surrounding Landscapes are similar in appearance with the exception of man-made structures located at neighboring properties. The only activitie currently occurring at the Site are cattle grazing and oil and gas production (ELEA 2007, Section 2.1.3).

The following structures are situated on the Site (ELEA 2007, Section 2.1.1. l & GEi 20 I 7, Section

2) (See Figure 3.1.3):
  • A communications tower in the southwest corner of the site;
  • A producing well is located near the communications tower;
  • A small water drinker (Livestock) is located along the aqueduct in the northern half of the property;
  • Oil r covery facility (abandoned) that till has tanks and associated hardware left in place in the northea t corn t" and
  • An oil recovery facility with tank and a ociated hardware till in place in the far outhea t corner.

According to the DOI and BLM, vi ual resource con ist of landscape or visual character, and visual sensitivity and exposure. The BLM provides a means for determining vi ual values in their Yi ual Re ource Management (YRM) Manual 8410. Thi inventory-like sy tem of e valuation con i t of three determination : (l) Scenic Quality (2) Sensitivity Level Analy is, and (3)

Delineation of Distance Zones. Based on these categories the BLM places land into one of four vi ual resource inventory classe . Four Management objective have been established based on scenic quality, vi ual en itivity, and distance from key observation points. The e objectives (classes) describe the different degrees of modification allowed in the basic elements of the landscape. Classes I and 11 are the most valued, Class ill is of moderate value and Class IV is of least value.

Yi ual re ource management obj ctiv shave been d tennin d for all public land in th Carlsbad Re ource Area (BLM 1986, page 3-29). These objectives were derived from previous land u e planning and visual resource inventories for lands west of the Pecos River. The Site has been determined to be in the range of a Class N (BLM 1986, page 3-29, 3-31), meaning that level of change allowable to the charact ri tic land cape can be high and that the e change may dominate the view and be the major focus of viewer attention as demonstrated below.

Evaluation of the scenic quality of a landscape the visual sensitivity of that landscape to change and the distance of the landscape from a viewer determines the final YRM class. A discussion of each a pect of this evaluation follow .

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 3.2.1 Scenic Quality Scenic quality is a measure of the visual appeal of a tract of land. In the visual resource inventory process, lands are given an A, B, or C rating based upon the apparent scenic quality which is determined using seven factors. These factors include landform, vegetation, water resource features, color, adjacent scenery, scarcity, and cu ltural modifications (that either add to or detract from visual quality). The overall impression of an area composed of the elements above, is refen-ed to as the "visual character." Based upon this process, the Site received the lowest scenic-quality rating, ther are no r gionally or locally important or high quality view associated with the Site. This rating means that the level of change to the characteri tic land cape can be high and allows for the greatest level of landscape modification (ELEA 2007, Section 2.1.3.1 ).

3.2.2 Sensitivity Level Analysis Sensitivity leve ls are a measure of public concern for scenic quality. Public lands are assigned high, medium, or low sensitivity levels by analyzing the various indicators of public concern.

These type of indicators include type of users amount ofu e, public interest, adjacent land u e special area and other factors specific to the location.

Because the Site is located in a sparse ly populated area more inclined to be used for cattle grazing or oil and gas exploration and production, the sensitivity level analysis for this location was determined to be low (ELEA 2007, Section 2.1.3 .2).

3.2.3 Delineation of Distance Zones Landscapes are subdivided into three distance zones based on relative visibility from trave l routes or ob ervat ion points. The e three zone are foreground-middleground background, and eldom seen. The Site is not visible from any city, township, borough or identifiable population center.

The Site boundary is located one-half mile no1th of Highway 62/180. Visibility of the Site is confined to east and we t traffic on Highway 62/180 and i imilar from either direction.

Half of the Site lies within the foreground-middleground due to the Site exhibiting a slight crest in the center of the location. The remaining half of the Site lies in the seldom seen zone on the opposite side of the crest from the highway. Neighboring properties include various oil and gas well locations surrounding the Site, a restaurant one-and-a-half miles to the west of the Site, a hydrocarbon remediation land farm to the southwe t of the Site, and an area potash mine to the west of the Site along with a communication tower (ELEA 2007 , Section 2.1.3.3).

3.2.4 Visual Resource Management Classes VRM classes de cribe the different degrees of modification allowed in the basic elements of the landscape. The e classes are determined through a matrix which combines scenic quality visual s nsitivity and distance zon s. The r suiting classes are mapped and become the basis used to a ess the impact of proposed activities. The following defines the VRM classes and how visual class ratings are developed. Figure 3.2-1 illustrates the VRM classes as a result of the inventory and evaluating process for the arlsbad Resource Areas (BLM 1986, Appendix I).

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Class I Applies only to classified special areas (e.g., Wilderness Primitive and Natural Areas). This quality standard is established through legislation or policy. Only nattu"al ecological changes are allowed.

C las II Landscapes with la A scenery quality or Class B cenery quality in the foreground middleground zone with high visual sensitivity. Changes in any of the basic elements (e.g., form, line, color, and texttu"e) caused by a management activity should not be evident in the characteristic landscape.

Clas III Landscapes with Clas B seen ry quality and high visual sensitivity in th background zone or with Clas B cenery quality and medium vi ual en itivity in the foreground middleground zone or w ith Class C scenery of high visual sensitivity in the foreground middleground zone. hanges in the basic elements (form, line, color and texture) cau ed by management activity may be evident in the characteristic landscape, however tbe change shou ld remain ubordi.nate to the visual trength of the existing character.

Class IV Landscapes with Class B scenery quality a11d high visual sensitivity in the seldom een vi ual zone or with Clas B cenery quality and medium or Low vi ual sensitivity in the background or seldom seen zones or with Class C cenery quality except with high sensitivity in tbe foreground middleground zone. Changes may subordinate the original composition and character but must reflect what could be a natural occunence within the characterist ic landscape.

Contrast Rating System. The degree to which a pro po ed project affect the vi ual quality of the landscape depends on the amount of visual contrast that is created between the activity and the existing landscape. The contrast rating system is used to assess this contrast.

The system reduces a landscape to its major features land and water vegetation and structures and each feature into it ba ic element (form, line, color, and texture). The predicted contra t of the proposal against each land cape feature then indicate the total anticipated vi ual impact.

For each management clas there are maximum acceptab le ratings for each element and any one feature.

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ATTACHMENT 5 TO HOL TEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Source: BLM 1986, page 3-31.

Figure 3.2.1. VISUAL RESOURCE MANAGEMENT CLASSES HOLTEC INTERNATIONAL COPYRIGIITED MATERIAL HJ-2167521 I Rev. 4 3-10 63 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.3 GEOLOGY AND SOILS Thjs ection identifies th geological, eismological, and geot chnical characteri tics of the IS Facility Site and its vicinity.

3.3.1 Regional and Site Specific Geology 3.3.1.l Structural Features The Site is located in the no1ihern portion of the Delaware Ba in, a northerly-trending, outhward plunging asymmetrical trough with tructural relief of greater than 20,000 feet on top of the Precambrian basement rock. The Basin was formed by early Pennsylvanian time, fo Bowed by major structmal adjustment from Late Pennsylvanian to Early Permian time. During the Triassic period, the area was uplifted, resulting in deposition of cla tic continental shale (redbed ).

Continuing uplift resulted in erosion and/or non-deposition until the middle to late Cenozoic period, when regional eastward tilting completed structural development of the basin as it exists today. Shallow sub urface structur at the Site consi t of gently east loping beds of Triassic age redbeds, dipping two degrees to the east. Faulting has not occurred in the northern Delaware Basin in the area of the Site. The regional geology suggests that there have been no recent, dramatic changes in g ologic proces e and rate in th vicittity of the Site (ELEA 2007 , Section 2.3.4.1.2).

During most of the Permian period, the D la ware Basin was the site of a deep marin canyon that extended across southea tern New Mexico and west Texa . Major structural element of the Delaware Basin area are shown in Figure 3 .3 .1. The major structures of the basin include the Guadalupe Mountains on the west sid , the Central Basin Platform on the east side, and the Capitan Reef Complex on thew t and north ide of the basin. The reef created steep lope toward the basin and the thicknes of sediments grows precipitously toward the center of the basin from the margin of the reef The Central Basin Platform forms an abrupt eastern terminus to the Delaware Ba in; it i a teeply fault-bound uplift of ba ement rock that grew through the early and middle Paleozoic period uch that most of the pre-Permian sedimentary ection is mjs ing from its apex.

Great thickness of organic-rich marine deposits in the basin and the presence of abrupt structures in the Capitan Reef Complex and Central Basin Platform combined to produce a prolific oil and gas province. These areas have been the focu of inten e petroleum exploration and development activities since approximately 1920. Surficial geology and subsurface structure across the Delaware Basin are depicted in the map and cross section in Figure 3.3 .2. Thickness of sediments in th basin exc ds 20 000 feet, and P nnfan strata alone account for mor than 13,000 ti t of sedimentary materials (ELEA 2007 Section 2.3.2.3).

3.3.1.2 Regional Stratigraphy Thi section di cu es the regional geology a cending from a depth of approximately 13 000 feet.

The geologic formations of concern beneath the Site comprise, from oldest to youngest, consist of Permian-aged rocks (Wolfcamp serie , Leonard series, Guadalupe eries, Ochoa eries); Triassic-aged rocks (Dockum Group); and Tertiary and Quaternary rocks (Lower Gatuna Formation, Upper Gatuna Formation), and alluvium. A stratigraphic column for the above units in provided in Figure 3.3-3 with brief descriptions of the units provided below.

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Permian Rocks Wolfcampian Series. The Wolfcamp varies in lithology, grading from primarily limestone that thins or is absent along the ere t of the Central Basin Platform to dark shale and sandstone in the Delaware Ba in. Both the cla tic and limestone facies of the Wolfcamp have been recognized a oil and gas exploratory targets.

Leonardian Series. The Leonardian con ists mostly of the Bone Spring limestone, which is dark gray thinly-bedded argillaceous limestone containing thin beds of fine sandstone and interbedded black calcareous cberty shale sequence that is as great a 3,000 fe t in thickness.

Guadalupian Series. The Guadalupian series consists mostly of sandston sand hales in th basin facies and limestone in the shelf facie . The basin facie are known as the Delaware Mountain Group consisting of light gray, very fine grained sandstone and siltstone separated by grey shales or limestones, dolomites, or evaporates. The Delaware Mountain Group contains important oil and ga exploratory targ ts in th Delaware Basin. The lat ral equival nt for the Delawar Mountain Group is the Capitan Limestone. The Capitan limestone i a light-colored, fo siliferous, locally vuggy limestone and breccia. The Capitan limestone forms an arc around the west, 1101th, and east margins of the Delaware Basin.

Ochoan Series. The Ochoan serie is composed primarily of evaporite deposits that formed during regre sive events of hallow sea waters.

Tria ic Rocks Upper Triassic rocks re t unconformably on late Permian aged Dewey Lake Redbeds in the area.

The upper Trias ic section consists ofup to l,500 feet ofreddish brown shales, silt tone , and fine grained sandstone known as the Dockum Group.

Tertiary-Quaternary Rocks The Gatuna Formation is likely of early to middle Pleistocene age and is up to several hundred feet thick. Depending upon the location and nearby ediment ource rock , the Gatuna Formation consi t ofreddi h brown friable sandstone, siltstone iliceous conglomerate, and locally; gyp um and claystone. Above the Gatuna Formation and on other pediment alluvial materials, laterally exten ive caliche depo its called the Mescalero are pre ent acros much of southea tern New Mexico. The Me calero i de cribed a a andy light gray to white lower nodu.lar and upper laminar caliche zone that ranges in thickness from 3 to 10 feet.

3.3.1.3 Site Specific Geology The entire Site is underlain by Trias ic bedrock consi ting of shale, iltstone and minor fine-grained, poorly sorted sandstone. Most of the proposed operational area is relatively flat and the shale bedrock is covered by a laterally exten ive veneer of25 feet of Quaternary pediment depo it con i ting of well orted eolian sand and sandy-gravelly materials near the bedrock interface. The Mescalero Caliche unit is near the surface and is about 10 feet thick at the Site.

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.3.2 Seismic Information 3.3.2.1 Earthquake Activity Earthquakes of low to moderate magnitude have been documented within a 200-mile radius of the Site. The vast majority of the earthquake activity is located southeast of the Site in west Texas, and west/northwest of the Site in central New Mexico. The U.S. Geological Survey (USGS) earthquake databa e wa used to query hi torical earthquake within a 200-mile radius of the Site (USGS 2016a). Results of the search of the 200-mile radius yielded a total of 244 historical earthquakes with magnitude 2.5 or greater between 1900 and the most recent update of the database in 2016. The re ult indicate the clo e t earthquake to the Site wa 24 mile outhwe t with a magnitude of3.1 that occurred on March 18, 2012. Two earthquakes with magnitudes greater than 5.0 were recorded within 200 miles of the Site. An earthquake with magnitude 6.5 occw-red on Augu t 16, 1931, located 140 miles southwest of the Site; and an earthquake with magnitude 5.7 occurred on April 14, 1.995, located 165 miles south of the Site. The re ults of the USGS earthquake search are plotted on a regional map in Figure 3.3.4.

There are three seismic source zones within a 200-mile radius of the Site: the northern and southern regions of the Southern Basin and Range - Rio Grande rift zone located west and southwest of the Site; and the Central Basin Platform zone located east of the Site . The most active seismic area within 200 mile of Site i the Centra l Ba in Platform ea t of the Site. Large magnitude earthquakes are not occurring or have not occurred within the recent geologic past along the Central Basin platfonn due to the ab ence of Quaternary fault . The ei micity in we t Texa , outhea t of the Site, is hypothe ' ized a being a result of fluid pre ure build -up from fluid injection, and consequential reduction in effective tres across pre-exi ting fracture and as ociated decrea e in frictional resistance to sliding. Similarly, recent records (1998 through 2005) from the Waste I olation Pilot Plant (WIPP) eismic monitoring network indicate that th tronge t vent recorded annually in 1999 2000, and 2002 through 2005 (typically of2.5 to 4.0 magnitude during this time period) have been located about 50 miles west of the Site. This seismic activity is suspected to be induced by injection of waste water from natural ga production into deep well or well (ELEA 2007, Section 2.3.4.1.4).

3.3.2.2 Ea rthquake Potential A review of the sei mic ri k was based on USGS Geologic Hazard Science Center 2009 Earthquake Probability Mapping (USGS 2009), which generates maps that show the probability of a magnitude 5.0 or higher earthquake within a 30-mile radius ofany location within the next 50 years. On a scale of 0.00 (the lowest probability of earthquake) to 1.00 (the highest probability),

all Project facilitie are within the low probability range of0.01 to 0.02 as hown in Figure 3.3.5 (USGS 2009).

3.3.2.3 Probabilistic Ground Motion Probabilistic ground motion for the Site was determined using information from the USGS (USGS 2014). Figure 3.3.6 is a probabilistic ground motion map of the Site, illustrating peak horizontal acceleration with a 2 percent probability of exc edanc in 50 y ars (2,500 y arr turn int rval).

The Peak Horizontal Ground Acceleration (PGA) value of 0.04 of the acceleration due to gravity (g) to 0.06g estimated by the regional USGS algorithm is similar to values sugge ted by several HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-13 66 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment site-specific studies for nearby locations. The Geological Characterization Repo,t (GCR) for the WIPP Site (Powers et al., 1978) detennined acceleration of :S0.06g for a return interval of 1,000 year , and :SO. lg for a return interval of 10,000 year (WIPP i located approximately 16 mile outhwe t of the Site); the results of the GCR were reviewed and confirmed by Sanford et al.

(1993), which e ti.mated a maximum expected acceleration ofO.lg for the WIPP, and again in the Safety Evaluation Repo1t for the WIPP (DOE 2016b, Section 3.2), which de cribe the GCR re ult a conservative. The ei mic hazard for the National Enrichment Facility (NEF) uranium enrichment faci lity predicts 0.15g for a return interval of 10,000 years (LES 2005, Section 3.3.1.1.5.1). The NEF faci lity is about 38 miles southeast of the Site (ELEA 2007, Section 2.3.4.1.1).

3.3.2.4 Faulting Quaternary-age faulting i not pr sent in the vicinity of th Site. Then ar t Quat rnary-ag fault is located 85 miles southwest of the Site (USGS 2016b). Little i known about this fault except that it is a normal fault, 3.6 mile in length, and has a slip rate of less than 0.01 inch per year. The Guadalupe fault forms a scarp on unconsolidated Quaternary deposits at the western base of the Guadalupe Mountain in the Ba in and Range physiographic province. The ame USGS databa e shows numerous other Quaternary-age faults within a 200-mile radius of the Site, located to the west and southwest, most of which are at the distal end of the radius and are near the Rio Grande Rift of central New Mexjco . Figure 3.3 .7 i a map of New Mexico and West Texas bowing Quaternary-age fau lting as cataloged by the USGS , and as down-loaded from the database referenced above. The database contains locations and information on fau lts and associated folds that have been active during the Quaternary (the pa t 1.6 million years).

In all, there are a total of 27 Quaternary faults or fault zones within a 200-mile radius of the Site.

A total of four "capable" fault were identified, including the Guadalupe fault. A "capable" fault i one that has exhibited one or more of the following characteristics (IO CFR J00 Appendix A.III

[Definitions]):

  • Movement at or near the ground surface at least once within the pa t 35,000 years or movement of a recurring natur within tb pa t 500,000 year .
  • Macro-seismicity instrumentally determined with records of sufficient precision to demonstrate a direct relationship with the fault.
  • A tructurnl relationship to a capab le fault according to the previou two characteri tics such that movement on one could be reasonably expected to be accompanied by movement on the other.

For the purposes of this assessment, capable faults were identified based solely upon the first characteri tic above.

3.3.3 Salt Dissolution and Sink Holes Comparison of conditions at the Site with those conditions favorable to karst development indicate that condition at the Site are not conducive to kar t development. No thick ection of so luble rock are present at or near land surface; the shallowest soluble bedrock materials are gypsum and halite beds in the Rustler Formation, which is located at least 1, l 00 feet below land HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-14 67 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment urface at the Site. Additionally, rainfall rates in the area are low. Mescalero caliche i soluble and situated at or near land surface; however this unit is no more than l O feet in thickness. Local di solution of this unit may have re ulted in the development of a nwnber of small hallow depre sion in the area; however this is not regarded as an active or significant kar t process at the Site (BLEA 2007, Section 2.3.4.2).

During site reconnaissance, detailed inspection of the areas around the margins of Laguna Gatuna and tributary drainages was performed to identify any tension cracks, disrupted soils, tilting, or other evidence of rapid earth displacement. No tension cracks or other evidence of displacement was observed. Additionally older cultural features in the area were inspected to identify evidence of tilting, off: et, or displacement that could indicate recent land movement. A number of oil wells were drill d along the w st flank of Laguna Gatuna beginning i.n th arty 1940' s. Mo t of th well were abandoned by 1975 and well monuments were installed ; several of the well monuments were identified during site reconnaissance. None of the monuments displayed evidence of tilting that might be a ociated with local earth movement (BLEA 2007, Section 2.3.4.2).

3.3.4 Soils U.S. Department of Agriculture (USDA) Natural Reso urces Con ervation Service (NRCS) Soil Survey Maps ofL a County, New M xico (USDNNRCS 2016) w r r viewed in order to identify the soil units present at the Site. A Soil Survey Map is provided as Figure 3.3 .8. The majority of onsite soils (60 percent) consist of Simona fine sandy loam (SE) and Simona-Upton association (SR). Simona so ils are calcar ous eolian d posits derived from sedin1entary rock and consi t of fine sa ndy loam underlain by grave lly fine sandy loam and cemented material, and gravelly fine sandy loam underlain by fine sandy loam and cemented material.

As shown on Figure 3.3.8, the construction zones for the Site largely include the SR and SE soils, a well a : Midessa and Wink fine sandy loam (MN), Mixed alluvial land (MU), Mobeetie-Potter as ociation (MW), and Kimbrough gravelly loam (KO). MN oils are calcareou alluvium and/or calcareous eolian deposits derived from sedimentary rock and con ist of fine sandy loam underlain by clay loam. MU soils are mixed alluvium derived from sedimentary rock; they consi t of stratified sand to loamy fine sand to loam to sandy clay loam to clay loam to clay. MW soil are calcareous sandy alluvium derived from sedimentary rock and consist of fine sandy loam. KO soils are calcareous alluvium and/or calcareous eolian deposits derived from sedin1entary rock and con i t of gravelly loam und rlain by cemented material (ELEA 2007, Section 2.3.3).

Appendix D provides additional information r garding soil descriptions, soil features, and physical, chemical, and engineering prope11ie , including so il salinity. A review of the available soil data, including engineering properties of the Site soils indicates favorable conditions for foundation , utilities, surface pavement, and other improvements (ELEA 2007, Section 2.3.3).

The geotechnical site characterization completed by GEI provides field and laboratory data on soil and rock obtained for de ign Pha e 1 of the propo ed HI-STORE confirmed the re ult ofpreviou investigations in the area. A thin layer of top soil underlain by caliche caprock and clayey sand/sandy clay residual soil was observed. Beneath the soil was bedrock consisting of Chinle mud tone underlain by Santa Ro a and tone(GEI 2017).

HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-15 68 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Faci li ty Environmental Report Chapter 3: Affected Environment I "

I Source : ELEA 2007, ection 2.3.2.2.

Figure 3.3.1: MAJOR REGIONAL GEOLOGICAL STRUCTURES NEAR THE SITE HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-16 69 of 558

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Figure 3.3.2: GEOLOGIC CROSS SECTION THROUGH THE CAPITAN REEF AREA, EDDY AND LEA COUNTIES, NM HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-17 70 of 558

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Figu re 3.3.3: PERMIAN TO QUATERNARY-AGED STRATIGRAPHY OF THE DELAWARE BASIN HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-18 71 of 558

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Figure 3.3.4: EARTHQUAKES (MAGNITUDE 2.5 OR GREATER) WITHIN 200 MILES OF THE SITE HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-19 72 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facili ty E nvironmenta l Report Chapter 3: Affected Environment U.S. Geologlcal Survey 2009 PSHA Model Slte: -103.71 d E 32.58 33* 30' 1.00 0.90 0.80 33* 00' 0.60 0.50 0.40 0.30

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Source : USGS 2009.

Figure 3.3.5: PROBABILITY OF EARTHQUAKE WITH MAGNITUDE GREATER THAN 5.0 WITHIN 50 YEARS AND 30 MILES OF THE SITE HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2 16752 1 I Rev. 4 3-20 73 of 558

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HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-21 74 of 558

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Figure 3.3.7: QUATERNARY FAULTS WITHJN A 200-MILE RADIUS OF THE SITE HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-22 75 of 558

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  • P ECT BOO~OARY Jcl Q SSO lie 0 iml:r oq 1;ravelly loorr  ?: iY*1..eA ~N!9'.GY A \I\N2 f"\OJ!-:T LP L<1 e-Pa.a rto c:om plex LEA COUN TT EWV CO M ide:a><1 nd ""'k f in~ saidy I
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Figure 3.3.8: SOIL SURVEY MAP HOLTEC INTERNATIONAL COPYRIGIITED MATERIAL HJ-2167521 I Rev. 4 3-23 76 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.4 ECOLOGICAL RESOURCES Thjs section d scribe the eco logical communiti in the ar a and is int nded to provide a baseline characterization of the ecology prior to any di turbance a sociated with construction or operation of the project. The plant and animal species associated with this major community are identified and their distributions are discuss d. Those peci that are considered important to the cology at the Site are described in detail, including the spec ies' habjtat requirements and life history. Al o, as part of the evaluation of important spec ies at the CIS Facility, pre-existing environmental conditions that may have impacted the ecological integrity of the CIS Facility and affected impo1tant specie are con idlered. An in-field ecological urvey of the Ho ltec Underground CIS Facility project in Lea County, New Mexico was conducted on October 14, 2016 (Appendix B).

The ecologic survey was conducted across the approximately 330-acre footprint that could be disturb d by the propos d ClS facility (all phases). The 2016 survey findings wer consistent with the prior 2007 eco logical urvey (See Section 3.4.1.1) conducted on the entire 1,040-acre parcel.

Because there was nothing remarkable about the comparison ofresults, there was no need to survey a greater area, a the combined results of the 2007 and 2016 ecological surveys adequate ly characterize the ecological nvironment of the Sit . Figure 3.4.1 i a topographic map of t he project boundary and surrounding area. This topographic map is enhanced with focus on the CIS Facility for Figure 3.4.2 and Figure 3 .4.3.

3.4.1 Ecological Systems 3.4.l.1 Prior Ecologica l Studies An ecological study for the Eddy-Lea Energy Alliance (ELEA) Global Nuclear Energy Project (GNEP) was conducted in 2007 (ELBA 2007, Section 2.6). The facilities proposed for GNEP were nuclear-related and w re expected to have a imilar footprint a the proposed IS Facility.

3.4.1.2 General Ecological Conditions The Proj ct area is classified as Apacherian-Chihuahuan mesquite upland scrub (NatureServe 2016). Thi ecosystem often occurs as invasive upland hrubland such a tho e that are concentrated in the foothills and piedmonts of the Chihuahuan Desert (NatureServe 2009).

Substrates are typically derived from alluvium, often gravelly without a well-developed argillic or calcic soil horizon that would limit infiltration and torage of winter precipitation in deeper oil layers. Deep-rooted shrnbs are able to access the deep-so.ii moisture that is unavailable to grasses and cacti. Vegetation is dominated typically by honey mesquite (Prosopis glandulosa) or velvet mesquite (Prosopis velutina) and succulents. Grass cover is typically low and compo d of de ert grasses such a low woollygra s (Dasy ochloa pulchella) , bush muhly (Muhfenbergia porteri) curlyleaf muhly (Muhfenbergia setffolia), and tobosagrass (Pleuraphis mutica) (NatureServe 2016). During the last century, the area occupied by this ecosystem has increased through conver ion of de ert gras land as a result of drought, overgrazing by livestock, and d crease in fire :frequency (NatureServe 2009).

Common mammals in the Project area include mule deer, antelope, coyote, skunk*, cottontail, jack.rabbits, pocket gophers, foxes, woodrats and various small rodents. Many species of lizards and snakes are also common. Various sized active burrows, tracks and scats en in the field implied HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2167521 I Rev. 4 3-24 77 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment the presence of small mammals, coyote, foxe and lizard (ELEA 2007, Section 2.6.1.1). Birds common in habitat typical of the proposed Site include quail, doves, various hawks, sparrows, loggerhead shrike, flycatchers, tlu*ashers and cowbirds.

3.4.1.3 Important Ecological Systems Ba ed on recent field tudie and the published literature, there are no on ite important ecologica l ystem that are e pecially vulnerable to change or that contain impo1tant specie habitat uch a breeding areas, nursery, feeding, resting, and wintering area , or other areas of seasonally high concentrations of individual of important specie .

3.4.1.4 lmportant Travel Corridors The Site does not pass through any designated wildlife corridors (NM CHAT 2016). The teITestrial wildlife species that potentially inhabit this area do not have e tablished migratory corridors through the Site. The Project would not block terrestrial spec ies trave l a they could eas ily move around the Site.

Southeastern New Mexico, including Lea County, is within the Central Flyway one of the four major North American bird migration corridors between nesting and wintering grounds.

Depending on the availabi lity of food and water that may be temporarily pre ent in th playa in the vicin ity of the Site during seasonal migrations, migratory birds such as these could occasionally be present on or in the vicinity of the Site.

3.4.1.5 Ecological Succession Long-term ecological studies of the Site are not available for analysis of ecological succession at this specific location. The property is located in a Desert Grasslands vegetation community (Dick-Peddie et al. 1993), within the Apacherian-Chihuahuan me quite upland scrub cla sification (NatureServe 2013), which is a climax community that ha been established in western Lea County for an extended period. With the exception of areas along maintained road and pipeline RO W ' s, the project area is in a climax successional tage, as evidenced by the presence of honey mesquite and broom nakeweed (Appendix B).

3.4.1.6 lndications of Ecological Stress Pre-exi ting environmental tre es on the plant and animal communitie at the Site con i t of ROWs for pipeline , roads, well pads power lines, telephone lines, and a communications tower, and domestic livestock grazing (ELEA 2007, Section 2.1. l ). The impact of road installation and maintenance of the ROW i colonization of the di turbed area by local plant pecie , typica lly by lower successional state species (i.e. , weed ). As long as ROW maintenance activities continue, this pattern of succession is expected to continue.

Historical domestic livestock grazing and partial fencing of the Site constitute a pre-existing and continuing environmental stress. Heavily grazed native gra lands t nd to exhibit changes in vegetation communities that move from matme, climax condition to mid-succes ional stages with the invasion of woody species such as honey mesquite and sagebrush. The Site has. stands of mesquite indicative of long-term grazing pressure that has changed the vegetative community from HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-25 78 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Faci li ty Environmental Report Chapter 3: Affected Environment one dominated by climax grasses to a sand scrub community and the re ulting change in wildlife habitat.

Another periodic environmental stre s is changes in local climatic and precipitation patterns. The Site i located in an area of the Pecos Vall y of New Mexico that experienc s shifts in precipitation amounts that can affect plant conununity diversity and production on a short-term sea onal basis and also on a long-term basis that may last fo r several years. Below average precipitation that negatively impacts the plant community also directly alters wild life habitat and may severe ly reduce w ild life populat ions.

Past live tock grazing fencing, and the maintenance of acce s road and pipel ine ROWs repre ent the primary pre-existing environmental stress on the wi ldlife community of the Site. The probable re ult of the pa t and current use of the Site is a shift from wildlife pecie a sociated with mature desert gras land to those a sociated with a gras land shrub community. Large herbivore species uch a the pronghorn ante lope (Antilocapra americana) that require large, open prairie areas with few obstructions such as fences have decreased. Other mammalian species that depend on open gra land , uch a the black-tailed prairie dog ( Cynomys ludovicianu ), are also no longer pre ent in the immediate area. Bird pec ies that depend on the mature gra land for habitat, such a the lesser prairie chicken (Tympanuchus pallidicinctus), have decreased in the region and at the Project area. Other pecies that thrive in a mid-successional p lant community, such as the black-tailed jackrabbit (Lepu californicu ), de ert cottontail (Sylvilagu audubonii) and mule deer

( Odocoileus hemionus) have probably increased. No other environmental stresses on the terrestrial wildlife community (e.g., disease, chemical pollutants) have been documented at the Project area.

3.4.2 Vegetation 3.4.2.1 Major Vegetation Characteristics The Site is in the primary vegetation conununity of Desert Grasslands (Dick-Peddie et al. 1993),

which is widespread at lower elevations in so uthern and western New Mexico . These communities are characterized by ignificant amounts of gra e and le than 10 percent of total cover being forbs and shrubs (Dick-Peddie et al. 1993).

Typ ical vegetation in Desert Grassland communities include black grama (Bouteloua eriopoda),

blue grama (Bouteloua gracilis), bluestem, buffalo grass (Bouteloua dactyloides), western wheatgrass (Pa copyrum smithii), galletas (Hilaria pp.), to bosa grass (Pleuraphis mutica), alkali sacaton (Sporobolus airoide ), three-awn (Ari tida spp.), mesquite (Pro opis spp.), serviceberry (Amelanchier denticulate), skunkbush sumac (Rhus trilobata), sand sagebrush (Artemisia

.filifolia), Apache plume (Fallugia paradoxa), creosotebush (Larrea tridentata), and cliffrose (Purshia mexicana). With appropriate moist ure (generally more than is typicaUy experienced) sunflower (Helianthus annuus), croton (Croton spp.), and pigweed (Amaranthus palmeri) may grow in disturbed or ponded depressions.

Surveys of the area have not documented traditional grassland species in this area. A survey conduct din March of2007 (ELBA 2007, Section 2.6.1.2) at thi ame ite documented vegetation more typ ica l of mesquite crubland conunun ities, includ ing sma ll oapweed (Yucca glauca),

globemallow (Sphaerakea sp.), dwarf desert ho Uy (Acourtia nana), threeawn, ragweed (Am brosia sp.), black grama, broom snakeweed (Gutierrezia sarofhrae), blue grama, spiny dogweed HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-26 79 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment (Thymophylla acerosa), muhly (Muhlenbergia sp.), cowpen daisy (Verbesina encelioides), vine mesquite (Panicum obtusum), Panicgrass (Panicum sp.), bladderpod (Lesguerefla sp.), bun-ograss (Scleropogon br vifolius), plains bristlegra (Setaria leucopila), james' nailwort (Paronychia Jame ii) fourw ing saltbush (Atriple.x canescens), lotebush (Condelia erkokfes), joint fir (Ephedra sp.), buffalobur (Solanum rostraturn), potts' leatherweed (Croton pottsii), mock vervain (Glandularia sp.), milkvetch (Astragaius sp.), and honey me quite.

A survey in October of 2016 (Appendix B) also documented a variety of mesquite scrubland and very few grassland specie . This further indicates that vegetation in the area has changed from a desert grassland to mesquite scmbland due to overgrazing. The dominant species documented during this smvey include broom snakeweed, honey mesquite, prairie verbena (Glandularia bipinnatifida), prickly pear ( Opuntia engelmannii), scarlet glob mallow (Sphaeralcea coccinea) ,

silverleaf nightshade (Solanum elaeagnifolium) , tobosa grass, we tern peppergrass (Lepidium montanum), and wooly croton (Croton capitatus).

3.4.2.2 Important Habitat Vegetation and habitats within the Site and immediately surrounding area are common within the region. The Site does not support any vegetation of significance. Significance is defined in this docum nt as any plant, animal, or habitat that: (I) ha high public interest or economic value or both; or (2) may be critical to the stmcture and function of the ecosystem or provide a broader ecological perspective of the region.

No riparian habitat exists in or near the Site. There are two playas (Laguna Gatuna and Laguna Plata) in the vicinity of the Project area (within two miles), but neither upport riparian habitat or other habitat for wi ldlife because of the lack of food and high salinity of the soil and water. (ELEA 2007; Section 2.6. l.2). There are several low-lying areas near the 1101thern border of the project area that show evidence of water collection during heavy rain event , re ulting in thicker upland vegetation communitie in the e area , but no riparian vegetation (Appendix B).

For most of the threaten d, endangered, and other impo1tant sp cies, th importance of the habitat on the proposed Project area relative to the habitat of those species throughout their entire range is rather low. Most of these species have little or no suitable habitat on the proposed Project area and the habitat pre ent ar not rare or uncommon in the local ar a or range-wide for thes sp cie .

Although the proposed Project area contains fair to poor quality wildlife habitat for mo t pecie ,

there are ome pecie of con ervation or manageme nt concern are a sociated with tbi ecological system, and may utilize it for some portions of their life cycle (nesting, foraging, cover, burrows).

These species are of conservation or manag m nt concern due primarily to their relative vulnerability to extinction through alteration of other eco ystem but me quite scrub may replace lo t habitat in ome cases (NatureServe 2013). Some of the pecies of concern that are associated with the mesquite upland scrub ecosystem include Ferruginous Hawk (Buteo regalis) (breeding population only), Mourning dove (Zenaidura macroura), No1thern Aplomado Falcon (Falco femoralis eptentrionalis), White-winged dove (Zenaidura a *tiatica) scaled quail ( Callipepla squamata), Banner-tailed Kangaroo Rat (Dipodomys spectabilis), Black-tailed Prairie Dog, Collared Peccary (Tayassu tajacu), Mule deer, White-tailed deer (Odocoileu virginianu ),

Slevin' Bunchgra s Lizard (Sceloporus slevini), among others (NatureServe 2013).

HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-27 80 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment This area historically supported lesser prairie-chickens, but their population has decreased in the region, as it typically depends on the mature grasslands for habitat, which has largely been converted to mesquite crubland in this area. The project area no longer consi t of gra sland vegetation and lesser prairie-chickens were not observed during recent surveys (see ection 3.4.3).

The majority of the project area is within the outer limits of a BLM Isolated Population Area and Timing and Noi e Re triction Zone for thi pecie . The timing re triction would entail certain activity re triction between 3:00 AM. - 9:00 AM. :from March 1 to June 15. However, the pmtion of the project area that is within thi restriction zone is on private property and the restrictions would not be enforced by the BLM. Jn 2007, several disjunct parcels in the region were proposed a Le r Prairie-Chicken Habitat Preservation Area of ritical Environm ntal Concern (ACEC)

(BLM 2008). One of these parcels was 2.2 miles north of the project area. However, the final 58,000-acre le ser prairie-chicken habitat preservation ACEC was e tablished approximately 58 miles north of th proj ct area (BLM 2008).

3.4.3 Wildlife During sw-vey conducted in March of 2007 (ELEA 2007, Section 2.6.1. l ), 16 bird species and 4 mammal pecies were recorded. No reptiles or amphibians were observed. Bird pecies encountered were Northern han-ier (Circus cyaneus) , ferruginous hawk (Buteo regalis), killdeer (Charadrius voc[f'erous), Greater yellowlegs (Tringa melanoleuca), Western snowy plover (Charadrius alexandlinus nivosus), Eurasian collared dove (Streptopelia d caocto), Ladder-backed woodpecker (Picoides scaralis). loggerhead shrike (Lanius ludovicianus), Homed lark (Eremophila alpestris), cactus wren (Campylorhynchus brunneicapillus), Crissa1 thrasher (Toxostoma crissale), Cassin ' s sparrow (Aimophila cas inii), lark bunting (Calamospiza melanocmys), savannah parrow (Passerculus sandwichensis), white-crowned parrow (Zonottichia leucophtys), and Western meadowlark (Sturnella neglecta) . Mammals encountered were black-tailed jackrabbit, desert cottontail, woodrate (Neotoma sp.}, and coyote (Canis latrans).

Most bird species observed were typical year-round residents or wintering species for mesquite-gm land habitat in outhern New Mexico. AU the wildlife pecie ob erved during the urveys were typical of the habitat. Additional surveys conducted during all sea ons and time of day in more than one year could reveal additional species.

A list of similar bird and mammal species was observed during the October 2016 survey. Eight birds and three mammals were observed: lark sparrow (Chondeste grammacus), loggerhead shrike, mourning dove (Zenaida macroura) , northern harrier, red-tailed hawk (Buteo jamaicensis) ,

scaled quail (Callipepla squamata) , western meadowlark, white-winged dove (Zenaida asiatica) ,

black-tailed jackrabbit, desert cottontaiL and Mearn's grasshopper mouse (Onychomys .arenicola)

(Appendix B).

3.4.3.1 Threatened and Endangered Species The list of Federally-listed threatened and endang red (T &E) species having th potential to occw-in the vicinity of the Project area wa developed via reviews of on line and hard copy re ource agency database requests and agency consultation. Initially, the Biota Information System of New Mexico (BISON) (BISON 2016), New Mexico Rare Plant Technical Council (NMRPTC) New Mexico Rare Plant Web ite (NMRPT 1999) and USFWS county-based internet earch engine HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-28 81 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment were reviewed for Federally- and state-listed T &E species by county and the Site (USFWS 2016a and USFWS 2016b). Results from this search revealed three Federally-listed special status species and 22 tate-li ted special tatu speci.es that occur in Lea County, New Mexico . The e pecies, along with their habitat and life history requirements are Ii ted in Table 3.4.1. There is no designated or proposed critical habitat within Lea County. However, in 2008, BLM established the Les er Prairie-Chicken Habitat Pre ervation Area of Critical Environmental Concern ( AC C) in the region. The nearest ACEC i about 58 miles from the propo ed CIS Facility ite.

3.4.3.2 Threatened and Endangered Species Sightings No rare, threatened, or endangered species have been ob erved in the vicinity of the pro po ed CIS Facility (ELEA 2007 Section 2.6.3 and Appendix B). However, during the October 2016 survey a loggerhead shrike, a state-listed Sensitive Taxa with Full Protection species, wa observed (Appendix B).

3.4.4 Aquatic Systems 3.4.4.1 Characterization of the Aquatic Environment The proposed Project area contains no aquatic habitat (ELEA 2007, Section 2.4.1 ). The two playas in the vicinity contain a small amount of water for everal days following a major precipitation event. However, these feature does not support aquatic life, and no rare, threatened, or endangered species are present. There also is a mall, shallow "canyon" that drains the northwest quaiter of section 13 of the Project area and emptie into Laguna Plata. This drainage does not exhibit uitable bed and bank morphology and i within a topographically closed ba in, and not a tributary to a Water of the United States (U.S.), which excludes it from consideration as a Water of the U.S.

(ELBA 2007, Section 2.5.2 and Appendix B).

There is no hydrologicaVchemical monitoring station onsite, and no data have been recorded in the pa t.

3.4.4.2 Key Aquatic Organism Indicators There are no key aquatic indicator organisms due to lack of habitat.

3.4.4.3 Significance of Aquatic Habitat There is no significant aquatic habitat in the Project ai*ea due to lack of perennial water sow-ces.

How v r th r are s veral easonally aquatic sp ci that may b present in the Project ai* a are during rain events or when ephemeral water i present in the nearby playas. The BISON database (BISON 2016) lists six amphibian species that could potentially be present. These are listed in Tabl 3.4.2 along with their pr ferr d habitat (BISON-M). All six species are provided limited protection by the State of New Mexico but all are listed a demonstrably ecure in the state (BISON 2016). However, no amphibian species were observed during the March 2007 or October 2016 survey .

3.4.4.4 Important Aquatic Ecological Systems There are no in1portant aquatic ecological systems onsite or in the local ai*ea that ai*e especially vulnerable to change or that contain impo1tant species habitats, such as breeding area , nursery HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-29 82 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Faci li ty Environmental Report Chapter 3: Affected Environment areas, feeding areas, wintering areas, or other areas of seasonably high concentrations of individuals of impo1tant species.

3.4.4.5 Commercial and Sport Fisheries There are no commercial or sport fisheries located on the Project area or in the vicinity. There is no aquatic habitat or any perennial urface water. The closest fi hery areas are the Pecos River and Lake Avalon located approximately 30 miles west of the Project area.

3.4.5 Recent Ecological Survey In October 20 16, Tetra Tech conduct d an eco logical surv y of the Site, focus ing on the ar as proposed for Phase 1 faci lities as well as the proposed rai l spur and Site access road. The results of that survey are included in Appendix B. Overall, that survey corroborated the infonnation from the 2007 surv y, and the information in Section 3.4 is consistent with the resu lts of the October 2016 urvey.

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.4.1:

FEDERALLY- AND STATE-LISTED SPECIES AND THEIR HABIT ATS EV AL ATEDFORTHE HOLTEC CIS FACJLITY PROJECT, LEA COUNTY, NEW MEXICO Common Federal State Scientific Name Habitat and l.lfe History Requirements Name Status* Status 2 Mammals The range of the black-tailed prairie dog appears to have expanded from Great Plai ns grasslands onto former shinnery savannah whi ch have been converted by li ve tock grazing into shortgrass- like habitat. l.n the Tran -Pecos of Texas, black-Bl ack-tai led Cynomys L LP tail ed prai ri e dogs favo r gras y area as ociated with allu vial prairie dog ludovicicmus fa ns at the mouths of draws, hardpan flats where bnish is thin or ab ent, and the edges of shallow valleys. olonies have been reported in plant assoc iati ons ranging from mesquite-creosote-bush to grama-needlegrass and bun*owgrass-cholla.

Caves are the main roosts for this southwestern species, although it also u es mines, and occa ionall y bui ldings and bridges. It is primaril y a "crevice dweller," prefen-ing "crevices, pockets, and holes in the cei lings of its underground retreats".

ave myoti s Myotis velifer NL LP In all likelihood these animals hibernate in the numerou

  • caves of the limestone country of Lincoln, Chaves, and Eddy counties. Tl i found in areas dominated by creosote bush, palo verde, brittlebusb, and cactus (Texas Parks and Wildlife Department fTPWDl 20 16b).

Common hog-nosed skunks have been found to inhabit hihuahuan Desert crub habitat in New Mex ico. Hog-nosed skunks are e *peciall y fo und in oak and juniper wood lands.

They ar also fo und in shortgra plain acaton gras I, nd, ommon hog- onepalus L LP sycamore, cottonwood, rabbitbrush, oak savanna, chapan-al ,

nosed kunk /e11co11otm and coniferous fore t. Within the even eco-zones in which they are found in New Mexico, their preferred habitat has rocky area which are u ed for denning. Residential areas and fa nnlands are classified as secondarv habitat.

Ringtail cats are found in riparian habitats primarily in montane habitats, but are also found in lowland in rough, rocky country. It stays close to the cliffs and canyons it inhabits. II Ba *sariscus uses a variety of habitats but it prefers rocky areas including Ringtai l L FP astutus rock pi les, stone fe nces, canyon wa lls, and talus slopes (TPWD 20 16c). It is al o fou nd in semi -arid country, de cit , chaparra l, oak wood land , pinyon pine woodlands,jw1iper woodlands, and montane conifer forests (Goldberg 2003).

Sandhill Odocoi/eus In eastern New Mexico, sandhill white-tailed deer are found whitc-tailed virgin/anus L FP most ollen in riparian communities on th e eastern sides of the deer texanus mountains. as well as in the sandbills east of Roswell.

The swill fox is found to inhabit Pl ain -Mesa Sand Scrub and Grasslands habi tat and occupies shortgrass and midgrass wift fox Vu/µ es velox L FP prairies. It is rare in ten-ain that i hi ghl y eroded with gu llies, washes, and canyons.

Occurs throughout the Trans-Peco and is most often found in associa tion with rocky canyon , cliffs. or brushy guk hcs where Western thi ckets or rock piles afford protection. It occupies a wide Spiloga/e gracilis L LP

  • potted skunk variety of habitats, including desert, gra land, 1110 11 tanc areas, and low rough, rocky ten-ain. This skunk is especially abundant in al!ri cultural areas and around human constructions.

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facili ty E nvironmenta l Report Chapter 3: Affected Environment Table 3.4.1:

FEDERALLY-AND STATE-LISTED SPECIES AN D THEIR HABITATS EVALUATED .FOR THE HOLTEC ClS FACILITY PROJECT, L EA COUNTY, NEW MEXlCO Common Federal State Scientific ame Habitat and Life History Requirements Name Status* Status1 Birds Arctic Nests in the arctic i land. and tundra regions of Ala ka, Falco peregri11us peregrine DL T Canada, and Greenland. Migra tes through New Mex ico twice a 11111dri11s falcon year to and from wintering areas in South America.

Breeds in native mixcd-grnss and foscuc prairie, winters in Baird 's Ammodra1111i.s grasslands; does not inhabit prairie lands where 6re L T parrow bairdii uppre ion and changes in grazing pattern have allowed excessive growth of wood v vegetation.

Found primaril y near rivers and large lakes* nests in tall trees or Ha/iaeews Bald eagle DL T on cl iffs near water: communally roosts, especially in winter; le11cocepha/11s hunts live prey, scavenges and pirates food from other birds.

Dense, low, shrnbby vegetation, generally early successional tages in riparian area , bru hy fi elds, young econd-growth Bell 's vireo Vireo be/Iii L T fores t or wood land, scmb oak, coastal chaparral, and mesquite brushlands o flen near water in arid regions.

Broad-bi lled Cynanlhus Arid scrub, open deciduous forest, semi-desert and other open L T hummingbird latiroslris situat ions in arid habitats.

ti lizes farms and annual grasslands with Jes than S percent Ath ene Burrowing owl L FP wood cover. Breeds in grasslands, prairies, or open areas near cunicu/aria human habitati on, esoeciallv go) f courses and aimorts.

Subspecies is Listed only when inland (more than 50 miles from a coastline); nests along sand and gravel bars wit hin bmided Sternula Inte rior least streams and rivers; also known lone ton man-made structures a111i/larum LE E tern (inland bcaclbcs, wa towatcr treatment plants, gravc*1 mine ,

at/,a/assos etc.); eat sma ll fi h and crustaceans, when breeding forages wit hin a few hundred feet of colony.

Arid grasslands, generally interspersed with ' hrubs such as sand sagebrush, sand plum skunkbush sumac, and hinnery Lesser prairie- Tympa1111ch1i.s R3 FP oak shrubs, but dominated by and dropseed, ideoats grama, chicken pa/lidicin tus sand bluestem, and little bluestem grasses; nests in a scrape li ned with grasses.

Occurs in a range of habitat types incl uding forested and non-fores ted to agricultural areas. Forested habitat may be of various canopy types, common ly wi.th an herbaceous Loggerh ead Lanius und erstory. Non-forested habitat may be open to dense stands L FP shrike ludovicianus of shrubs and low tTee . Additional habitat types in Jude semi-arid rands of native gra ses and forb r open rands of hrub and succulents on dry, shallow, rocky, soils of mesas, benches, and canyon walls.

Migratory species found in lowland shortgrass prairies, dry playas and o:flentimes on fall ow agri cultura l fields. Appears to Mountain haradrius L FP require some degree of bare ground which may be provided by plover 111011/am,s livestock activity or disturbed areas around windmills and water tanks.

Wintering migrant along the Texas Gttl fCoast; beache, and Northern bayside mud or salt flats, open country, especially ,ivanna and Fa/co femoral is LEXPN, ap lomado E open woodland, and sometimes in very barren areas; gra sy sep1e111rionalis XN falcon plains and va lleys wit h scattered mesquite. yucca, and cactus; nests in old stick nests of other bird species.

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facili ty E nvironmenta l Report Chapter 3: Affected Environment Table 3.4.1:

FEDERALLY-AND STATE-LISTED SPECIES AN D THEIR HABITATS EVALUATED .FOR THE HOLTEC ClS FACILITY PROJECT, L EA COUNTY, NEW MEXlCO Common Federal State Scientific ame Habitat and Life History Requirements Name Status* Status1 Occur in mature, closed canopied coni ferou. fore. ts of Northern Accipiier genii/is L FP mou11tains and high mesas, hu11ting in an open understory or goshawk oocninus often with water ncarbv.

Year-round resident and local breeder in west Texas, nests in ta ll cliffcyrics; also, migrant across state from more nort hern breeding areas in U.S. and Canada, winters along coa t and farther south; o cupies wide range of lrnbitats during migration, Peregrine Falco peregrinus including urban, concentrations along coast and barrier islands; DL T falcon ana/um low-altitude migrant, stopovers at leading land cape edge uch a lake hores, coast Iines. and barrier i lands. The ub pccies Falco peregrinus flmdrius is not ea ily distinguishable at a di tance, so reference i generally made onl y to the pecies level.

On ly in New Mexico during migration and winter, mid-September to early April; short to medi um distance, diurnal Sprague's pipit A111/1t1s spragueii NIA migrant; strongly tied to native upland prairie. can be locally common in coastal grasslands, uncom mon to rare fu rt her west; sensitive to patch size and avoids edges.

Migrates to orth America throughout summer months, Apri l Yellow-billed through November; habitat include open deciduou cuckoo Coccyzus LT FP cottonwood-dominated woodlands with dense undergrowth, (we tern a111erica111.1s overgrown orchards and pa lures, and moi t thicke ts and popul ation) wi ll ow groves along stream beds.

Reptiles Appears to be confined to areas of active sand dunes Dunes celopor11s pecifically vegetated by hinnery oak* adjacent open habitats sagebrush L E arenicolus of and sagebnish and yuccas may be used in some places.

lizard I C - Candidate, DL - Delisted, LE - Listed Endangered, LEXPN, XN - Listed Experimental Population, Nonessential, LT -

Li sted Threaten d, UR - Under R view, NL - Not Li ted 2 E - Endangered, FP - Sensitive taxa (infonnal) Full Protection, LP - Sensitive taxa (informal) Limi ted Protection, IA -

ot Applicable, T - Threatened 3 The lesser prairie-chicken was listed as a threatened species under the federal Endangered Species Act on May 11, 20 14.

This listi ng was challenged and subsequently vacated (Permian Basin vs. SFWS, September 20 15). On July 20, 20 16, the species was removed from listing as a threatened species, but remai ns under review by USFWS. Although protections for the bird have ceased under the authority of the Endangered pecie Act, the lesser prairie-chicken is stil l afforded protection by the tate of ew Mex ico under "Full Protection" statu .

ources: Biota rnformation System of New Mexico (BlSON) 2016, Goldberg 2003, Natural Heritage New Mexico ( H M) 20 16, Texas Parks and Wildlifo Department (TPWD) 20 16a, U.S. fish and Wildlife Service (USFWS) 2016a,b.

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ATTACHMEN T 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.4.2:

AMPHIBIANS POTENTIALLY PRESENT AT THE SITE AND VICINITY AND THEIR HABIT AT Common Name Scientific Name Preferred Habitat Couch's Spadefoot Sc:aphiopus couchii Shallow to standing pools of water Great plains toad Anaxyrus cognatus Desert Grassland, creosote bush, grassland flats, mesq11ite dominated flats New Mexico spadefoot Spea multip/icata Shallow to standing pools of water Plains spadefoot toad Spea bombi{rons Shallow to standing pools of water Tiger Salamander Ambystoma mavortium; nebulosum Tall grass prairie and desert grasslands Western i:.,rreen toad Anaxvrus debilis Desert Grassland habitat Source: B1SON 2016.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HJ-2 167521 I Rev. 4 3-34 87 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Figure 3.4.1 : TOPOGRAPHY OF SITE AND SURROUNDING AREA (1)

HOLTEC INTERNATIONAL COPYRIGIITED MATERIAL HJ-2167521 I Rev. 4 3-35 88 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 0

Figure 3.4.2: TOPOGRAPHY OF SITE AND SURROUNDING AREA (2)

HOLTEC INTERNATIONAL COPYRIGIITED MATERIAL HJ-2167521 I Rev. 4 3-36 89 of 558

ATTACHMENT 5 TO HOL TEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Figure 3.4.3: TOPOGRAPHY OF SITE AND SURROUNDING AREA (3)

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.5 WATER RESOURCES Thjs ection describ the water r sources including urface and ground wat r hydrology, water use, and water quality.

3.5.1 Surface Water Resources Surface water generally con ist of lakes river and stream . Surface water is important for its contributions to the economic, ecological, recreational, and human health of a community or locale. Waters of the U.S. are defined within the Clean Water Act (CWA) as amended, and jUJisdiction is addr ssed by the U.S. Environm ntal Prot ction Ag ncy (EPA) and th U.S. Army Corp of Engineer (USACE) (33 CFR Part 328).

Surface drainage at the propo ed CIS Facility site is contained within two local playa lake that have no external drainage. Runoff does not drain to one of state's major rivers. The only major natural lakes or ponds within 6 miles of the Site include Laguna Gatuna, Laguna Tonto, Laguna Plata, and Laguna To ton which are ephemeral playa . Surface runoff from the Site flow into Laguna Gatuna to the east and Laguna Plata to the northwest (ELEA 2007 , Section 2.4. l ). Surface water is lost through evaporation, resulting in high alinity conditions in soils associated with the playa ( ee Appendix D for more information concerning alinity in Site oil ). The e condition are not favorable for the development of viable aquatic or riparian habitats. Other than the playa the nearest urface water is the Peco River which is west of the Site. At its nearest approach, the distance from the Site to the P co River is 26 mil . Lik most riv rs in New Mexico, the Pecos River i de cribed a "extremely variable from year-to-year" due to it dependence on runoff. The principle use of Pecos River water is for agriculture. There are no sensitive or unique aquatic or riparian habitat or wetlands at the Site, nor is there surface water in the vicinity that is potable (EL A 2007 , Section 2.4) .

Th Site He within the Pecos River Ba in as presented in Figure 3.5. l which has a maximum basin width ofl30 miles, and a drainage area of 44,535 square miles. The Pecos River is the closest surface water feature to the Site. The principle use of Pecos River water is for agriculture. The main stem of the Pecos River and its major tributaries have low flow , and the tributary streams are frequently dry. Seventy-five percent of the total annual precipitation and 60 percent of the annual flow result from intense local thunderstorms between April and September (ELEA 2007).

The Pecos River originates in the mountains of northeast New Mexico. The northern most major r servoir is Santa Rosa Lake located on the Pecos River, 225 miles north of Carlsbad. The flow in the P cos River below Fort Sumner i regulated by storage in Sumner Lake, Brantley Reservoir Lake Avalon, and everal other mailer dams, such a Tans ill and Lower Tan ill Dams in the City of arlsbad. The vast majority of tributaries to the river flowing westward are unnamed an-oyos.

An xception is Pierce Canyon south of Malaga Bend that provide drainage into the Peco River.

Nash Draw, the large t surface drainage feature ea t of the Peco River in the region, i a clo ed depression and does not provide surface flow into the Pecos (ELEA 2007, Section 2.4.1).

Water quality in the Pecos River basin is affected by mineral dissolution from natural sources and from irrigation retmn flow . At Santa Rosa, New Mexico, the average uspended-sediment di charge to the river is 1,650 ton per day. Large amount of chlorides from Salt Creek and Bitter HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-38 91 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Creek enter the river near Roswell. River inflow in the Hagerman area contributes increased amounts of calcium, magnesium, and sulfate; and waters entering the river near Lake Arthur are al o high in ch loride (ELEA 2007, Section 2.4.1).

Below Brantley R servoir, pring that were ampled had total di solved solid concentrations of 3,350 to 4,000 mg/ I. Brine is generated and enters the Pecos River at Malaga Bend as the river contacts the Salado Formation adding an estimated 370 tons/day of chloride to the Pecos River (ELEA 2007, S ction 2.4.1).

3.5.2 Groundwater Grow1dwater is water that exists in the aturated zone beneath the earth's urface and includes underground tream and aquifer . It i an e ential re ource that fimction to recharge urface water and is used for drinking, inigation, and indu trial proce e . Groundwater features include depth from the surface, aquifer or well capacity, quality, recharge rate, and surrounding geologic formalions.

3.5.2.1 Site Groundwater The Site is located in the Capitan Underground Water Basin (UWB) as shown in Figure 3.5.2 (NMOSE 20 16). A declared groundwater ba in i an area of the tate proclaimed by the State Engineer to be underlying a groundwater so urce having reasonably ascerta inable boundaries. By such proclamation, the State Engineer assumes jurisdiction over the appropriation and u e of groundwater from th source. The Capitan UWB covers approximat ly 731,500 acre in th south-central portion of Lea Cou nty. rt i located within a geo logic province known as the Delaware Basin, a subdivision of the Permian Basin. The Capitan UWB is oriented in a northwest-southeast alignment above an arc- haped section of a formation known as the Capitan Reef Complex. The Capitan aquifer occur within dolomite and lime tone trata depo ited a an ancient reef The groundwater quality of the Capitan in Lea County is very poor, with total dissolved solids ranging from 10,065 to 165,000 mg/L.

Other aquifers in the Capitan UWB are found in the overlying Ru stler Formation, Santa Ro a Sand tone, Ogallala Formation, and Cenozoic alluvium and are important ources of groundwater in the Capitan UWB . The depth to the top of the Rustler Formation ranges from 900 to 1,100 feet.

Applications for new appropriations in the Capitan UWB are accepted by the Office of the State Engineer, although the high total di solved solid and depth to water have restricted the use of the water.

Evapo-transpiration at the Site is five times the precipitation rate, indicating that there i little infiltration of precipitation into the subsurface. Furthermore, the near smface water table appears to be 35-50 feet deep, where present and is likely controlled by the water level in the playa lakes.

Groundwater encountered o:n the ea t ide of the Site i brackish, exceeding l 0,000 part per million in total dissolved olid which i the New Mexico regulatory thre hold (NM Water Quality Control Commission Regulations, 20.6.2.3101A) for protected water. No groundwater has been encountered on the we t ide of the Site. There are numerou low permeability layer between the tu-face and the expected groundwater level (EL A 2007, Section 2.4.2).

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Well drilling was conducted at the Site in 2007. Two wells ELEA-1 and ELEA-2 were drilled on the Site to identify the depth and character of water-bearing rocks. The goals of the drilling investigation were to identify the potential for thin groundwater satu rat ion in lower alluvium perched on the Tria sic shale, or deeper groundwater aturation in the Triassic shale. Locations of these wells and other wells in the vicinity are shown on the well location map in Figure 3.5 .3.

Additionally, GEI Consultants drilled 3 monitoring wells to measure depth periodically during the subsurface exp loration completed in December of 2017 . Groundwater was observed in 8107 from a depth range of93.l to 100 feet , and in B10] from a depth range of 253.4 to 263 .7 feet. No groundwater was encountered in Bl06 (GEI 2017, Section 5.3). See Figure 3.5.4 for boring locations. Figure 3.5.5, 3.5.6, and 3.5.7 show the subsurface profiles for BlOl, Bl06, and Bl07.

Piezometer ELEA-1. A small amount of water was initially detected in the well; however the water has teadily declined to within a few inches of the bottom of the well and i attributed to the mall amount of bentonite hydration water that wa placed in the well to seal the upper annulus during completion. Based on the data obtained from ELEA-1, no shallow groundwater saturation is present at the top of the Triassic shale at the location (ELEA 2007, Section 2.4.2.2).

Piezometer ELEA-2. Water lev l in thi well ro e lowly over everal day to a tatic depth of34 feet below land urface (3,497 feet above mean sea level [amsl]). The water-bearing zone in this well consists of either fractures or tight sandy zone between the depths of 85 and l 00 feet; water in this zone is under artesian head of 50 feet. Laboratory analyses of water samples from the well indicate that the water i highly mineralized brine (ELEA 2007, Section 2.4.2 .2).

Ba ed upon information obtained from the on ite drilling, shallow alluvium i Like ly non-water-bearing at the Site. Groundwater saturation in the Triassic shale appears to be limited to small amounts of highly mineralized water likely associated with the brine in Laguna Ga tuna, where the brine i 3,500 feet ams) (ELEA 2007, Section 2.4.2.2).

3.5.2.1 Regional Groundwater Potable groundwater is available from three geologic units in southern Lea County; the Triassic Dockum shale, the Tertiary Ogallala, and Quaternary alluvium (Nicho lson and Cl b ch 1961). No potable groundwater is known to exist in the immediate vicinity of the Site. Shallow grou ndwater is present in a number of locations in the area, but water quality and quantity are marginal at best and mo t, if not all, hallow wells that have been drilled in tbe area are either abandoned or not currently in use. Potable water for the area is generally obtained from potash company pipeline that convey water to area potash refineries from Ogallala High Plain aquifer on the caprock area of east rn Lea County. At pre ent, water is generally obtain d from these pipelines for other area user .

Much of the hallow groundwater near the Site ha been directly or indirectly influenced by brine discharges from potash refining or oil and gas production. Potash mines have discharged thousand s of acre-feet of near-saturated refinery process brine to Laguna Plata and to Laguna Toston for many year . But di charge cea ed in Laguna Plata in the mid-1980 and in Laguna To ton by 2001. Laguna Gatuna was the site of multiple facilities for collection and discharge of brines that were co-produced from oil and gas wells in the entire area; facility permits authorized discharge of almost one million ban-el of oilfield brine per month between 1969 and 1992. As a result, HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-40 93 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment saturation of sha llow groundwater brine have been created in a number of areas associated with the playa lakes (ELEA 2007, Section 2.4.2.1).

3.5.3 Wetlands Wetlands are identified as those areas that are inundated or saturated by surface or groundwater at a frequency and duration ufficient to upport, and that und r normal circum tance do support, a prevalence of vegetation typically adapted for life in saturated o il condition . The USACE regulates the discharge of dredged or fill material into waters and wetlands of the U.S. pursuant to Section 404 of the CWA. No USACE jmisdictional wetlands were identified on the Site (ELBA 2007, Section 2.5).

3.5.4 Floodplains Floodplains are area of low-I v I grow1d pres nt along rivers, stream channels, or coastal waters subject to periodic or infrequent inundation due to rain or melting snow. Risk of flooding typically depends on local topography, the frequency of precipitation events, and the size of the watershed above the floodplain . Flood potential is evaluated by the F deral Emergency Management Agency (FEMA), which defin the 100-year floodplain a an area that ha a one percent chance of inundation by a flood event in any given year. Federal state and local regulations often limit floodplain development to passive uses such as recreational and preservation activities to reduce the ri k to human health and safety. Floodp lain co y tern functions include natural moderation of floods , flood storage and conveyance groundwater recharge, nutrient cyc ling, water quality maintenance, and diversification of plants and animals.

The proposed CIS Facility site or Lea County has no floodplain identified or mapped for Lea County, New Mexico (FEMA 2008, Section 6.0; FEMA 2016). Elevations in Lea County vary from 2,900 feet in the outbea t to 4,400 feet in the northwe t. Thi relief provide two urface water drainage basins in the county. The Texas Gulf Basin, located in the northern portion of Lea County, and the Pecos River Basin, located in the southern portion of the county, is separated by the Mescalero Ridge and its extended escarpment (ELEA 2007 , Section 2.5.1).

In Lea County neither of the two major drainage basins, the Texa Gulf Ba in in the north and a t and the Pecos River Basin in the south and west, contain large-scale surface-water bodies or through-flowing drainage systems. The surface water supplies that exist are tran itory and limited to quantitie of runoff impounded in short drainage way , shallow lakes, and small depressions, including various playa and lagunas. The Texas Gu lf Ba in contains a lake the Llano Estacado, and the Simona Valley. The Pecos River Basin contains the Querecho Plains, the Eunice Plains, and the Antelope Ridge (ELBA 2007, Section 2.5. l ).

The topography of the Site shows a high point located on the southern border oftbe Site and gentle slope leading to the two drainages (Laguna Plata and Laguna Gatuna). Both of the e drainages wou ld be ab le to accept a one-day evere torn, total within the 7.5 inch range with exces free board space. The natural drainage of the Site is useful by providing a natural area for impoundment of excess runoff during sever storms (ELBA 2007, S ction 2.5.1).

HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-41 94 of 558

ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Source: ELEA 2007, Section 2.4. 1.

Figure 3.5.1: PECOS RIVER BASIN DRAINAGE AREA HOLTEC INTERNATIONAL COPYRJGHTED MATERIAL Hl-2167521 I Rev. 4 3-42 95 of 558

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ATIACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility E nvironmenta l Report Chapter 3: Affected Environment Ed(fy Lea Suing:

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ATTACHMENT 5 TO HOL TEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment (b) (7)1F)

Figure 3.5.4: BORING LOCATION PLAN HOLTEC INTERNATIONAL COPYRIGIITED MATERIAL HJ-2167521 I Rev. 4 3-45 98 of 558

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.6 CLIMATOLOGY, METEOROLOGY, AIR QUALITY, AND NOISE This section presents data and information of the regional climatology, meteorology, a ir quality, and no ise around t he Site. Informat ion in this section w ill be used to eva luate the air qua lity and noise impacts of constructing and operating the CIS Facility at the Site. A key metric for the air quality analysis is to ensure that emissions are maintained below the National Ambient Air Quality Standards (NAAQS) for criteria pollutants and the New Mexico Ambient Air Quality Standards (NMAAQS) for all listed pollutants.

3.6.1 Regional Climatology and Meteorology The c limate at the Site is typically semi-arid with generally mild temperatures, low precipitation, low humidity, and with a high evaporation rate. The winter weather typically has high pressure systems that are located in the central part of the western U.S. and low-pressure systems located in north-centra l New Mexico. In the summer, the region is typ ically affected by low pressure systems located over Arizona. Overall, precipitation is low and storms are infrequent. Winds during the spring may cause dust during construction periods; however, it is anticipated to be a min imal and temporary impact in comparison to the naturally occurring dust.

Based on the season and the affected of high pressure systems or low-pressure systems, the pressure can affect temperature and cause cloud formation. Clouds are formed w hen warm, moist air rises into the atmosphere and the droplets are cooled. When the droplets cool, the water fro m the air condenses into tiny droplets and forms clouds. This occurs during low pressuJe system.

These low-pressure systems typically occur during the spring and summer.

Meteorological informat ion was obtained fro m various sources, including the Western Regiona l Climate Center (WRCC) and other sources as noted in this section. The use of the data from the WRCC and other sources are appropriate due to proximity to the proposed CIS Facility site and are expected to have similar climates (see Appendix A, Section A.2).

3.6.1.1 Temperatures Based on data collected over approximately the past 75 years at the Lea County Regional Airpo1t station, the annua l mean average temperature is approximately 61 ° Fa hrenheit (°F) with the mo nthly mean average temperatures ranging from 42°F in January to 80°F in Ju ly. T he highest mean average monthly maximum temperature is approximately 94°F and the lowest mean average monthly minimum temperature is approximately 28°F. The highest maximum temperature was 108°F occurring in July of 2000 and again in 200 1, and the lowest minimum temperature was -

11°F occurring in February of 195 1. A summary of this info rmation is presented in Table 3.6. 1 and depicted graphically in F igure 3.6. 1 (WRCC 2016).

3.6.1.2 Winds Prevailing wind directions and wind speeds at the Lea County Regional Airport station are presented in Table 3.6.2 and depicted graphi.c ally in Figure 3.6.2. Table 3.6.2 and Figure 3.6.2 are summaries of all data collected from 1948 to 20 14. Annual Wind Rose data from 1948 to 20 14 can be fo und in Appendix E; data was not avai lable for every year in that time frame. The average wind speed is approx imately 12 miles per hour (mph) and the prevailing wind direction is from HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-49 102 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment the south. Winds are typically moderate, between 1 mph and 19 mph blowing 84 percent of the time, with calm winds (winds less than 1.3 mph) occurring only approximately 8 percent of the time (WRCC 2016).

With respect to wind gusts, the average wind speed of the all the maximum gusts is approximately 25 mph. The prevailing wind direction for wind gusts is wind from southwest during 11 percent of the observations; however, the wind gusts are out of the south, south-southeast, and southeast during 30 percent of the observations. Typical gusts range in speed from 13 mph to 32 mph, comprising of 86 percent of the gusts. Gusts range in speed from 32 mph to 47 mpb occurred during 13 percent of the observations, and less than 1 percent of the gusts observed were over 47 mph (WRCC 2016).

3.6.1.3 Mixing Heights Mixing height is the height above the ground where the strong, vertical mixing of the atmosphere occurs. G.C. Holzworth developed mean annual morning and afternoon mixing heights for the contiguous United States (Holzworth 1972, Appendix B). The results of Holzworth 's calculation methods for mixing heights include mean annual morning and afternoon mixing heights at the Site of approximately 1,430 feet and 6,854 feet, respectively. Table 3.6.3 (Holzworth 1972, Appendix B) shows the average morning and afternoon mixing heights for Midland-Odessa, Texas, which is the nearest available area with mixing height data, located approximately 100 miles southeast.

3.6.1.4 Tornadoes Tornadoes are typically classified by the F-Scale classification. The F-Scale classification of tornadoes is based on the appearance ofthe damage that the tornado causes. The six classifications range from FO to F5 with an FO tornado having winds of 40-72 mph and an F5 tornado having winds of 261-318 mph (Geer 1996). Note that as of February 1, 2007, an enhanced F-scale for tornado damage went into effect in the United States. The switch to the enhanced F-scale involves:

1 Changing the averaging interval for wind speed estimates from the fastest quarter-mile wind speed to a maximum three-second average wind speed.

2 Changing the minimum tornado wind speed from 40 mph to 65 mph.

3 Changing the wind speed intervals associated with each F scale class.

The enhanced F-scale uses three-second wind gusts estimated at the point of damage based on a judgment of eight levels of damage to 28 indicators. The enhanced F-scale has six classifications, EFO to EF5, with an EFO tornado having three-second gusts of 65-85 miles per hour and an EF5 tornado having three-second gusts of over 200 miles per hour (NOAA 2016).

Based on a U.S.-wide study performed on a state by state basis, the average tornado probabi lity for any F-scale tornado for the Site is between lxl0*6 and 2xl 0*4, as is presented in Figure 3.6.3 (ELEA 2007, Secti.o n 2.2.1.4). No tornadoes of FO or higher scale have occurred w ithin 1,000 square miles (comprised of portions of Eddy and Lea counties) of the Site in the five years ending in 2015 (THP 2016).

Ninety two tornados have occurred in Eddy and Lea counties since 1954. The highest number of tornados in any given year was 15 in 1991 ; of which, 14 occurred over a two day period. The HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-50 103 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment lowest number of tornado in a year has been zero, with a mean average of 1.5 tornados occurring in a year. Most tornados recorded were FO in scale and occur in the spring (THP 2016).

3.6.1.5 Hurricanes The Site is located over 500 miles from the oceanic coast. Because hurricanes lose their intensity quickly once they pass over land, impacts from a hurricane at the Site are unlikely.

3.6.1.6 Thunderstorms Thunderstorms can occur during every month of the year, but generally occur from March through October of each year. Thunderstorms occm an average of 39 days per year in Carlsbad, New Mexico. The seasonal averages are: 2.7 days in spring (March through May); 8.3 days in summer (June through August); 2.3 days in fall (September through November); and less than 1 day in winter (December through February) (WRCC 2016).

3.6.1.7 Precipitation A summary of rainfall data collected at the Lea County Regional Airport station resulted in an annual mean average total rainfall of 10.2 inches with monthly mean average totals ranging from 0.24 inches in March to 1.9 inches in September. The monthly minimum total is 0.00 inches and the monthly maximum total is 6.2 inches. The highest daily total is 3.6 inches occurring in December of 2015. A summary of this information is presented in Table 3.6.4 and depicted graphically w ith monthly average total rainfall in F igure 3.6.4. (WRCC 2016).

A summary of snowfall data collected at the Lea County Regional Airport station resu lted in an annual mean average total rainfall of 5. 13 inches with monthly mean average totals ranging from 1.84 inches in February to 0.0 inches from May to October. The monthly minimum total is 0.00 inches and the monthly maximum total is 21.2 inches. T he highest dai ly total is 10.00 inches occurring in February of 1956. A summary of this information is presented in Table 3.6.5. (WRCC 20 16).

3.6.2 Air Quality To assess air quality, the EPA uses six criteria air pollutants with maximum concentrations as a baseline. The criteria pollutants are ozone (03), carbon monoxide (CO), nitrogen dioxide (N02),

sulfur dioxide (SOs), particulate matter (PM), and lead (Pb). The maximum allowable concentrations for these criteria pollutants are the NAAQS. The current NAAQS are presented in Table 3.6.5 (EPA 2016a).

The State of New Mexico also has New Mexico Ambient Air Quality Standards (NMAAQS) and Significance Levels to assess air quality. The NMAAQS pollutants are carbon monoxide, hydrogen sulfide, nitrogen dioxide, total suspended particulate matter, sulfur dioxide, and total reduced sulfur (except for hydrogen sulfide). New Mexico also has Significance Levels to assess air quality for nonattainment areas. The pollutants with Significance Levels are carbon monoxide, hydrogen sulfide, lead, nitrogen dioxide, ozone, particu late matter, total suspended particulate matter, sulfur dioxide, and non-methane hydrocarbons. The current NMAAQS and Significance Levels maximum allowable concentrations are presented in Table 3.6.6 (NMED 2010, Section 2.5).

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-5 1 104 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment One exceedance of the NAAQS maximum 24-hour limit was reported in Hobbs, New Mexico, for particulate matter in 2003 due to a natural event - a dust storm. Conective actions were taken by the state of New Mexico. According to NAAQS, one exceedance of this limit is allowed per year (EPA 2016a).

The NMED collects data from emission sources each year to determine compliance with NAAQS.

These emissions are also considered background emissions and are presented in Table 3.6.7 for Lea County, location of the proposed Site; and the surrounding New Mexico Counties of Eddy, Roosevelt, and Chaves (NMED 2016).

Based on EPA information, the region within 50 miles of the Site is in attainment for all of the criteria po llutants as demonstrated in Figure 3.6.6 (EPA 20 16b).

3.6.2.1 Dispersion For normal and off-normal conditions, an atmospheric dispersion coefficient is calculated using D-stability and a wind speed of 5m/sec and a 1OOm distance to the controlled area boundary. The controlled area boundary is more than 100m from the site so the use of 100m is conservative. For accident conditions, a dispers ion coefficient is ca lculated using F-stability and a w ind speed of l m/sec. These atmospheric conditions are consistent with the guidance of NUREG-1536 (NRC 2010) and NUREG-1567 (NRC 2000a). The smallest vertical plane cross-sectional area of one horizontal underground storage module (SM) is conservatively used as the vertical plane cross-sectional area of the underground storage modu le (SM): area = SM Width X SM Height; thus:

2.95m X 0.38m = 13.47m2* The atmospheric dispersion coefficients can be determined through selective use of Equations 1, 2, and 3 of Regulatory Guide 1.145 (NRC 1981).

With the three values of x/Q determined, the higher x!Q value of the first two (Equation 1 and Equation 2) is compared with the last one (Equation 3) and the lower of those two is evaluated as the appropriate atmospheric dispersion coefficient per in Regu latory Guide 1.145 (NRC 1981).

The parameters used and the calculated atmospheric dispersion coefficients are summarized in Table 3.6.8.

3.6.2.2 Stability Stability c lasses can be used to assess dispersion of materials released into the atmosphere.

Dispersion of materials is affected by the stability class of the atmosphere. The Pasquill-Gifford stability categories (Table 3.6.9) are used to detem1ine stability. Distributions of wind speed and direction, the amount of incoming so lar radiation, and other factors are used to determine the stability of the atmosphere. Pasquill-Gifford have defined atmospheric stability classes, each representing a different degree of turbulence in the atmosphere. When moderate to strong incoming solar radiation heats air near the ground, causing it to rise and generate large eddies, the atmosphere is considered unstable, or relative ly turbulent. Unstable conditions are associated with atmospheric stability c lasses A and B. When solar radiation is relatively weak or absent, air near the surface has a reduced tendency to rise, and less turbulence develops. In this case, the atmosphere is considered stable, or less turbulent, and the stability class would be E or F. Stability c lasses D and C represent cond itions of more neutral stability, or moderate turbu lence. Neutral cond itions are associated with re lative ly strong wind speeds and moderate solar radiation.

Atmospheric stability classes are listed in Table 3.6. l 0.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.6.3 Noise The purpose of this section is to provide information to assess the impacts of noise at the Site during construction, operation, and decommissioning. Noise levels at the Site will be principally created by construction equipment and traffic on nearby roads. After construction, most noise is expected to be traffic related. Since the Site is over one-half mile from U.S. Highway 62/ 180 and the surrounding area is comprised of rural land with oil and gas well development, construction noise impacts are expected to be low. A list of typical community sound levels and noise levels of common sources is shown on Table 3.6.11 (IIFP 2009, Section 3.7).

The Noise Control Act of 1972 requires the EPA to publish information on the acceptable levels of environmental noise fo r the protection of the public (ELEA 2007, Section 2.9). Following these guidelines, the Department of Housing and Urban Development (HUD) developed Noise Assessment Guidelines presented in Table 3.6.12 (HUD 2016). The EPA has defined a goal of 55 A-weighted decibels (dBA) for Ldn in outdoor spaces, as described in the EPA Levels Document (EPA 1973, Section 5). HUD has developed land use compatibility guidelines for acceptable noise versus the specific land use. However, both the Noise Control Act and the HUD Noise Assessment Guidelines do not provide guidance for areas away from population areas such as the Site. Because no guidelines exist for construction activities in non-populated areas and no guidelines exist for the county or state control of noise levels, the Site is not subject to noise requirements; however, the HUD Noise Assessment Guidelines will be used in assessing noise from the Site.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-53 106 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.1:

LEA COUNTY REGIONAL AIRPORT STATION TEMPERATURE DATA (09/01/1941-06/09/2016)

Average Average Monthly Monthly Average Extreme Extreme Minimum Maximum Monthly Minimum Maximum Month Temperature °F Temperature °F Temperature 0 f Temperature 0 f Temperature 0 f January 27.72 56.25 41.98 4.00 81.00 February 30.68 6 1.1 2 45.90 -1 1.00 84.00 March 35.67 67.32 51.53 14.00 86.00 April 44.32 75.05 59.69 24.00 93.00 May 53.77 84.05 68.91 28.00 103.00 June 63 .7 1 92.90 78.31 5 1.00 107.00 July 66.73 93.62 80.1 7 52.00 108.00 August 65.50 92.57 79.04 55.00 104.00 September 58.29 86.47 72.37 41.00 104.00 October 47.82 75.76 6 1.79 24.00 94.00 November 34.23 64.42 49.33 4.00 85.00 December 28.78 59.04 43.91 7.00 79.00 Annual 46.34 76.03 6 1.1 9 -1 1.00 108.0 Source: WRCC 2016.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-54 107 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.2:

LEA COUNTY REGIONAL AIRPORT STATION ALL WIND DATA 12/0 l/l 948-12/ 31/2014)

Wind Speed N NNE NE ENE E ESE SE SSE s SSW SW WSW w WNW NW NNW Total

(%) (%) (%) (%) ('Y* ) ("I.) (% ) (%) (%) (% ) (%) (%) ("I.) (%) (%) (%) (%)

(mph) 1.3-4 0.1 0.1 0.2 0.1 0.2 0.2 0.2 0.2 0.3 0.2 0.2 0. 1 0.1 0.1 0.1 0.1 2.5 4-8 I 0.8 0.9 0.7 1.8 1.3 1.4 1.4 2.7 1.7 1.3 0.9 0.6 0.5 0.6 0.5 18.2 8-13 2 1.5 1.7 1.5 3 2.8 3.9 4.5 6.2 3.4 2.8 2.3 1.7 1.2 I. I 0.9 40.4 13-19 1.4 1.2 I.I 0.6 I.I 1.2 2.2 2.8 2.9 1.6 1.9 1.8 I 0.7 0.6 0.5 22.7 19-25 0.5 0.4 0.2 0.1 0.1 0.1 0.3 0.6 0.4 0.4 0.7 0.7 0.4 0.3 0.2 0.2 5.6 25-32 0.2 0. 1 0.1 0 0 0 0 0. 1 0.1 0. 1 0.2 0.3 0.1 0. 1 0. 1 0.1 1.7 32-39 0 0 0 0 0 0 0 0 0 0 0 0. 1 0 0 0 0 0.4 39-47 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.1 47+ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total 5.3 4.1 4.1 3.1 6.2 5.7 7.9 9.5 12.6 7.5 7.2 6.4 3.9 3 2.7 2.3 91.5

(%)

Avg.

Wind 12.6 12.4 11.4 10.5 10.0 10.5 11.3 11.9 11.0 l l.3 12.9 14.1 12.8 13.4 11.9 12.3 10.8 Speed (mph)

Source: WRCC 2016.

NOTE: Total Calm Winds (Calm Winds is defined as less than 1.3 mph) is 8.4 percent.

NOTE 2: The meteorological tower wind data height was IO meters.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-55 108 of 558

ATTACHMEN T 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.3:

AVERAGE MORNING AND AVERAGE AFTERNOON MIXING HEIGHTS Winter Spring Summer Autumn Annual (feet) (feet) (feet) (feet) (feet)

Morning 951 1,407 1,988 1,375 1,430 Afternoon 4, 186 8,035 9,003 6, 191 6,854 Source : Holzworth 1972, Appendix B.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.4:

LEA COUNTY REGIONAL AIRPORT STATION PRECIPITATION DATA (09/01/1941-06/09/2016)

Monthly Extreme Daily Monthly Monthly Average Maximum Minimum Maximum Totals Totals Totals Totals (Inches)

Month (Inches) (Inches) (Inches)

January 0.00 2.09 0.3 1 0.68 February 0.00 1.02 0.32 0.68 March 0.00 1.41 0.24 0.52 April 0.00 2.26 0.65 1.40 May 0.00 5.02 1.43 1.72 June 0.00 3. 19 0.75 1.77 July 0.00 3.49 1.17 1.98 August 0.04 4.08 1.32 2.28 September 0.05 5.84 1.85 2.1 3 October 0.00 3.81 1.52 1.73 November 0.00 1.07 0.26 0.95 December 0.00 6.2 1 0.56 3.63 Annual 2.81 18.66 10. 16 3.63 Source: WRCC 2016.

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.5:

LEA COUNTY REGIONAL AIRPORT STATION SNOWFALL DATA (09/01/1941-06/09/2016)

Monthly Monthly Monthly Extreme Daily Minimum Maximum Average Maximum Totals Totals Totals Totals Month (Inches) (Inches) (Inches) (Inches)

January 0.00 9.00 1.06 6.00 February 0.00 21.20 l.84 10.00 March 0.00 13.00 0.97 8.00 April 0.00 0.80 0.05 1.00 May 0.00 0.00 0.00 0.00 June 0.00 0.00 0.00 0.00 July 0.00 0.00 0.00 0.00 August 0.00 0.00 0.00 0.00 September 0.00 0.00 0.00 0.00 October 0.00 0.00 0.00 0.00 November 0.00 7.00 0.44 4.00 December 0.00 8.30 0.6 I 9.00 Annual 0.00 29.00 5.1 3 10.00 Source: WRCC 2016.

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.6:

NATIONAL AND NEW MEXICO AMBIENT AIR QUALITY STANDARDS AND NEW MEXICO SIGNIFICANCE LEVELS Primary/ Averaging Significance Level 1 Pollutant Secondary Time NAAQS (µg/m3) NMAAQS 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 9 ppm 2 500 8. 7 ppm

!Carbon Monoxide (CO) primary I hour 35 ppm 2 2000 13.1 ppm I hour 1.0 0.0 10 ppm 2

  • 3 Hydrogen Sulfide (H2S) 'h hour 5.0 0.10 ppm 4

'h hour 5.0 0.030 ppm 6 primary and Rolling)

Lead (Pb) 0.03 secondary month averagf primary and I year 53 ppb 7 1.0 0.050 ppm secondary

!Nitrogen Dioxide (N0 2) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 5.0 0.10 ppm primary I hour 100 ppb 1.0 primary and

!Ozone (03) 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 0.070 ppm 8 secondary primary I year 12.0 ~tg/m3 secondary I year 15.0 ~tg/1113 0.30 IPM2.s primary and Particulate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 35 ~tg/m 3 1.17 secondary Matter (PM)

I year 1.0 PM10 primary and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 150 µg/m 32 secondary I year 1.0 60 µg/m 3 Total Suspended 30 day 90 µg/m 3 Particulates (TSP) 7 day 110 µg/111 3 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 5.0 150 ~tg/m3 I year 1.0 0.02 ppm 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 5.0 0.IOppm

~ulfur Dioxide (S02) secondary 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 0.5 ppm 25.0 primary I hour 75 ppb 9 Total Reduced Sulfur 'h hour 0.003 ppm 3 Except Hydrogen Sulfide

'h hour 0.010 ppm 4 Non-Methane 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 5.0 Hydrocarbons HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-59 112 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Source EPA 2016a and NMED 2010, Section 2.5.

I Significance levels as listed in 20.2. 72.500 NMAC.

2 Not to be exceeded more than once per year.

3 For the state, except for the Pecos-Permian Basin Interstate Air Quality Control Region (AQCR).

4 For the Pecos-Permian Basin Interstate AQCR.

5 In areas designated nonattainmen.t for the Pb standards prior to the promulgation of the current (2008) standards, and for which implementation plans to attain or maintain the cu1Tcnt (2008) standards have not been submitted and approved, the previous standards (1.5 ~tg/m3 as a calendar quarter average) also remain in effect.

6 For within 5 miles of the corporate city limits of municipalities within the Pecos-Permian Basin Interstate AQCR or of municipalities with a population greater than 20,000.

7 The level of the annual N02 standard is 0.053 ppm. It is shown here in terms of ppb for the purposes of clearer comparison to the I-hour standard level.

8 Final rule signed October I, 20 15, and effective December 28, 2015. The previous (2008) 03 standards additionally remain in effect in some areas. Revocation of the previous (2008) 03 standards and transitioning to the current (20 15) standards will be addressed in the implementation rule for the current standards.

9 The previous S02 standards (0. 14 ppm 24-hour and 0.03 ppm annual) will additionally remain in effect in certain areas: (I) any area for which it is not yet I year since the effective date of designation under the current (20 I 0) standards, and (2)any area for which implementation plans providing for attainment of the current (20 I0) standard have not been submitted and approved and which is designated nonattainment under the previous S02 standards or is not meeting the requirements ofa SIP call under the previous S02 standards (40 CFR 50.4(3)), A SIP call is an EPA action requiring a state to resubmit all or part of its State Implementation Plan to demonstrate attainment of the require NAAQS.

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ATTACHMEN T 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6. 7:

NMED EMISSION TOTALS BY COUNTY FOR 2015 Total Emission (Tons Per Year)

County co N0 2 S02 voe PM Pb Lea 2,903.8 7,684.7 6,389.6 1,542.1 197.7 0.0 Eddy 1,409.7 2,315.3 1,051.6 2,267.2 195.3 0.0 Roosevelt 21.4 22.6 3.4 1.3 18.7 0.0 Chaves 99.9 233.5 0.1 85.4 1.3 0.0 Source: NMED 2016.

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.8 ATMOSPHERIC DISPERSION COEFFICIENTS PARAMETER NORMAL/OFF-NORMAL ACCIDENT Parameter Normal/Off-Normal Accident Stabilitv D F U (m/sec) 5 1 A (m2) 13.47 13.47 crv (m) 8 4 crz (m) 4.6 2.3 M I . 122 4 Equation 1 (sec/ml) 0.00 1635 0.02806 Eauation 2 (sec/ml) 0.0005766 0.01 153 Equation 3 (sec/ml) 0.00 1542 0.00865 x/Q (sec/ml) 0.00 1542 0.00865 Source: Regulatory Guide 1.145 (NRC 1981)

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.9:

PASOUILL-GIFFORD STABILITY CATEGORIES Surface Wind Day Incoming Day Incoming Day Incoming Night* Night*

(Measured at Solar Solar Solar {Thin Overcast (<= 3/8 10m) (mph) Radiation Radiation Radiation or >= 4/8 Cloudiness)

(Jnsolation) (Insolution) (Insulation) Cloudiness)

(Stron!!:) (Moderate) (S1i2:ht)

<4.5 A A-B B E E 4.5-6.7 A-B B C E E 6.7-11.2 B B-C C D E 11.2-13.4 C C-D D D D 13.4 C D D D D

  • Night is defined as t he period from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> before sunset to 1 hr after sunrise Source: UTED 2017 HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-63 116 of 558

ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.10 PERCENT FREQUENCY OF OCCURENCE OF ATMOSPHERIC STABILITY CLASSES FOR HOBBSs, NEW MEXICO A REA Stability Class Percent Frequency of Occurrence A 0.4 B 3.8 C 12.3 D 52. 1 E 18.4 F 13.7 HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-64 117 of 558

ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.11:

NOISE LEVELS OF COMMON SOURCES Sound Source Sound Pressure Level (dBA)

Air Raid Siren at 50 Feet 120 Maximum Levels at Rock Concerts (Rear Seats) 110 On Platform by Passing Subway Train 100 On Sidewalk by Passing Heavy Truck or Bus 90 On Sidewalk by Typical Highway 80 On Sidewalk bv Passing Automobiles with Mufflers 70 Typical Urban Area 60-70 Typical Suburban Area 50-60 Quiet Suburban Area at Night 40-50 Typical Rural Area at Night 30-40 Isolated Broadcast Studio 20 Audiometric (Hearing Testing) Booth 10 Threshold of Hearing 0 Source: II FP 2009.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.6.12:

HUD NOISE ASSESSMENT GUlDELINES HUD Land Use Compatibility GuJdelines for Noise Sound Pressure Level (dBA L dn Clearly Norma lly Normally Clearly Land Use Cate2orv Acceptable Acceptable Unacceptable Unacceptable Residential <60 60-65 65-75 >75 Livestock Farming <60 60-75 75-80 >80 Office Buildings <65 65-75 75-80 >80 Wholesale, Industrial, Manufacturing, <70 70-80 80-85 >85

& Utilities Source: HUD 2016.

dBA = decibels A-weighted.

Lon = day-night sound level HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-66 119 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment HOBBS LEA CO AP, NEW MEXICO (294028)

Period of Record: 09/01/1941 to 06/09/2016 40 30 20 10 0

-10

-20 I

Jan 1 Mar 1 Ma!::J 1 Jul 1 Sep 1 Nov 1 Dec 31 Feb 1 Apr 1 Jun 1 Aug 1 Oct 1 Dec 1 Day of Year Re9ionQl

( Ext re111e Max - - Ave Max - Ave Min Extre111e Min) Cli=h Cente.-

Source: WRCC 2016.

Figure 3.6.1: LEA COUNTY REGIONAL AIRPORT STATION TEMPERATURE DATA (09/01/1941-06/09/2016)

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ATTAC HMENT 5 TO HOLTEC LETTE R 5025040 Holtec CIS Facil ity Environmental Report Chapter 3: Affected Environment Station Hobbs New Mexico MPH 32° 41' 15" t-1 1.3 - 4 Latitude Longitude : 103° 13 ' 01" ',l N 4 - 8 Elevation : 3661 ft . 18% 8 - 13 13 - 19 Element 19 - 25 15% 25 - 32 32 - 39 39 - 47 12% 47 +

9%

6%

E Start Dat e: Dec. l, 1948 Sub-interval \olincicTII':;

End Date: Dec. 31, 2014 Start End f of Day:; : 24137 of 2413 7 f obs:poss: 82579 of 579288 s Date: Jan . 01 Dec. 31 Hour: 00 23 Western Regional Climate Center Source: WRCC 20 I6.

Figure 3.6.2: LEA COUNTY REGIONAL AIRPORT STATION ALL WIND ROSE (12/0l/1948-12/31/2014)

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment LEGEND *

~ -. :.;.!II LOW COLOR HIGH 4*10-4 . 5-to-4 Ho-4

  • 4,10-4 2-10-4 Cl 3.1()"'1 J.Lo-4 D 2-l o-4 5.10-S O 1-lo-4 H o-S O s- 10-S
  • 1-io-6 D 1-10-s
  • 1- 10-6
  • PER YEAR Source: ELEA 2007, Section 2.2. I .4.

Figure 3.6.3: TORNADO PROBABILITY MAP HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-69 122 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment HOBBS LEA CO AP, NEW MEXICO (294028)

Period of Record: 09/01/1941 to 06/09/2016 2, 5 -----------------------,

Jan Mar Ma~ Jul Sep Nov Feb Apr Jun Aug Oct Dec Day of Year Meste!'n Regional

( Average Total Monthl~ Precipitation J Cli11>::1h Cente!'

Source: WRCC 20 16.

Figure 3.6.4: MONTHLY AVERAGE TOTAL PRECIPITATION LEA COUNTY REGIONAL AIRPORT STATION (09/01/1941-06/09/2016)

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Counties Designated "Nonattainment" for Clean Air Act's National Ambient Air Quality Standards (NAAQS)

  • Legend**

County Designated Nonattainment for 6 NAAQS Pollutants County Designated Nonattainment for 5 NAAQS Pollutants County Designated Nonattainment for 4 NAAQS Pollutants County Designated Nonattainment for 3 NAAQS Pollutants

- County Designated Nonattainment for 2 NAAQS Pollutants

- County Designated Nonattainment for 1 NAAQS Pollutant Guam - Piti and Tanguisson Counties are designated nonattainment for the S02 NAAQS

  • The National Ambient Air Quality Standards (NAAQS) are health standards for Carbon Monoxide, Lead (1978 and 2008), Nitrogen Dioxide, 8-hour Ozone (2008), Particulate Matter (PM-10 and PM-2.5 (1997, 2006 and 2012), and Sulfur Dioxide.(1971 and 2010)
    • Included in the counts are counties designated for NAAQS and revised NAAQS pollutants.

Revoked 1-hour (1979) and 8-hour Ozone (1997) are excluded. Partial counties, those with part of the county designated nonattainment and part attainment, are shown as full counties on the map.

Source EPA 2016b.

Figure 3.6.5: NONATTAINMENT AREAS MAP HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-71 124 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.7 CULTURAL RESOURCES 3.7.1 Background Due to the required licensing by the Nuclear Regulatory Commission (NRC), this project is subject to Section 106 of the National Historic Preservation Act (NHPA) of 1966, as amended, and its implementing regulations in Title 36, Section 800 (and following section), of the Code of Federal Regulations (CFR) (36 CFR § 800 et seq.). Pursuant to these regulations, the NRC must take into account the effects of the proposed undertaking on " historic properties"; that is, cultural resources included in or eligible for listing in the National Register of Historic Places (NRHP). To accomplish this, the NRC must first identify cultural resources that may be affected by the undertaking and then evaluate these resources to determine whether they are historic properties and, which are prehistoric and historical-period sites, buildings, structures, districts, a nd objects listed in, or eligible for listing in the NRHP. Holtec anticipates that the NRC would issue the Final Environmental Impact Statement and License by 2019. Thus, cultural resources that will be 45 years or older by 2019 will need to be eva luated for listing in the NRHP as part of the ide ntification of historic properties.

The Area ofPotential Effects (APE) for direct impacts to historic properties is the project footprint, which includes the CIS Facility and appurtenant infrastructure such as access roads and fence lines.

With respect to the APE for direct impacts, this ER contains information for the main CIS Facility site where facilit ies would be located, as well as the rail spur and access road corridors (see Figure 2.1 ). The APE for indirect or visual impacts to historic prope11ies is dependent on the location, size, and scale of the project. Because of the extremely low height of facilities associated with the CIS Facility, this ER uses a 1-rnile radius around the Project footprint for the APE for indirect or visual impacts to historic prope11ies.

3.7.2 Cultural Setting The APE is situated within the Mescalero Plain of southeastern New Mexico in Lea County. The earliest evidence of human occupation in the Mescalero Plain dated to the Paleoindian period (ca.

10,000- 6000 B.C.). Paleo indian period populations are traditionally characterized as highly mobi le groups that primarily hunted bison. The Archaic period (ca. 6000 B.C.- A.D. 500) encompasses a wide time-depth and is traditionally divided into Early, Middle, and Late periods, based on variations in projectile point typology and paleo-environmental conditions. The Formative period (pre-A.D. 500- 1500) is marked by the introduction of ceramic techno logy, the appearance of the bow and aITow, the intensification of maize agriculture, and the adoption of a more-sedentary way of life. Early Spanish explorers travelled through portions of southeastern New Mexico during expeditions conducted around the mid-sixteenth century, while the period from 1650 to l 800 was host to several Spanish mi litary expeditions that entered southeastern New Mexico to commercially engage w ith the Jumanos. Recorders of those expeditions also described encounters with Apache groups. Subsequently, Euro-American settlers attracted by available grazing land migrated into southeastern New Mexico and had established livestock ranches in the area by the mid-nineteenth century. Potash mining became a prominent industry in the area during the 1920s and continues into the present day. The Carlsbad area became the focus of oil and gas development with the establishment of the El Paso Natural Gas Company in 1928, and an emphasis HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-72 125 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment on extractive activities has remained a mainstay ofthe local economy for a lmost a century (Murrell 2015).

3.7.3 Analyses The analytical process to identify historic properties in this ER included perfonning a search of existing records, conducting an intensive pedestrian survey, evaluating cultural resources identified within t he direct APE for listing in the NRHP, and providing previous recorders' NRHP recommendations for the cultural resources within the indirect APE.

3.7.4 Records Search On November 30, 2016, Statistical Research, Inc. (SRI), performed a records search of the land within the direct and indirect APEs through the New Mexico Cultural Resources Information System (NMCRIS), a digital repository of the Archaeological Records Management Sections (ARMS) of the New Mexico Historic Preservation Division (NMHPD)/office of the State Historic Preservation Officer.

The direct APE boundary for this search was based on an approximately 290-acre extent for the CIS Facility facilities, as derived from proposed layout documentation provided by Holtec. The indirect APE is a 1-mile buffer around the direct APE and totals 10,891 acres.

The record search revealed that 91 cultural resource investigations have been conducted w ithin the APEs (Table 3.7.1), with pottions of 12 investigations extending into the APE of direct impacts.

The records search provide that 42 cultural resources have been previously identified within the APEs (Table 3.7.2), with two of them intersecting the APE of direct impacts. These two sites area a prehistoric artifact scatter and a historical-period rail line segment; both have an undetermined NRHP eligibility status. Of the 40 cultural resources identified within the indirect APE, 14 are eligible for listing in the NRHP, seven are not e ligible for listing in the NRHP, 18 have an undetermined NRHP status, and one site has no NRHP status.

3.7.5 Pedestrian Survey From December 6 to 9, 2016, SRI conducted an intensive pedestrian survey of the 290. 11 acres of the CIS Facility and appurtenant fac ilities. SRI holds a Genera l Archaeologica l Permit (No.17-135) with the NMHPD and a Cultural Resource Use Permit (No. 159-2920-14-M) with the U.S.

Department of the Interior Bureau of Land Management (BLM). All cultural resource fieldwork and subsequent repo1ting entirely conformed to the New Mexico Standards for Survey and Inventory (New Mexico Administrative Code, Title 4, Chapter 10, Part 15 [4.10.15 NMAC]).

Methods derived from BLM Manual Supplement H-8100-1 and ELM-Carlsbad Field Office (BLM-CFO) standards were also applied to the entire project area, for consistency. The survey was directed by Dr. Timothy Mills (Registered Professional Archaeologist [RPA] No. 28577206) and Amanda Hernandez (RP A No. 37450280), who are both listed in the NMHPD's Directory of Qualified Supervisory Personnel under Archaeology.

The primary goal ofconducting the survey was to identify and document all cultural manifestations within the APE for direct impacts. Transects were spaced at 15 m. The crew's positions were monitored using a mapping-grade Trimble GeoXH Global Positioning System (GPS) unit that included the location of the survey parcel and any previously recorded cultural resources. All HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-73 126 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment cultural manifestation that qualified as Isolated Occurrences (IOs) observed at the proposed Site were recorded as they were encountered during the pedestrian survey. These instances were point-provenienced and fully documented, in terms of the range of items present, including characterist ics that are temporally diagnostic. Archaeo logical sites discovered during the survey were plotted using a Trimble GPS unit, and marked using pin flags and flagging tape. A permanent datum consisting of a capped rebar, including the SRI field site number and recording date, were set at each archaeo logical site recorded in the Site.

The survey resulted in the identification of 17 !Os and 4 cultural resources: 1 previously recorded prehistoric archaeological site (artifact scatter), l newly discovered archaeological site (campsite),

1 previously recorded historical-period linear resource (rail-line segment), and l newly discovered historical-period linear resource (two-track-road segment). SRI recommends the two archaeological sites (a1tifact scatter and campsite) e ligible for listing in the NRHP.

The results of this survey are included in Appendix C.

3.7.6 Historic Properties Through the records search and the intensive pedestrian survey, SRI identified two historic prope1ties that cou ld be directly affected by this project.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.7.1:

CULTURAL RESOURCE INVESTIGATIONS WITHIN THE APE Activity Author Year Title APE No.

393 Laumbach, 1979 Laguna Plat Archaeological District Form for Bureau of Land indirect only K.W. Management 394 Brett, Linda, 1982 Archaeological Clearance Report for the State Highway indirect only and William Department Proposed Widening of State Highway 62-180 B. Sanders 4 11 Hilley, Carol 1982 An Archaeological Clearance Survey of Seismic Testing Transects indirect only G. in Chaves, Eddy and Lea Counties, New Mexico 493 Towner, R. 1982 El Paso Natural Gas Company indirect only H.

1151 Haskell, J. 1980 Archaeological Clearance Report for Bass Enterprises Production indirect only Loring Company Quarry, Section 15, T2*0S, R32E, NMPM, Lea County, New Mexico 1175 Clifton, Don 1982 Culniral Resource Investigations at Ten Proposed Materials Pits in indirect only Lea County, New Mexico 1226 Jones, D., and 197 Site Survey, Laguna Toston indirect only others 1232 Drobka, 1982 Miss Connection Pipeline to Existing Trough indirect only Dianna 1235 Botsford, M. 1977 Easement for General Telephone Company of the Southwest indirect only L.

1525 Clifion, Don 1983 A Cultural Resource Survey of Borrow Pit B Extension, Borrow indirect only Pit C Extension, and the Waste Isolation Project Entrance in Lea County, New Mexico 1625 Haskell, J. L. 1982 El Paso Natural Gas Company indirect only 1627 Clifton, Don 1982 Cultural Resource bivestigations at a Proposed Materials Pit and indirect only Associated Haul Road in Lea County, New Mexico, NMSHD Project No. ST-(F)-022-2(203) 1632 Kyte, M. 1982 Western Geophysical Line C Segment No. I and No. 2 Line indirect only Segment No. I 1843 Brett, L. 1984 Texaco Seismic Line 98 indirect only 2795 Haskell, J. L. 1984 Saltwater Disposal Line for Tenneco Oil indirect only 7584 Michalik, 1983 An Archaeological Survey of Seven Borrow Pits, Nine Haul indirect only Laura Roads, One Yard Area and A Caliche Pit in Lea County, New Mexico 10700 Duran, M. S., 1985 Five Seismic Testing Transects for Strata Search direct and and others indirect 11369 Martin, 1985 Archaeological Clearance Report for Geo-Search Corporation indirect only Joseoh P. Teas DeeD Recon NM4642-1 Teas Deeo Recon NM4642-2 16811 Bradley, 8. 1982 Water Pipeline Waste Isolation Pilot Project for U.S. Army Corps direct and A. of Engineers indirect 18597 Haskell, J. L. 1987 Tract B Plata Waste Water Disposal Project for Petro-Thermal indirect only Corporation 21560 Ma11in, R. J. 1988 Snyder Ranches Saltwater Line indirect only 23164 Botsford 1977 C. W. Trainer indirect only Manton 23997 Haskell, J. L. 1987 Tract A Plata Waste Water Disposal Project for Petro-Thermal indirect only Corporation 26194 Maclennan, 1980 ROW No. 79 1034/DWG 3745.0-64-1,2,3 for El Paso Natural Gas indirect only R.B. ComDany HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-75 128 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.7.1:

CULTURAL RESOURCE INVESTIGATIONS WITHIN THE APE Activity Author Year Tide APE No.

27957 Martin, R. J. 1989 Salt Water Disposal Pipeline for Laguna Gatuna, Inc. indirect only 28259 Haskell, J. L. 1989 7427- 195 Power Line for Southwestern Public Service Company indirect only 3 1565 Doebley, 1975 An Archaeological Survey of the Proposed Caprock Watersystern direct and John F. Pioeline ROW in Southeastern New Mexico indirect 32437 Hunt, J.E., 1990 Seismic Testing Linc No. SB for Western Geophysical direct and and others indirect 32605 Hunt, J.E. 1990 Seismic Testing Line No. 38 for Western Geophysical direct and indirect 32901 Hunt, J.E., 1990 Spec Seismic Testing Line for Western Geophysical direct and and others indirect 36238 Haskell, J. L. 1991 7694- l 95 Power Line and 7701- 195 Power Line for Southwestern indirect only Public Service Comoany 36941 Haskell, J. L. 1991 No. I Belco Aia Federal Power Line for Yates Petroleum indirect only 37615 Hunt, J.E., 1992 Seismic Testing Lines 20-NM-92 and 21-NM-92 for Dawson direct and and others Geophysical indirect 37617 Hunt, J.E. 1992 Lusk No. 2 Saltwater Disposal Pipeline for Yates Petroleum direct and indirect 39483 Abbott, R. 0 . 1992 Belco Aia Federal No. 2 and Flow Line for Yates Petroleum indirect only 39484 Abbott, R. 0., 1992 Belco Aia Federal No. 3: Access and Flow Line for Yates indirect only and others Petroleum 39485 Abbott, R. 0. 1992 Belco Aia No. 4: Access Road and Flow Line for Yates Petroleum indirect only 39852 Haskell, J. L. 1992 No. I Belco Aia Federal Gas Gathering and Water Disposal Line indirect only for Yates Petroleum 42244 Haskell, J. L. 1992 Water Station and Access Road for B & E, Inc. indirect only 42256 Haskell, J. L. 1993 Control No. 7986- 195/Power Line Station, Hat Mesa Lease for indirect only Southwest Public Service 45090 Hunt, James 1993 Archeological Inventory Report for Scurlock Permian indirect only E. Corporation's Truck Loading Station and Access Road Situated on Public Lands in Lea County, New Mexico 46296 Griffiths, 1994 Archaeological Survey of the Scurlock Permian Corporation Trnck indirect only Dorothy M., Loading Site Area T20S, R32E, Section 17 (NW l/4SE l/4), Lea and James V. County, New Mexico Sciseen ti 49377 Staley, David 1995 Cultural Resource Survey of a Powerline Route Between Potash indirect only P., and Junction and Cunningham Station Eddy and Lea Counties, New Kathleen A. Mexico Adams 50647 Reid, 1994 A Cultural Resources Survey of Barbara Fasken's Proposed Baetz indirect only Kathleen C. 23 Federal Well No. 2 Well Pad and Access Road 5089 1 Hunt, James 1994 Archeological Clearance Report for C. W. Trainer's Pipeline direct and E. Easement in Section 13 Situated on Public Lands in Lea County, indirect New Mexico 5 1738 Adams, 1995 Cultural Resource Survey for a Proposed 11 5 kV Powerline Lea indirect only Kathleen A. County, New Mexico 55547 Dillington, 1997 Cultural Resources Survey for Three BLM Range Projects Near indirect only Eric Laguna Toston, T20S, R32E, Lea County, New Mexico 57 188 Wilcox, 1997 Archaeological Survey of the Southwestern Public Service indirect only David, and Company's Proposed Electric Li11c to Serve Western Wireless Jon R. (Control No. I95-B295) in Sections 23 and 24, T20S, R32E, Blackwelder NMPM, Lea County, New Mexico HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-76 129 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.7.1:

CULTURAL RESOURCE INVESTIGATIONS WITHIN THE APE Activity Author Year Tide APE No.

58640 Clifton, Don 1997 An Archaeological Survey of Three Proposed Water Pipe Lines, indirect only Lea and Eddy Counties New Mexico 59474 Michalik, 1998 An Archaeological Clearance Survey of the Proposed GTE Fiber indirect only Laura Optic Linc Along US62-180 and NM 360 Between Hobbs and Carlsbad, Eddy and Lea County, New Mexico 60817 Wilcox, 1998 Archaeological Survey of Mesquite SWD, lnc.'s Proposed direct and David, and 200'x200' Tank Battery, 3,696' Access Road/Electric Line and 250' indirect Peter C. Line to Laguna Toston Disposal Pond, Sections 17 and 20, T20S, Condon R32E, Lea County, New Mexico 61526 Wilcox, 1998 Archaeological Survey of Southwestern Public Service Company's indirect only David Proposed Electrical Distribution line to Serve the Mesquite Services, lnc.'s Brine Station in Section 20, T20S, R32E, NMPM, Lea County, New Mexico 63808 Sullivan, 1999 An Archaeological Survey of the Bureau of Land Management's indirect only Tiffany Sue 8100 Range Improvement Estes Water Pipeline and Troughs (Allotment No. 6022) located in T20S, R32E, Sections 22, 27, 28, Lea County, New Mexico 71314 Michalik, 2000 Culn1ral Resources Class Jll Inventory and Significance indirect only Laura Evaluation of a Proposed Buried Fiber Optic Cable in Eddy and Lea Counties New Mexico 71698 Michalik, 2000 Cultural Resources Inventory ofa Proposed Waterline ROW Near direct and Laura Lairuna Toston Lea Countv. New Mexico indirect 74608 Kearns, 2003 An Archaeological Survey of the New Mexico Portion of Link indirect only Timothy M., One of the AT&T NexGen/Core Project DianneM.

Berrigan, Dorothy L.

Webb, Steven F. Mehis, and Bob Estes 77191 Michalik, 2001 Cultural Resources Inventory of an Electric Line ROW South of indirect only Laura Laguna Gatuna Lea County, New Mexico 77398 Baker, 2001 Archaeological Survey or Inspection of Access Roads Rejected or indirect only Kathleen A., Recommended Cleared for Traffk: Addendum I to An and Timothy Archaeological Survey of New Mexico Portion of Link One of the Kearns AT&T NexGen/Core Project 78662 Smith, 2002 Survey for the Baetz 23 Federal No. 9 Well Pad and the Baetz 23 indirect only Stephen, and Federal No. 3 Well Pad and Access Road Theresa Straight 881 11 Gregory, 2004 Culn1ral Resource Survey for Shoulder Rehabilitation Along NM indirect only Danny 243, Eddy and Lea Counties, New Mexico 89664 Gregory, 2004 Culn1ral Resource Inventory along Smith Ranch Road in Lea indirect only Danny County, New Mexico 89953 Higgins, 2004 Archaeological Inventory Survey in the Laguna Plata indirect only Howard C., Archaeological District, Lea County, New Mexico Robert Hall, and Mark Sale 93986 Railey, Jim 2006 Culniral Resources Survey of the Intrepid Potash Land Exchange, indirect only A., and Eddy and Lea Counties, New Mexico Patrick 0 .

Mullen HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-77 130 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.7.1:

CULTURAL RESOURCE INVESTIGATIONS WITHIN THE APE Activity Author Year Tide APE No.

100474 Sanders, Joe 2006 A Class 111 Cultural Resource Inventory Report for the Lusky indirect only Ben, Federal Number I Proposed Well Location, Section 15, T20S, Doralenc R32E, Lea County, New Mexico Sanders, and Gail Wimberl y 100590 Pangburn, 2006 A Class m Archaeological Survey of the Belco AIA Federal Well indirect only Jeffrey 2H Pad and Associated Access Road 100842 Sanders, Joe 2006 A Class Tll Cultural Resource Inventory Report for the Permian indirect only Ben, Basin Pipeline ROW, Eddy and Lea Counties, New Mexico Doralene Sanders, and Staci Sanchez 101277 Clifton, Don 2006 A Cultural Resource Survey of the Halfway Communications indirect only Tower Lea Countv. New Mexico 101929 Pangburn, 2006 A Class lll Archaeological Survey for a Powerline Easement indirect only Jeffrey, and Dagmar Youn!!bern 107422 Boone, Ann, 2007 Belco Aia Federal Well No. 3-H indirect only and Danny Boone 109 158 Boone, Ann, 2008 Belco Aia Federal Well No. 4H, Surface Location indirect only and Danny Boone 11 3755 Robinson, 2009 Archaeological Clearance for the Laguna Fence Reconstruction indirect only Lynn 114011 Robinson, 2009 Class Ill Archaeological Survey for the South Trap Fence Line indirect only Lynn 11 5107 Smith, 2009 Archaeological Monitoring and Sttrvey for Yates Petroleum indirect only Stephen Corporation's Proposed Pipeline Reroutes for the Belco Battery BPLLooo 11 5461 Hroncich, 2009 A Class llT Cultural Resource Su,vey for a Proposed Fiber Optic C indirect only Maria, Toni able, US 62/ 180, Eddy and Lea Counties, New Mexico Goar, and Scott Walley 11 6048 Walker, 2009 A Class Ill Cultural Resources Inventory of the Proposed North indirect only Patricia Mine Gas Pipeline for Intrepid Potash- NM, LLC, Eddy and Lea Counties New Mexico 116891 Goar, Toni R. 20 10 An Addendum to a Class Ill Cultural Resource Survey for a indirect only Proposed Penasco Valley Telephone Cooperative Fiber Optic Cable, US 62/180, Eddv and Lea Counties, New Mexico 11 8942 Walker, 20 10 A Cultural Resources Inventory of Four Proposed Van Sickle indirect only Patricia, and Coreholes: IP-075, IP-076, IP-077, and IP-078 and Associated Robert Delio Access Roads, Eddy County, New Mexico, for Intrepid Potash-Russo NM, LLC 12 1906 Okun, Adam 20 11 Archaeological Survey for the Carlsbad Double Eagle Water indirect only System Improvement Project Eddy County, New Mexico 123058 Cribbin, 2012 A Class 1 and Class 111 Survey of 214 Acres for Two Southwestern indirect only Brian Public Service 11 5 kV Circuits in Lea County, New Mexico 123200 Sullivan- 20 12 A Class Ill Pedestrian Survey of the Proposed Excel Energy indirect only Owens, Manzano Queenie 15 No. IH Power Linc, Lea County, New Tiffany Mexico HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-78 131 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.7.1:

CULTURAL RESOURCE INVESTIGATIONS WITHIN THE APE Activity Author Year Tide APE No.

125675 Cordua, 2012 Cultural Resource Survey of 8. 72 Acres for the Proposed Intrepid indirect only Teresa North Compaction Powerline in Sections 18 and 19, Township 20 South, Range 32 East, Lea County, New Mexico 126039 Travis, Cathy 2013 Revised Cul tural Resource Survey of 12.87 Acres for the Proposed indirect only Intrepid North Compaction Powerline, Lea County, New Mexico 126789 Hill, Rebecca 2013 Class 111 Archaeological Survey for Agave Energy Company's indirect only L., and Pipeline to Green Frog Cafe Fed Com No. I H Joshua Broxson 127779 Carlson, C., 20 13 A Class 111 Survey for the Proposed Zia 11 Natural Gas Plant and indirect only C. Walth, J. Pipeline in Eddy and Lea Counties, New Mexico Walborn, and M. Bandy 128094 Stowe, 20 13 Cultural Resource Survey for Souder Miller and Associates for indirect only Michael Proposed Road improvements to NM State HWY 176 from the Intersection of US HWY 62/ 180 extending East Roughly IO Miles to MP 10 Lea County, New Mexico 128 168 Kerr, R. 201 3 A Cultural Resource Survey for 4.5 Miles of Proposed Double indirect only Stanley, and Eagle Waterline in Carlsbad, Eddy and Lea Counties, New Mexico Toni R. Goar 128460 Smith, 20 13 Class Ill Archaeological Survey for Yates Petroleum Corporation's indirect only Stephen Proposed Well Pad to Serve the Anise AN! Federal Com No. 3H Well 128497 Smith, 2013 Class Ill Archaeological Survey for Yates Petroleum Corporation's indirect only Stephen Proposed Access Road and Well Pad to Serve the Anise ANI Federal Com No. 4H Well 129109 Mavrick, 201 3 A Class Ill Archaeological Survey for the Fasken Oil Laguna 2H indirect only Christine A. Pipeline 129407 Rein, Justin 2014 A Class Ill Cultural Resource Survey for the BOPCO, LP Laguna indirect only State No. 2 Drilling Island n/a Condie, Carol 2007 Cultural Resources in the Eddy-Lea Energy Alliance Project Area, direct and J. Lea Counrv. New Mexico for Gordon Environmental Inc. indirect HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-79 132 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.7.2:

CULTURAL RESOURCES IDENTIFIED WITHIN THE APE State Site Temporal Site Components Year Eligibility APE No. (LA) Affiliation Recorded 8058 prehistoric artifacts and features 1963 undetermined indirect only 22107 prehistoric artifacts and features 1979 eligible indirect only 22108 unknown artifacts and features 1979 eligible indirect only 22109 unknown artifacts and features 1979 eligible indirect only 221 10 unknown artifacts and features 1979 eligible indirect only 221 11 unknown artifacts and features 1979 eligible indirect only 221 12 prehistoric artifacts and features 1979 eligible indirect only 221 14 unknown artifact scatter 1979 eligible indirect only 34667 prehistoric artifacts and features 1982 undetermined indirect only 34668 unknown artifact scatter 1982 undetermined indirect only 35654 prehistoric artifact scatter 1973 undetermined indirect only 35655 unknown artifacts and features unknown unknown indirect 011ly 43355 prehistoric artifact scatter 1960 undetermined indirect only and historical period 47384 prehistoric arti facts and features 1984 eligible indirect on ly 57150 unknown artifact scatter 1970 undetermined indirect only 57151 unknown artifact scatter 1970 undetermined indirect only 60817 unknown artifacts and features 1987 undetermined indirect only 608 18 unknown artifact scatter 1987 undetermined indirect only 68669 prehistoric artifacts and features 1988 eligible indirect 011ly 70084 unknown artifacts and features 1988 undetermined indirect only 70085 unknown a11i fact scatter 1987 undetermined indirect only 70086 prehistoric artifacts and features 1987 undetermined indirect only 70087 unknown artifact scatter 1987 undetermined indirect only 70088 unknown artifact scatter 1987 undetermined indirect on ly 89619 prehistoric artifact scatter 1992 eligible indirect only 89675 prehistoric artifact scatter 1992 eligible indirect only 89676 unknown artifact scatter 1992 undetermined direct and indirect 109924 historical artifacts and features 1995 not eligible indirect on ly period 109925 prehistoric artifact scatter 1995 not eligible indirect only 120944 prehistoric artifacts and features 1997 undetermined indirect only 120945 prehistoric artifacts and features 1997 undetermined indirect oi1ly 130744 historical buried cable 2000 not eligible indirect only period HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-80 133 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.7.2:

CULTURAL RESOURCES IDENTIFIED WITHIN THE APE State Site Temporal Site Components Year Eligibility APE No. (LA) Affiliation Recorded 143904 historical artifacts and features 2004 not eligible indirect only period 149297 prehistoric artifacts and features 2005 undetermined indirect only and historical period 149298 historical artifact scatter 2005 not eligible indirect only period 149299 historical artifacts and features 2005 undetermined direct and indirect period 149302 prehistoric artifact scatter 2005 not eligible indirect only 149303 prehistoric artifacts and features 2005 undetermined indirect only 153898 prehistoric arti facts and features 2006 eligible indirect only 163 183 prehistoric artifacts and features 2009 eligible indirect only 163231 prehistoric artifacts and features 2009 not eligible indirect only 177043 prehistoric artifacts and features 2013 eligible indirect 011.ly HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-81 134 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.8 SOCIOECONOMICS This section describes social and economic characteristics for the 50-mile region of influence (ROI) surround ing the proposed CIS Facility site inc luding Lea and Eddy Counties in New Mexico and Andrews and Gaines Counties in Texas (see Figure 3.8.1). The ROI reflects an area where anticipated CIS Facility workers reside and includes the area in which these workers would spend much of their wages. Infonnation is provided for socioeconomic characteristics and include population, ho using, community services, employment, and regional economy for the ROI. This section also includes a discussion of enviromnental justice populations.

3.8.1 Population Characteristics Lea County is primarily rural, as are the other counties in the ROI. Between 2000 and 2010, the po pulation in the ROI has grown at a slower rate in comparison to New Mexico-wide population growth. Population est imates in the ROI are projected to grow at a slower rate than New Mexico, increasing 10 percent between 20 15 and 2025 while New Mexico is projected to increase 19 percent during the same time period. Table 3.8. l lists historical population and Table 3.8.2 lists projected population in the ROI and New Mexico and Texas.

The population in the ROI in 2015 was estimated to be 166,914 (USCB 2016a). In 2015, 43 percent of the population of the ROI resided in Lea County, New Mexico. Between 2010 and 2015, the counties within the ROI a ll experienced an increase in population. Gaines County, Texas had the greatest increase at 14 percent, while Eddy Cow1ty, New Mexico had the lowest increase at seven percent during the same time period.

The county seat of Lea County, New Mexico is located in Lovington, New Mexico and covers 2,822,522 acres with a population density of 14.7, the highest in the ROI. The county seat and largest city of Eddy County, New Mexico is Carlsbad. The county has a total area of 2,675,200 acres with a population density of 5.4, the lowest in the ROI. The county seat of Andrews County, Texas is Andrews. The county's area comprises 960,640 acres with a population density of 9.9.

The county seat of Gaines County, Texas is Seminole. The county's area comprises 496,000 acres with a population density of 11.7. Table 3.8.3 presents the density per square mile for the ROI and county subdivisions.

3.8.1.1 Minority Population The term minority population is defined by the U.S. Census Bureau to include the five racial categories of black/African American, American Indian or Alaska Native, Asian, Native Hawaiian or other Pac ific Islander, some other race, and two or more races. NUREG-1 748 defines minority populations to include individual of Hispanic or Latino origin. Table 3.8.4 presents the de mographic profile of the ROI.

3.8.1.2 Low-Income Population Low-income populations are defined us ing statistical pove rty thresholds used by the U.S. Census Bureau. Informatio n on low-income populatio ns was deve lo ped fro m 20 13 incomes repo11ed in the 2010-2014 American Community Survey selected economic characteristics. The poverty HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-82 135 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment weighted average threshold for unrelated individual was $ 12,071 (USCB 2014). Table 3.8.5 presents the percentage of individuals below the poverty level.

3.8.2 Housing Characteristics Detailed housing characteristics for the ROI are presented in Table 3.8.6. Between 2000 and 2014, Lea County, New Mexico and Gaines County, Texas had a decrease in the total number of owner-occupied housing units, wh ile Eddy County showed no change. Lea and Eddy counties in New Mexico and Gaines County, Texas had a decrease in the number of renter-occupied units during the same period. Eddy County, Texas accounts for 38 percent of the housing units in the region, fo llowed by Lea County, New Mexico (41 percent), Gaines County, Texas (3 1 percent) and Andrews County, Texas (10 percent).

The median home value ranges from $89,500 in Gaines County, Texas to $ 101,400 in Lea County, New Mexico. The median cost ofa home in New Mexico in 2014 was $ 159,300 and $ 131,400 in Texas. The variation in housing units between the counties and the state is reflective of the rural nature of the county areas.

3.8.3 Community Characteristics The community characteristics in the ROI include public schools, law enforcement, fire suppression, medical services, and recreation resources. Figure 3.8.2 depicts the community services in the vicinity of the CIS Facility.

3.8.3.1 Education The ROI has 12 public school districts with a total of 80 schools serving a student population of 32,669 during the 2014-2015 school year, as presented in Table 3.8.7 (NCES 2016). Lea and Eddy Counties in New Mexico had student/teacher ratios greater than the state average of 15. 1 wh ile Andrews and Gaines Counties in Texas had student/teacher ratios less than the state average of 15:1. The ROI had an average student/teacher ratio of 15.1.

Lea and Eddy County in New Mexico school enrollment makes up six percent of enrollment for New Mexico and Andrews and Gaines County in Texas makes up less than one percent of enrollment for Texas. Table 3.8.8 summarizes the school enrollment data for the ROI.

3.8.3.2 Health Care and Public Safety Health Care There are two hospitals in Lea County, New Mexico. The Lea Regional Medical Center is located in Hobbs, New Mexico. Lea Regional Medical Center is a 201-bed hospital that can handle acute and stable chronic care patients (LRMC 2016). In Lovington, New Mexico, Covenant Medical Systems manages Nor-Lea Hospital, a small, 27-bed critical access facility. The emergency room has a basic trauma unit for crit ica l care. Patients need ing more extensive treatment can be transported to Lubbock, Texas or Albuquerque, New Mexico. Other clinics are located in Jal and Tatum (ELEA 2007, Section 2.7.4.6.3).

There are two hospitals in Eddy County, New Mexico. The Carlsbad Medical Center is a 115-bed fac ility with inpatient, outpatient, diagnostic, medical, surgical and emergency services located in HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-83 136 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Carlsbad, New Mexico. The Carlsbad Medical Center has one main site and two medical office buildings. Carlsbad Medical Center's sister facility is the Lea Regional Medical Center in Hobbs, New Mexico. The Artesia General Hospital is a 34-bed critical access hospital. The emergency room is open 24-hours and has six beds. Patients need ing more extensive treatment are usually transported to Lubbock, Texas or Albuquerque, New Mexico (ELEA 2007, Section 2.7.4.6.1).

There is one hospital in Andrews County, Texas. The Permian Regional Medical Center is a 42-bed faci lity in Andrews, Texas with inpatient, outpatient, diagnostic, medical, surgical and emergency services located in Andrews, Texas (A.HD 2016). There is one hospitals in Gaines County, Texas. The Yoakum Community Hospital is a small 25-bed critical access facility in Yoakum, Texas (A.HD 2016).

Public Safety Table 3.8.9, shows the number of police and fire departments in each county within the ROI. There are a total of 18 police departments and 22 fire departments serving the counties in the ROI.

Fire support service for the Hobbs area is provided by the Hobbs Fire and Rescue. It is staffed by a full-time Fire Chief with 72 employees and a class rating of 4. The Hobbs Fire Department has 19 paramedics and 43 Emergency Medical Technicians (EMT) EMT- 1, and 2 Special Weapons and Tactics (SWAT) Medics serving with the Hobbs Fire Department. The Hobbs Fire Department inventory of Emergency Medical Services (EMS) units bas increased to seven (IIFP 2009, Section 3.10.3.4).

The Hobbs Police Department, with five full-time officers, provides local law enforcement. The Lea County Sheriffs Department also maintains a substation in the community of Hobbs. lf additional resources are needed, officers from mutual aid communities within Lea County, New Mexico can provide an add itional level ofresponse. The New Mexico State Police provides a third level of response.

3.8.4 Economic Characteristics 3.8.4.1 Employment Employment by sector is presented in Table 3.8.10. The agriculture, forestry, fishing, hunting, and mining industry provides the highest percentage of the employment in the ROI, 21 percent, fo llowed by the educational services, and hea lth care and socia l assistance, retail trade, and constrnction, with 17.2 percent, 9.7 percent, and 8.7 percent, respectively (USCB 2016b).

Since 2005, the ROI labor force grew from 62,926 in 2005 to 77,433 in 2015, for a growth rate of 23 percent for that period. Employment for the ROI declined from 70,360 in 2009 to 67,140 in 2010 for a decrease of nearly five percent for that period. The ROI unemployment rate, which was 4.4 percent in 2005, was five percent as of 2015, as presented in Table 3.8. 11. The average unemployment rate for the New Mexico was 6.6 percent in 2015 and 4.5 in Texas during the same time period (BLS 2016a).

3.8.4.2 Income Table 3.8.12 presents the median household and per capita incomes for 2014. Andrews County, Texas has the highest median household income and per capita income in the ROI and also exceeds HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-84 137 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment the values fo r Texas. Eddy County, New Mexico has the lowest median househo ld income within the ROI while Gaines County, Texas has the lowest per capita income in the ROI (USCB 20 16b).

3.8.4.3 Tax Structure New Mexico's property tax rate is perennially ranked among the three lowest in the nation, with any change requiring an amendment to the state constitution. The prope1ty assessment rate is uniform, statewide, at a rate of l /3 of the value (except oil and gas properties), which means that the net taxable value is one third of the assessed value minus allowable exemptions. The maximum operating levy that may be imposed by a county in New Mexico is 11.85 mils per $1,000 of net taxable value of a prope1ty, while the maximum for a municipality is 7.65 mils per $1,000 of net taxable value of a property (NMDF A 2016). The tax applied is a compos ite of state, county, municipal, school district and other special district levies. Prope1ties outside city limits are taxed at lower rates. Major facilities may be assessed by the New Mexico State Taxation and Revenue Department instead of by the county. The Lea County, New Mexico tax rate fo r non-residential property outside the city limits of Hobbs is 27.4 mils per $1,000 of net taxable value of a property (EDCLC 2016). New Mexico communities can abate property taxes on a plant location or expansion for a maximum of 30 years, (usually 20 years in most communities), controlled by the commun ity (NM Partnership 2016).

New Mexico also has a Gross Receipts Tax paid by product producers. This tax is imposed on businesses in New Mexico, but in almost every case it is passed to the consumer. In that way, the gross receipts tax resembles a sales tax. Certain deductions may apply to this tax for plant equipment (Finance NM 2015).

New Mexico counties have more limited general authority to impose a county gross rece ipts tax and they do not receive a state-shared distribution. However, counties have numerous options to impose taxes for other purposes. Some of these taxes, e.g., fire protection, county environmental gross receipts tax, may only be imposed on residents of the unincorporated area. Some, like that for jails and hospital and health care, reflect county responsibilities and are imposed county-wide (Finance NM 2015).

Property taxes provide a majority of revenue for local services in Texas. Property taxes are based on the most current year's market value. Any county, municipality, school district or college district may levy property taxes. Texas local governments make much more use of the prope1ty tax than is true of their New Mexico counterparts. According to the Tax Foundation, property taxes per capita in Texas were $1,562, versus $633 in New Mexico in 2010. Texas ranked 14th among the states, while New Mexico ranked 48th (Tax Foundation 2016a). By contrast, state and local gross receipts taxes per capita in Texas in fiscal year 2011 were $856, giving the state a ranking of 18th, while per capita gross receipts taxes in New Mexico were $907, putting the state in 15th place (Tax Foundation 2016b). While not a local government revenue source, New Mexico's personal income tax per capita in 2011 ranked it 39th among the states (Tax Foundation 20 16c). Texas has no personal income tax.

3.8.5 Environmental Justice Under Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, Federal agencies are responsible for identifying and HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-85 138 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment addressing the possibility of dispropo1tionately high and adverse human healt h or environmental effects of its programs, policies, and activities on minority populations and low-income populations in the United States and its territories and possessions, the District of Columbia, the Commo nwealt h of Puerto Rico, and t he Commonwealth of the Mariana Is lands. Minority populations refer to persons. of any race self-designated as Asian, Black, Native American, or Hispanic. Low-income populations refer to households with incomes below the Federal poverty thresholds.

For this analysis, the populations of counties or block groups that intersected or were within the 50-mile radius were wholly included in population counts. Block groups that fell within a 50-mile radius and which met the criteria described below were identified as minority or low-income populations. Such a methodology is conservative, in that it cou ld include hig her populations than may actually exist within the 50-mile radius.

The threshold used for identifying minority and low-income communities surrounding specific sites were developed consistent with CEQ guidance (CEQ 1997, Section 1-1) for identifying minority populations using either the 50 percent threshold or another percentage deemed "meaningfully greater" than the percentage of minority o r low-income individuals in the genera l population. CEQ guidance does not provide a numerical definition of the term "meaningfully greater." CEQ guidance was supplemented using the NRC, Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040). The policy statement directs analysts to consider environmental justice matters in greater detail " if the percentage in the impacted area significantly exceeds that of the state or county percentage for either the minority or low-income population." "Significantly" is defined by staff guidance to be 20 percentage points. The percentage of minority or low-income individuals in the general population is defined in this ER as the lower of the average percentage of minority or low-income individuals living in the state(s) in which the ROI lies or in the counties that are at least partially included within the ROI.

For the impact assessment, the analysis of environmental justice used block groups for minority populations and census tracts for low-income populations.. Table 3.8.1 3 presents the site-specific thresholds in New Mexico and Texas for minority and low-income populations. The ROI for the environmental justice analysis was defined as an area within a 50-mile radius surrounding the proposed CIS Facility site that encompasses three counties in New Mexico and six counties in Texas. Because the Site is located in a rural area, a 50-mile radius surrounding the Site was used to present a sample of the surrounding population.

3.8.4.1 Minority Population In 2010, minorities made up approximately 54 percent of the population of the three-county area surrounding the Site in New Mexico and 56.9 percent in the six-county area in Texas. During this time period, Hispan ics were the largest minority group within the three-county area in New Mexico, consisting ofapproximately 49.4 percent of the population and 53 percent within the six-county area in Texas. Black or African Americans made up approximately 2.2 and 2.3 percent in New Mexico and Texas, respectively (USCB 2016e, t). Table 3.8.14 presents block groups identified to contain minority populations that exceed the site-specific thresho lds for minority populations identified in Table 3.8.13.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-86 139 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment There were 35 block groups identified to contain minority populations that exceed the site-specific thresholds for minority populations within the 50-mile radius. Within a smaller ROI, no minority populations were identified that exceed the site-specific threshold within a 4-mile or a 25-mile radius of the Site. The closest minority populations that exceed the site-specific threshold were located in the population centers of Artesia and Carlsbad in Eddy County and Hobbs in Lea County.

3.8.4.2 Low-Income Population In 2010, the poverty threshold was $12,071 for unrelated individual (USCB 2014). There were no low-income populations identified in the three-county area surrounding the proposed CIS Facility site in New Mexico or the six-county area in Texas that exceed the site-specific threshold for low-income populations (USCB 2016g, h) identified in Table 3.8.13. Within a smaller ROI, no low-income populations were identified that exceed the site-specific threshold within a 4-mile or a 25-mile radius of the Site.

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.1:

POPULATION ESTlMATES FOR THE REGION OF INFLUENCE Census Census Census Population Estimates as of July 1 Area 1990 2000 2010 2011 2012 2013 2014 2015 Lea 55,765 55,528 64,727 63,690 64,670 65,681 66,876 71 ,180 Eddy 48,605 51,633 53,829 53,288 53,693 54,284 54,834 57,578 AndJews 14,338 13,004 14,786 14,500 15,006 15,554 16,126 18, 105 Gairnes 14,123 14,467 17,526 17, 123 17,572 18,019 18,496 20,05 1 Total Ror :132,831 134,632 150,868 148,601 150,941 153,538 156,332 166,914 New Mexico 1,515,069 1,819,046 2,059, 179 2,037, 136 2,055,287 2,069,706 2,080,085 2,085,109 Texas 16,986,510 20,851,820 25,145,561 24,774,187 25,208,897 25,639,373 26,092,033 27,469,1 14 Source: NMDWS 201 5, USCB 2016a, Texas 201 6.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.2:

POPULATION PROJECTIONS FOR THE REGION OF INFLUENCE Area 2020 2025 2030 2035 2040 Lea 78,407 85 ,773 93,712 102,090 110,66 1 Eddy 57,908 59,945 6 1,836 63,595 65,258 Andrews 16,450 17,244 17,973 18,695 19,378 Gaines 20,064 21 ,420 22,858 24,316 25,644 Total ROI 172,829 184,382 196,379 208,696 220,941 New Mexico 2,351 ,724 2,487,227 2,613,332 2,727, 118 2,827,692 Texas 27,238,610 28, 165,689 28,994,2 10 29,705,207 30,305,304 Source: NMDWS 2015, Texas 2016.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.3:

POPULATION DENSITY PER SQUARE MILE OF LAND FOR IBE REGION OF INFLUENCE, 2010 A rea 2010 County Lea 14.7 Eddy 5.4 Andrews 9.9 Gaines 11.7 County Subdivision and Place Eunice City, Lea County 970.6 Hobbs City, Lea County 1,424.4 Jal City, Lea County 446.4 Lovington City, Lea County 2,320.9 Carlsbad City, Eddy County 903 .3 Source: USCB 2010.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.4:

DEMOGRAPHIC PROFILE OF THE REGION OF INFLUENCE, 2014 Lea County, New Eddy County, New Andrews County, Gaines County, New Mexico Texas Minority Mexico Mexico Texas Texas Minority 39,720 59.4% 27,093 49.4% 8,945 55.5% 7,666 41.4% 1,255,794 60.4% 14,529,580 55.7%

Hispanic or Latino 35,747 53.5% 24,840 45.3% 8,359 51 .8% 7,082 38.3% 978,189 47.0% 9,962,643 38.2%

(of any race)

Black or African 2,06 1 3.1% 783 1.4% 292 1.8% 281 1.5% 37,519 1.8% 3,015,767 11.6%

American alone American Indian 445 0.7% 536 1.0% 46 0.3% 90 0.5% 177,555 8.5% 65,974 0.3%

and Alaska Native alone Asian alone 120 0.2% 339 0.6% 105 0.7% 82 0.4% 26,991 1.3% 1,053,474 4.0%

Native Hawaiian 0 0.0% 38 0.1% 0 0.0% 58 0.3% 942 0.0% 18,730 0.1%

and Other Pacific Islander alone Some other race 97 0. 1% 206 0.4% 0 0.0% 51 0.3% 3,7 18 0.2% 33, 11 4 0.1 %

alone Two or more races 1,250 1.9% 351 0.6% 143 0.9% 22 0.1 % 30,880 1.5% 379,878 1.5%

White alone 60,769 90.9% 49,227 89.8% 14,947 92.7% 17,061 92.2% 1,575,631 75.7% 20,027,796 76.8%

Total population 66,876 100.0% 54,834 100.0% 16,126 100.0% 18,496 100.0% 2,080,085 100.0% 26,092,033 100.0%

Source: USCB 20 16a.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.5:

PERCENT OF PEOPLE BELOW THE POVERTY LEVEL IN THE REGION OF INFLUENCE, 2014 State/County Percent of People Below Poverty Level Lea County, New Mexico 16.4%

Eddy County, New Mexico 13 .0%

Andrews County, Texas 11.4%

Gaines County, Texas 14.9%

New Mexico 20.9%

Texas 17.7%

Source: USCB 20 16b.

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.6:

ROI HOUSING CHARACTERISTICS, 2014 Total Occupied Owner- Renter- Owner Rental Vacant Median County housing housing occupied occupied vacancy vacancy units home value units units units units rate rate Lea 24,993 21 ,33 1 15,050 6,281 3,662 2.2% 9.3% $ 10 1,400.00 Eddy 22,960 20,190 14,849 5,341 2,770 0.4% 7.5% $ 116,200.00 Andrews 5,935 5,414 4, 161 1,251 523 2.6% 0.0% $95,500.00 Gaines 6,322 5,483 4,299 1,184 839 0.5% 7.0% $89, 500.00 Total ROJ 60,210 52,418 38,359 14,057 7,794 1.4% 7.7% $98,450.00 Source: USCB 2016c.

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ATTACHMEN T 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.7:

PUBLIC EDUCATION STATISTICS FOR THE 2014-2015 SCHOOL YEAR Number of Number of Student Number of Studentffeacher County School Schools Enrollment Teachers Ratio Districts Lea 5 37 14,661 849 17: 1 Eddy 3 27 10,802 651 17: l Andrews 1 6 3,764 257 14: l Gain es 3 10 3,442 29 1 12:1 Total ROT 12 80 32,669 2,048 15:1 New Mex ico 152 88 1 339,019 22,222 15 :1 Texas 1,244 9,282 5, 144,745 333,959 15 : l Source: NCES 2016.

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ATTACHMEN T 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.8:

EDUCATION CHARACTERISTICS IN THE REGION OF INFLUENCE, 2014 School College/Graduate Area Grades <8 (%) Grades 9-12 (%)

Enrollment (% )

Lea 18,178 60.0 23.3 16.9 Eddy 13,863 59.0 24.4 16.5 Andrews 3,963 65 .7 26.4 7.9 Gaines 4,709 75.0 20.7 4.4 Total ROI 40,713 79.1 33.7 25.3 New Mex ico 567,0 18 50.4 20.6 29.1 Texas 7,366,632 54.6 20.5 24.9 Source: USCB 20 I 6d.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.9:

POLICE AND FIRE DEPARTMENTS BY COUNTY County Police Departments Fire Departments Lea 10 6 Eddy 3 13 Andrews I I Gaines 4 2 Total ROI 18 22 Source: HomeFacts 2016.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.10:

CIVILIAN EMPLOYMENT BY INDUSTRY SECTOR Eddy County, Lea County, Andrews County, Gaines County, New Mexico Texas Industry New Mexico New Mexico Texas Texas Estimate Percent Estimate Percent Estimate Percent Estimate Percent Estimate Percent Estimate Percent Agriculture, forestry, fi shing and 4,552 18.4% 5,900 20.9% 2, 148 28.3% 1,733 23.0% 38,509 4.4% 386,778 3.3%

hunting, and mining Construction 1,744 7.1% 2,480 8.8% 6 10 8.0%, 1,075 14.3% 60,090 6.9% 9 2 1,062 7.8%

Manufacturing 1,437 5.8% 1,295 4.6% 437 5.8% 385 5.1% 43,074 4.9% 1,095,393 9.3%

Wholesale trade 590 2.4% 1,263 4.5% 201 2.6% 178 2.4% 18,038 2. 1% 352,72 1 3.0%

Retail trade 2,622 10.6% 2,805 9.9% 454 6.0"/o 725 9.6% 98,645 11.3% 1,365,482 11.6%

Transportation and warehousing, 1,572 6.4% 2,249 8.0% 651 8.6% 643 8.5% 39,326 4.5% 639,379 5.4%

and utilities lnfonnation 339 1.4% 303 1.1% 42 0.6% 47 0.6% 13,961 1.6% 212,915 1.8%

Finance and insurance, and real 989 4.0% 1,030 3.7% 326 4.3% 78 1.0% 39,473 4.5% 779,765 6.6%

estate and rental and leasing Professional, scientific, and 1,356 5.5% 1,833 6.5% 531 7.0"/o 298 4.0% 95,808 10.9% 1,288, 14 1 10.9%

management, and administrative and waste management services Educational services, and health 4,674 18.9% 4,435 15.7% 1,349 17.8% 1,268 16.9% 220,881 25.2% 2,569,387 21.8%

care and social assistance Arts, entertainment, and recreation, 2,062 8.3% 2,123 7.5% 374 4.9% 374 5.0% 95,461 10.9% 1,038,023 8.8%

and accommodation and food services Other services, except public 1,154 4.7% 1,3 12 4.7% 369 4.9% 576 7.7% 41,932 4.8% 636,462 5.4%

administration Public administration 1,627 6.6% 1, 171 4.2% 105 1.4% 144 1.9% 70,749 8. 1% 523,502 4.4%

Source: USCB 2016b.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HJ-21 67521 I Rev. 4 3-97 150 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.11:

ANNUAL AVERAGE LABOR FORCE AND UNEMPWYMENT RATES (2005-2015)

State/County 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Labor Force 25,780 26,605 27,686 29,278 28,329 26,349 27,297 28,403 29,329 30,544 29,428 Lea County, New Unemployment Mexico Rate 4. 1 3. 1 2.5 2.9 7.9 7.9 5.6 4.7 4.5 4.4 6.2 Labor Force 24,586 25, 144 26,054 27,31 1 28,005 25,736 26,493 26,845 27,670 28,848 29,366 Eddy County, New Unemployment Mexico Rate 4.6 3.5 3.0 3.0 5.9 6.4 5.1 4.7 4.6 4.5 4.9 Labor Force 6,337 6,786 6,678 6,87 1 6,985 7,120 7,794 8,552 9, 198 9,527 9,303 Andrews County, Unemployment Texas Rate 4.0 3.5 3.2 3.3 7.0 6.2 5.0 4.0 3.8 3.0 3.5 Labor Force 6,223 6,040 6,399 6,794 7,041 7,935 8,508 8,794 8,941 9,366 9,336 Gaines County, Unemployment Texas Rate 4.8 4.6 3.7 3.8 6.3 5.9 5.1 4.2 4.1 3.3 3.2 Labor Force 918, 156 928,094 934,027 944,548 940,352 936,088 930,356 928,739 923,685 921 ,380 919,889 New Mexico Unemployment Rate 5.1 4.2 3.8 4.5 7.5 8. 1 7.5 7. 1 7.0 6.7 6.6 Labor Force 11,124,240 11,327,995 11,431,631 11,664,390 11 ,9 10,799 12,241 ,970 12,504,498 12,682,204 12,89 1,255 13,022,851 13,078,304 Texas Unemployment Rate 5.4 4.9 4.3 4 .8 7.6 8. 1 7.8 6.7 6.2 5.1 4.5 Source: BLS 20 16a.

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ATTACHMEN T 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.12:

MEDIAN HOUSEHOLD AND PER CAPITA INCOMES IN THE REGION OF INFLUENCE, 2014 State/County Median Household Income Per Capita Income Lea County, New Mexico 55,248 22,962 Eddy County, New Mexico 51 ,303 27,630 Andrews County, Texas 6 1,250 29,363 Gaines County, Texas 54,434 2 1,690 ewMex ico 44,968 23 ,948 Texas 52,576 26,513 Source: USCB 2016b.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.13:

SITE-SPECIFIC THRESHOLDS FOR IDENTIFICATION OF MINORITY AND LOW-INCOME COMMUNITIES WITHIN THE 50-MILE REGION OF INFLUENCE (PERCENT AGE)

Population New Mexico Texas Minority Population 80.4 75.7 Low-Income Population 40.9 37.7 Source : USCB 20 16b.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.8.14:

MINORITY POPULATIONS EXCEEDING SITE-SPECIFIC THRESHOLDS WITHIN THE SO-MILE REGION OF INFLUENCE (PERCENTAGE)

Block Group Census Tract County State Percent Minoritv Block Group 3 Census Tract 4 Chaves New Mexico 80.7%

Block Group 2 Census Tract 6 Chaves New Mexico 94.8%

Block Group 3 Census Tract 6 Chaves New Mexico 94.6%

Block Group 4 Census Tract 6 Chaves New Mexico 90.5%

Block Group 5 Census Tract 6 Chaves New Mexico 93.4%

Block Group l Census Tract 7 Chaves New Mexico 83.8%

Block Group 4 Census Tract I 1.0 I Chaves New Mexico 85.3%

Block Group 3 Census Tract 5 Eddy New Mexico 82.3%

Block Grouo 2 Census Tract I0 Eddv New Mexico 89.1%

Block Group 4 Census Tract 10 Eddv New Mexico 84.7%

Block Group 3 Census Tract l Lea New Mexico 81.0%

Block Group I Census Tract 2 Lea New Mexico 75.5%

Block Group 2 Census Tract 2 Lea New Mexico 77.9%

Block Group 3 Census Tract 2 Lea New Mexico 75.7%

Block Group I Census Tract 3 Lea New Mexico 92.2%

Block Group 2 Census Tract 3 Lea New Mexico 88.7%

Block Group 3 Census Tract 3 Lea New Mexico 85.6%

Block Group 1 Census Tract 4 Lea New Mexico 81.3%

Block Group 3 Census Tract 4 Lea New Mexico 94.4%

Block Group 5 Census Tract 6 Lea New Mexico 85.1 %

Block Group 6 Census Tract 6 Lea New Mexico 82.6%

Block Grouo 2 Census Tract 9503 Culberson Texas 88.8%

Block Group 3 Census Tract 9503 Culberson Texas 80.6%

Block Group 4 Census Tract 9503 Culberson Texas 77.9%

Block Group 4 Census Tract 9501 Gaines Texas 85.6%

Block Group 1 Census Tract 9502 Reeves Texas 94.6%

Block Group 2 Census Tract 9502 Reeves Texas 95.8%

Block Group 3 Census Tract 9502 Reeves Texas 86.5%

Block Group l Census Tract 9503 Reeves Texas 95.5%

Block Group 2 Census Tract 9503 Reeves Texas 84.8%

Block Group 1 Census Tract 9504 Reeves Texas 89.1%

Block Group 3 Census Tract 9504 Reeves Texas 86.6%

Block Group 4 Census Tract 9504 Reeves Texas 79.6%

Block Group 1 Census Tract 9505 Reeves Texas 78.3%

Block Grouo I Census Tract 9503 Winkler Texas 75.9%

Source: USCB 2016e, f HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-101 154 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 50-Mile Radius r Andrew s 1115S 581 0 31

  • CISFS1te 0 ., ...

0 50 Mlle Radius D County Boundaries Source: EJScreen 2016.

Figure 3.8.l: REGION OF INFLUENCE WITHIN A 50-MILE RADIUS OF THE CIS FACILITY HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-102 155 of 558

ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Community Services

~

Lea

.~* G ai n e

/ / Andre w s I

D 1:1, 155,581

  • CISFSite D 10 >Jl ..., ...

0 50 M ile Radius D 1S JO aum c::::J County Boundariu Fire Sia.lions e Police Hospitals e Schools Figure 3.8.2: COMMUNITY SERVICES IN THE VICJNTY OF THE CIS FACILITY HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-103 156 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.9 TRANSPORTATION Transportation services to the CIS Facility would include the delivery of equipment, supplies, and staff, including contractors, needed to work and provide miscellaneous maintenance activities at the CIS Facility. T he mode of transpo1tation for these types of services wou ld be by road. The offsite transportation of solid and radioactive waste generated at the CIS Facility would also be by road.

DOE or utility licensees would be responsible for transporting SNF from ex isting commercial nuclear power reactor storage faci lities to the CIS Facility. SNF would be transported to the CIS Facility by rail. Approximately 3,000 canisters are expected to be transported over 40 years. SNF would be shipped in transportation packages licensed pursuant to IO CFR Part 71 and in compliance with requirements established by the DOT.

In order to support the transportation needs of the CIS Facility, this section describes the roads and railroads, from county roads to U.S. highways in the vicinity of the Site and on the Site. Figure 3.9. 1 shows the roads and railroads in the area.

3.9.1 Roads The major roads in the area consist ofcounty and state roads interconnecting the various population centers, but only fow- U.S. highways traverse the area.

  • U.S. Highway 285 runs south to no1th along the Pecos River through Carlsbad;
  • U.S. Highway 62/180 runs southwest to the northeast through Carlsbad and Hobbs, New Mexico;
  • U.S. Highway 82 travels west to east from Artesia through Lovington, New Mexico;
  • U.S. Highway 380 traverses west to east from Roswell through Tatum, New Mexico (ELBA 2007, Section 2.1.2.2).

The nearest highway to the Site is U.S. Highway 62/ 180 (1 /2 mile to the south), which is of four lane construction and the major route between Carlsbad and Hobbs. In 2015, the annual average daily traffic (AADT) on U.S. Highway 62/180 ranged from approximately 9,952 vehicles per day near Hobbs, to 5,696 vehicles per day in the vicinity of the proposed Site (near the Eddy-Lea County line), to 7,273 vehicles per day near Carlsbad. Approximately 43 percent of vehicles in the vicinity of the proposed Site were associated with commercial trucks (NMDOT 2016). U.S.

Highway 62/180 is also the final major highway segment on the WIPP Transpo1tation Route. From 1999 to 2014, there have been almost 12,000 shipments ofwaste to WIPP covering over 14 million miles (DOE 2016a).

Laguna Road, which connects to U.S. Highway 62/ 180, currently provides access to the Site from the south. Laguna Road runs south-north through the Site and connects to small county roads north of the Site. As discussed in Section 4.9 of this ER, a new roadway is proposed to be constructed to the Site from U.S. Highway 62/ 180. The nearest Interstate Highway is Interstate-20, approximately 95 miles to the southeast in Odessa, Texas (ELEA 2007, Section 2.7.7.1).

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.9.2 Railroads Two railroads service the area. One railroad company operates to the west of the Site and the other to the east. Southwestern Railroad operates the Burlington Northern-Santa Fe (BNSF) Carlsbad Subdivision (Carlsbad to Clovis, New Mexico, plus industrial spurs serving potash mines east of Carlsbad and east of Lov ing, New Mexico) under a lease agreement. Customers include potash mines, a petro leum refinery in Artesia, New Mexico, and various feed mills and agricultural-related businesses in Roswell and Portales, New Mexico. The Carlsbad spur ends at the Intrepid Mining LLC North facility which is 3.8 miles due west of the Site (ELEA 2007, Section 2.7.7.2).

As discussed in Section 4.9 of this ER, a spur from this railroad would be constructed to serve the Site.

East of the Site, the Texas-New Mexico Railroad (TNMR) operates 104 miles of track near the Texas-New Mexico border from a Union Pacific connection at Monahans, Texas to Lovington, New Mexico. The railroad serves the oil fields of West Texas and Southeast New Mexico. The primary commodities hauled are oilfield chemicals and minerals, construction aggregates, industrial waste, and scrap (ELBA 2007, Section 2.7.7.2). Approximately 400 railroad cars per year travel on this rail (IIFP 2009, Section 3.2.1).

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Transportation in the Vicinity

.. ., .,~~/ , :. 1 0 0 lO 0:: ml

[ ~Buffer l\rco

  • CISFSite D l.::.nt1es

+ .'.irport Poin:: 'f,lltJ ~ i.

  • io., - ~ * .,.. _ .. 11,,\ ;;\ * *
  • 1...-1 .._-J>r~41P "1'f"A""I

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LH .'10:"' ~'I:. *. t : t .........~ 1'!IOl"I; M1'i ..u u m ~ 11 f f' HMI

-+- R. I uod,

,'S'i,...c

'-'*** "'.t NtOC ¢ ~ nJ: utWi> ~ .ar'III *t Gt:> ..Mr Figure 3.9.1: TRANSPORTATION IN THE VICINITY OF THE SITE HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-106 159 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.10 INFRASTRUCTURE This section describes the existing services available to the proposed CIS Facility. These services include water and electric ity. The information is necessary to evaluate the availability of infrastructure (power and water) to support construction, operation and decommissioning activities.

The Site is located in southeastern New Mexico in Lea County, 32 miles east of Carlsbad, New Mexico, and 34 miles west of Hobbs, New Mexico. Both locations are nearby population centers to the Site. Larger population centers are Roswell, New Mexico, 74 miles to the northwest; Odessa, Texas, 92 miles to the southeast; and Midland, Texas, also to the southeast at 103 miles.

Oil and gas extraction provides most of the activity in the vicinity. Roads are built and maintained to provide access to the various wells. Pipelines are installed to move the product efficiently from one area to the next. Where pipelines are not used, access for heavy trucks to hau l the oil produced is required. Compressor stations are needed to pump the product through the pipelines. Electric power is required at the individual well pads to provide the electricity necessary to operate the pumps, compressors, and other equipment as needed. There are two major facilities related to oil/gas activity in the area. 'fhe Zia Gas Plant is located northwest of the Site, while Controlled Recovery Incorporated is southwest of the Site (ELBA 2007, Section 2. 1).

3.10.1 Water The Site and immediate v1cm1ty contain no significant sources of potable water, either as groundwater or surface water. The Site's proximity to the Ogallala Aquifer and the presence of a 24-inch diameter water line on site assures a plentiful supply of water for operation. The Ogallala Aquifer is est imated to contain 14,000,000 acre-feet of recoverable water in Lea County portion (BLEA 2007, Section 1.7).

The City of Hobbs Water Department would provide the potable water needed for the construction and operation of the CIS Facility.

3.10.2 Electricity N umerous power transmission lines exist within the region assw-ing plentiful electricity to meet the demands of the CIS Faci lity. Xce l Energy is very active in the area and is planning a major addition to the power system as part of its Power for the Plains grid enhancement initiative that will deliver a more reliable and abundant electricity supply to customers in New Mexico and Texas (Hobbs News 2016).

Xcel Energy is currently seeking route approvals in both New Mexico and Texas for a 345-kilovolt transmission line, a similar transmission project was completed in 2014. By 2020, a 345-kilovolt line will stretch more than 400 miles from western Oklahoma to southeastern New Mexico (Hobbs News 2016). Xcel energy would provide the electrical power needed for the construction and operation of the CIS Facility.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.11 WASTE MANAGEMENT This section describes the waste management capability in the vicinity of the Site. The purpose of this information is to provide a basis to assess potential impacts associated with the timely and proper disposal of waste resulting from construction, operation, and decommissioning of the CIS Facility. Based on the availa ble information, several facilities are available to handle the small quantities of hazardous and non-hazardous waste that would be expected from the proposed CIS Facility. This includes low-level radioactive waste, radioactive mixed waste, hazardous waste, solid (sanitary) waste, and industrial waste.

There are currently no existing facilities or structures on the proposed CIS Facility site; therefore, no waste is currently produced and no waste management services provided. There are three fac ilities that have permits from the state ofNew Mexico to handle non-hazardous waste. Two are permitted municipal landfills and the third is an industrial waste landfill (ELBA 2007, Section 2,8).

The Sandpoint Landfill is 25 miles west of the Site and serves Eddy County. The service area covers 4,200 square miles and has a population of 49,000. The County and the City of Carlsbad jointly own the Landfill, which is operated by Waste Connections, Inc. The City of Artesia operates a transfer station, as does the County at the V illage of Loving. Commercial collection services are available to most county residents living outside the incorporated areas of the county (ELEA 2007, Section 2.8).

The Lea County Solid Waste Authority has a service area that covers 4,400 square mi les and has a population of 55,800. The Lea County Solid Waste Authority consists of Lea County and all of the incorporated municipalities in the County. Commercial collection service is available to County residents living outside of the incorporated areas. T he Authority's landfill is east of Eunice New Mexico, opened in Ju ly 1999 and is operated by Waste Connection, Inc. (ELEA 2007, Section 2.8).

Lea Land, Inc. operates an industrial waste landfill three miles from the Site. The landfill is permitted to take non-hazardous industrial waste under a permit issued by NMED (ELEA 2007, Section 2.8). The Lea Land landfill has plenty of available capacity and is projected to remain open for 40 years (Lea Land 2016). With regard to Resource Conservation and Recovery Act (RCRA) wastes, the Waste Control Specialist (WCS) facility in Andrews County, Texas, approximately 39 miles from the proposed Holtec CIS Facility, includes a RCRA Subtitle C landfill.

3.12 PUBLIC AND OCCUPATIONAL HEALTH AND SAFETY This section describes existing public and occupational health issues that relate to the location and operations at the CIS Facility. It begins with a description of the general radiological environment in the U.S., followed by a discussion of background leve ls and sources of radiation and historic exposures near the CIS Facility. This section a lso presents public and occupational dose limits applicable to the CIS Facility, and summarizes health effects studies related to the radiation exposure.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.12.1 Radiological Exposure Al l members of the public are exposed to sources of ioniz ing radiation that occur naturally in the environment and as a result of human activities. Relative concentrations of radionuclides in different environmental media around the U.S. (e.g., air, soil, ground water) vary by geographic location.

Table 3.12.1 identifies background doses to a typical member of the U.S. population. In the table, the annual values are rounded to the nearest 1 percent. An average annual total effective dose equivalent to members of the U.S. population (i.e., 624.8 millirem [mrem]/year) comes from two primary sources: (1) naturally occurring background radiation and (2) medical exposure to patients (NRC 2014b, Table 6-3). Because the proposed CIS Facility site has not been used previously for activities that involve radioactive materials, the background exposure levels in Table 3. 12. l provide a baseline for the CIS Facility project. Table 3. 12.1 provides the best approximation of radiological conditions for the follow ing reasons:

  • There are no legacy activity issues since the Site has not been previously used for activities that invo Ive radioactive materials.
  • Nuclear facilities in the vicinity will not provide any significant radiological doses because the maximally exposed individual (MEI) exposures at those facilities are small (See Table 5.2.3).
  • The DOE established radiological monitoring programs in southeastern New Mexico prior to the WIPP project to determine the widespread impacts of nuclear testing at the Nevada Test Site on the background radiation. The DOE estimated an annual dose ofapproximately 65 millirem is rece ived from atmospheric partic ulate matter, ambient radiation, soil, surface water and sediment, groundwater, and biota. These values fall within expected ranges and do not indicate any unexpected environmental concentrations (NRC 2012b, Section 3 .14.1 ).
  • A major propo11ion of natural radiation comes from naturally occurring airborne sources such as radon and thoron (an isotope ofradon). The proposed site is in an area characterized by radon concentrations of 2 to 4 picocuries per liter (pCi/L) and is defined as moderate radon potential. Moderate radon potential indicates that 1/3 to 1/2 of the structures have more than 4 pCi/L of indoor radon. In May 2 004, direct background radiation was measured by the NMED Radiation Control Bureau to be 8 to l O microrad per hour, which corresponds to 70 to 88 millirem per year. This range fa lls w ithin the NRC's estimation of the average annual direct background radiation for the United States (NRC, 2012b,Section 3.12.1).

3.12.2 Public and Occupational Dose Limits This section provides the radiation standards and dose limits applicable to CIS Facility, describes occupational injury and fatality rates related to the CIS Facility, and summarizes health effects studies related to radiation exposure.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment 3.12.2.1 Applicable Standards and Dose Constraints Radiation exposure limits for the workers and general public have been established by the NRC and the EPA in the following:

  • l OCFR Part 20, Standards for Protection Against Radiation;
  • 410 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste.

The radiation protection standards for members of the public apply to any real individual located at or beyond the nearest boundary of the controlled area for the facility. The controlled area is defined as "that area immediately surrounding an ISFSI. .. fo r wh ich the licensee exercises authority over its use and within which ... operations are performed." (10 CFR 72.3) Radiation protection standards are summarized in Table 3.12.2.

3.12.2.2 Occupational Injury and Fatality Rates Potential health impacts to workers during the construction and operation of the proposed CIS Facility would be those normally associated with construction and industrial activities. The U.S.

Department of Labor, Bureau of Labor Statistics (BLS) compiles annual data on nonfatal and fatal occupational injuries in various industries. Incidence rates ofnonfatal occupational injur.ies in New Mexico are presented in Table 3.12.3 for 2009- 2014 and fatal occupational injuries rates by industry in New Mexico are shown in Table 3. 12.4 (DOL 2009-2014, New Mexico).

3.12.3 Health Effects Studies Know ledge of the effects of ionizing radiation comes primarily from studying groups of people who have received high doses. The risks associated with Large doses of ionizing radiation like X-ray and gamma radiation are relatively well established and have been reported in numerous publications by national and international organizations including the National Academy of Sciences (NAS), the NRC, the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), and the International Commission on Radiation Protection (ICRP).

There are several studies of occupationally exposed persons, who generally receive low doses of ionizing radiation at low dose rates. Radiation is a weak carcinogen, but undue exposure can certainly increase health risks. Radiation protection standards assume that any dose of rad iation, no matter how small, involves a possible risk to human health.

Radiation epidemiology has provided clear insights into radiation exposures and risks. A single radiation exposure can increase cancer risk for life and the young are more susceptible than the elderly. In utero, susceptibility to radiation-induced cancer is no greater than in early childhood, and females are more susceptible than males. Radiation cancer risks differ by organ and tissue and some sites have not seen a convincing increase after exposure. Radiation epidemiology is highly uncertain about low dose and low-dose rate risks. However, available scientific evidence does not indicate any cancer risk or immediate effects at doses below 10 rem per year. At low levels of exposure, the body's natural mechanisms repair radiation damage to cells soon after it occurs.

In the U.S., cancer is the second most common cause of death in the U.S., exceeded only by heart disease, and accounts for nearly 1 in every 4 deaths. Cancers can be caused by external factors, HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2 167521 I Rev. 4 3-110 163 of 558

ATTACHMEN T 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment such as tobacco, infectious organisms, and an unhealthy diet, as well as internal factors, such as inherited genetic mutations, hormones, and immune conditions (ACS 20 16, page 1). The American Cancer Society repo1ts that an estimated 9,750 new cancer cases were expected for the state of New Mexico in 2016, and nearly 1.7 million new cases were expected for the entire U.S. (ACS 2016, Table 2 for New Mexico). Table 3.12.5 shows the cancer incidence rate for New Mexico and surrounding states for the period 2008-2012 for selected cancer sites.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.12.1:

AVERA GE ANNUAL EFFECTIVE DOSE EQUIVALENT OF IONIZING RADIATION TO A MEMBER OF THE U.S. POPULATION Source Effective Dose Equivalent mrem Percent of Total Radon and thoron 228 37 Cosmic 33 5 Terrestrial 21 3 Internal 29 5 Subtotal for ubiquitous background 311 50 Computed tomography 147 24 Nuclear medicine 77 12 lnterventional fluoroscopy 43 7 Conventional radiography and fluoroscopy 33 5 Subtotal for medical 300 48 Consumer products 13 2 Industrial, security, medical, educational and research 0.3 0.05 Occupational 0.5 0.08 Total 624.8 100 Source: NRC 2014b, Table 3-3.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.12.2:

SUMMARY

OF RADIATION PROTECTION STANDARDS Individual Annual Dose Limit Reference Worker 5 rems TEDE 10 CFR20.1201 50 rems CDE to any organ 10 CFR20.1201 15 rems dose equivalent (DE) lens of eye 10 CFR 20.1201 50 rems DE skin 10 CFR 20.1201 General Public 0.1 rem TEDE all man-made sources 10 CFR20.1301 0.002 rem EDE in any 1-hour period 10 CFR20.1301 25 mrems CDE whole body JO CFR 72. 104 25 mrems CDE any other critical organ JO CFR 72. 104 75 mrems CDE thyroid 10 CFR 72. 104 HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL Hl-2167521 I Rev. 4 3-113 166 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.12.3:

NONFATAL OCCUPATIONAL INJURrES RATES BY INDUSTRY IN NEW MEXICO*

Industry 2014 2013 2012 2011 2010 2009 All industries J.6 1.7 2.0 2.2 2.0 2. 1 Agriculture-crop production 1.3 4.8 4.9 1.3 2.0 --b Agriculture-an imal production 2.8 2.9 0.7 2.4 1.7 2.8 Construction 1.7 1.5 1.9 2.0 2.1 1.7 Mining (except oil & gas) 0.9 l.2 1.5 2.0 2.0 l.9 a Incidence rates represent the number of injuries and illnesses per 100 fulltime workers (working 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week x 50 weeks per year = 200,000 worker hours) reported as cases with days away from work, job transfer, or restriction rate (DOL 2009-2014, New Mexico, first column of link, page I).

b Values were not reported for New Mexico for this industry for this year.

c Values were not reported for "Mining (except oil & gas)" for this year and values reported here are for the most relevant industry reported, which is "Mining, quairying, and oil and gas extraction."

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3: Affected Environment Table 3.12.4:

FATAL OCCUPATIONAL INJURIES RATES BY INDUSTRY IN NEW MEXICO "

lndustrv 2013 2012 2011 2010 2009 Overall rate 6.7 4.8 6.6 4.9 5.2 Construction 15.6 15.7 18.4 17. l 12.l Mining 37.3 28.0 37.3 -- b -- b Manufacturing -- b -- b 17 .1 12.5 -- b Transportation and utilities 55.4 -- b 36.6 20.7 21.0 a From the U.S. DOL Bureau of Labor Statistics, in cooperation with state and Federal agencies, Census of Fatal Occupational Injuries (DOL 2009-20 14, ew Mexico, last column of links). The rate represents the number of fatal occupational injuries per 100,000 full-time equivalent workers and can be used to compare the risk among worker groups with varying employment levels.

b Values were not reported for New Mexico for this industry for this year.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 3 : Affected Environment Table 3.12.5:

INCIDENCE RATES FOR SELECTED CANCERS BY STATE, 2008-2012" State All Sites Lung & Bronchus Breast Prostate Non-Hodgkin Lymphoma Male Female Male Female Female Male Male Female Arizona 420.4 373.9 59.2 47.0 111.0 89.8 18.3 13.3 Colorado 473.7 396.5 52.8 43.3 125.2 133.2 22 .1 15.5 New Mexico 431.2 367.2 49.7 37.4 112.1 110.4 18.0 13.8 Oklahoma 520. l 411.8 90. l 60.2 119.2 128.8 21.9 15.4 Texas 488.5 384.4 73.0 46.7 113.1 115.7 21.8 15.4 Utah 480.6 368.0 34.7 23.7 113. 8 156.8 23.9 15.4 a From ACS 2016, Table 4. lnc1dence rate per I00,000, age-adJusted to the 2000 U.S . standard populat10n.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts CHAPTER 4: ENVIRONMENTAL IMPACTS

4.0 INTRODUCTION

This chapter presents the potential environmental impacts of the Proposed Action and the No Action Alternative. For the Proposed Action, the potential impacts are presented in Sections 4.1-4.13 for the following areas: land use; visual and scenic resources; geology and so ils; water resources; ecological resources; climatology, meteorology, air quality, and noise; cultural resources; socioeconomics and environmental justice; transportation; site infrastructure; waste management; public and occupational health and safety; and accidents. Section 4. 14 presents the potential environmental impacts of the No Action Alternative.

For the Proposed Action, the analysis addresses the potential impacts associated with construction, operations, and decontamination and decommissioning (D&D). Construction impacts are presented for: (1) Phase 1, which accounts for the greatest amount of construction because all support facilities ( e.g., Cask Transfer Building, Security Building, and Administration Building) and supporting infrastructure (e.g., railroad spur and Site access road); and (2) Phases 2-20, which would occur concurrently with operations of any phases previously constructed. Operational impacts account for Phase 1 as well as the full build-out of the Consolidated Interim Storage Facility (CIS Facility) (i.e., storing 10,000 Vertical Ventilated Modules [VVMs] containing 100,000 metric tons of uranium [MTUs] of spent nuclear fue l [SNF]). In order to provide a context for the impacts of the Proposed Action, each resource section also includes a comparative analysis against previous, relevant Nuclear Regulatory Commission (NRC)/other agency environmenta l reviews.

4.1 LAND USE This section describes the potential impacts to land use associated with the Proposed Action.

Construction impacts for Phase 1 are presented in Section 4. 1.1; concurrent impacts from operations and construction of Phases 2-20 are presented in Section 4.1.2; ful l fac ility build-out operations are presented in Section 4.1.3; NRC analysis related to land use is presented in 4.1.4; and D&D impacts are presented in Section 4.1.5. Chapter 6 describes proposed mitigation measures that wou ld be in place to reduce adverse impacts that could occur during construction, routine, and non-routine operation of the CIS Facility.

4.1.1 Construction (Phase 1)

During Phase 1, the initial Independent Spent Fuel Storage Installation ( ISFSl) Pads (for the frrst 500 canisters of SNF that would be stored in the VVMs) and all supporting facilities ( e.g., Cask Transfer Building, Security Building, and Administrative Building) and suppo1ting infrastructure

( e.g., railroad spur and Site access road) wou ld be constructed. Phase I accounts for the greatest amount of construction during any phase of construction and, thus, bounds the construction impacts for any subsequent phase of construction that might occur. Accounting for the Protected Area (i.e. , the area within the security fence conta ining the ISFST Pads and the Cask Transfer Building), Phase I construction would disturb approximate ly 11 9.4 acres. Of this disturbance, 6.2 acres would be associated with constructing the Site access road and relocating the existing road HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-2167521 I Rev.4 4-1 170 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts t hat currently runs through the site; 39.4 acres would be associated w ith constructing the railroad spur; and 1.4 acres would be associated with constructing the Security Building, Administrative Building, Parking Lot, and the concrete batch plant/laydown area.

During construction of the CIS Facility, conventional earthmoving and grading equipment would be used. The removal of very dense soil or caliche may require the use of heavy equipment with ripping tools. Soil removal work for foundations will be controlled to minimize excavation. In addition, loose soil and/or damaged caliche would be removed prior to installation of foundat ions fo r se ismically designed structures.

The CIS Facility would require the installation of water, natural gas, and electrical utility lines, which would result in land disturbance and short-term impacts to vegetation. The construction activities would also include construction of a railroad! spur, which would be routed across relatively level land and wou ld not have to cross major highways. Similarly, a new roadway of approximate ly one mile in lengt h wou ld be constructed to the Site from U nited States (U.S.)

Highway 62/180. Construction of both the railroad spur and roadway would be across Bureau of Land Management (BLM) lands and would not be inconsistent with BLM-designated land use, a lthough add itional Nat ional Environme ntal Policy Act (NEPA) ana lysis would likely be required for a right-of-way (ROW) on Federal lands (ELEA 2007, Section 2. 1).

No water wells are located on the Site. However, the Site has been associated with oil and gas explorat ion and deve lopment with at least 18 plugged and abandoned oil and gas wells located on the prope1ty. However, none of these plugged and abandoned oil and gas wells are located within the area where the ISFSI would be located or where any land would be disturbed and they are not expected to affect the construction and operation of the CIS Facil ity. The plugged wells are estimated to be 30-70 years o ld. It is possible that hydrocarbon contamination exists at the Site as a result of these past practices (ELEA 2007, Appendix 2G). There are no active wells o n the Site and there are no p lans to use any of the plugged and abandoned we lls on the Site.

4.1.2 Concurrent Operatiion and Additional Construction (Phases 2-20)

Construction of Phases 2-20 would occur in 20 phases over approximately 20 years and would require an additional 210.6 acres of land. Such construction would occur adjacent to operational areas previously constructed. Ho ltec would have procedures in place to ensure that the construction activities of Phases 2-20 do not adverse ly affect operations. In terms of land use, this means ensuring an adequate buffer is maintained between operational and construction areas. The construction process for Phases 2-20 would consist of constructing additional ISFSI Pads (each of which would accommodate 500 canisters of SNF). The construction process for additio na l phases would be the same as that for Phase l CIS Facility, with similar impacts to land use. At full build-out, the CIS Facility would contain 10,000 VVMs that would be constructed on approximately 330 acres. The Protected Area would account for 283 acres of this total. Within the Protected Area, approximately 110 acres would be disturbed by the ISFSI once all 20 phases are constructed.

4.l.3 Operation The operation of the CIS Faci lity is not antic ipated to result in any significant impacts to land use considering that the majority of the Site would remain undeveloped. In general, these la nds would likely be used for grazing or other purposes if they were not utilized for the CIS Facility. Currently, HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-216752 1 I Rev.4 4-2 171 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts approximately 93 percent of land in Lea County is used as range land for grazing (approximately 2.6 million acres) (NRC 2012b, Section 3.2). The operation of the CIS Facility at full build-out would restrict activities on 330 acres would result in the loss of0.01 percent of the land available for grazing and other purposes. Due to t he abu ndance of other nearby land for grazing and other purposes, this impact would not be significant.

Although the proposed CIS Facility would change the existing land use ofthe Site, the CIS Facility would be compatible and consistent with land use activities in the area and would be compatible and consistent with the current land use designation fo r the S ite.

4.1.4 Comparable NRC Land Use Analysis This analysis is consistent with NRC Regulation (NUREG)-2157 (NRC 2014b, Section 4.1 ), in which NRC determined that construction and operation of an ISFSI would have minimal impacts on land use. Normal operatio n and ISFSI construction would not significantly affect land use and would not be inconsistent with agency land use.

4.1.5 Decontamination and Decommissioning D&D activities are similar in nature to the construction activities, however, the D&D activities would be expected to be completed within a few years compared to the full CI S Facility construction over 20 years. At the end of useful plant life, the CIS Facility wou ld be decommissio ned such that the Site and remaining facilities could be released for unrestricted use and for NRC license termination pursuant to 10 Code of Federal Regulations (CFR) §20. 1401 and

§20.1 402. Therefore, land use impacts from the D&D would be minimal. Additional information related to the D&D of the CIS Facility can be found in the Holtec License Application.

4.2 VISUAL AND SCENIC RESOURCES This section describes the potential impacts to visual and scenic resources associated with the Proposed Act io n. Construction impacts for Phase l are presented in Section 4.2. L; concurrent impacts from operations and construction ofPhases 2-20 are presented in Section 4. 2.2; fu ll facility operations are presented in Section 4.2.3; NRC analysis related to visual and scenic resources is presented in Section 4.2.4; and D&D impacts are presented in Section 4.2.5. Potentia l mitigation measures are presented in Chapter 6.

4.2.1 Construction (Phase 1)

Construction activities would resu lt in short-term, less than significant impacts to visual and scenic resources. Equipment used during the proposed construction projects of Phase 1 could create a short-term visual effect; however, the visual environment of the Site does not constitute a unique or sensitive viewshed of public interest. In additio n, there are no regionally or locally important or hig h qua lity views associated with the Site. The Site is located in a sparse ly populated area more inclined to be used for cattle grazing or oil and gas exploration and is not visible from any city, township, borough o r identifiable population center. Visibility of the Site is confined to east and west traffic on U.S. Hig hway 62/ 180 and is similar from either direction. Following the completion of construction, the CIS Facility would remain as a permanent visual feature within the viewshed.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts The Site has been determined to be in the Class IV BLM visual resource inventory class, meaning that the level of change allowable to the characteristic landscape can be high, and that these changes may dominate the view and be the major focus of viewer attention. During construction activities of Phase 1, t he visua l and aesthetic characteristics of areas undergoing deve lopment would be temporarily altered by the use of construction equipment, and the delivery and stockpiling of construction materials. Temporary visual intrusions into the landscape may result from the use of construction cranes at the Site fo r erecting building structures and installing equ ipment. Although CIS Faci lity construction would a lter the natural state of the land scape, impacts to scenic views are not considered to be significant, based on the absence of high quality scenic views in the area.

4.2.2 Concurrent Operation and Additional Construction (Phases 2-20)

Construction of Phases 2-20 would result in short-term, less than significant impacts to visual and scenic resources. The viewshed and BLM visual resource inventory class would remain unchanged after completion of Phase 1 construction. Construction of additional phases would occur as operations are occurring at any areas previously constructed. Holtec would have procedures in place to ensure that the construction activities of Phases 2-20 do not adversely affect operations.

The construction process for additional phases would be the same as that for Phase 1 CIS Facility.

Expanding the ISFSI Pad for Phases 2-20 would not cause any additional impacts to visual and scenic resources.

4.2.3 Operation The operation ofPhase 1 CIS Facility is not anticipated to result in any appreciable effects to visual and scenic resources. Given that the Site is undeveloped, the proposed CIS Facility might be considered "out of character" with current, onsite conditions. However, considering that properties in the general area have been developed for industrial purposes ( e.g., numerous oil and gas wells),

the proposed CIS Facility would be similar to existing, architectural features on surrounding land.

The proposed use of the CIS Fac ility site does not fall outside of the objectives for Class IV , which provides for management activities that require major modifications of the existing character of the landscape. Security lighting for all ground level facilities and equipment would be down-shie lded to keep light within the boundaries of the Site, helping to min imize the potential for impacts.

The most visible structure would be the Cask Transfer B uilding, which would be constructed during Phase 1, would be approximately 60 feet high. Due to the relative flatness of the Site and the vicinity, the structures may be observable from nearby highways and properties, partially obstructing views of the existing landscape. However, considering that there are no high quality viewing areas and the presence of many existing, man-made structures (pump jacks, high power lines, industrial buildings, and above-ground tanks) near the CIS Facility, the obstruction of existing views due to the proposed structures would be comparable to current conditions. Overall, the visual impact of the CIS Facility would be minimal. The operation of the CIS Facility at full bu ild-out would not alter visual and scenic resources and the viewshed and BLM visual resource inventory class would remain unchanged.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts 4.2.4 Comparable NRC Visual and Scenic Resources Analysis This analysis is consistent with NUREG-2157 (NRC 2014b, Section 4.14), in which NRC determined that no changes to the visual profile are likely to occur as a result of the continued operation and maintenance of an ISFSI, and that construction of an ISFSI would have minimal impacts on visual and scenic resources.

4.2.5 Decontamination and Decommissioning D&D activities of the CIS Facility would involve removal of all materials from storage and decontamination of the used process equipment and materials from building interiors and from outdoor storage areas, and demolition of structures on the Site. After D&D activities are complete, the area previously occupied by the CIS Facility would be covered with topsoil, contoured, and replanted with native vegetation. The visual and scenic resource impacts resulting from the D&D of the facility would be minimal.

4.3 GEOLOGY AND SOILS This section presents the potential impacts of the construction and operation of the CIS Facil ity on the existing geo logic and soil conditions as well as any existing geologic and soil conditions that may impact the CIS Facility project during construction and operation. Construction impacts for Phase 1 are presented in Section 4.3.1 ; concurrent impacts from operations and construction of Phases 2-20 are presented in Section 4.3.2; fu ll fac ility operations are presented in Section 4.3.3; comparable NRC analysis related to geology and soils is presented in Section 4.3.4; and D&D impacts are presented in Section 4.3.5. Chapter 6 describes proposed mitigation measures that would be in place to reduce adverse impacts that could occur during construction, routine, and non-routine operation of the CIS Facility.

Background. The entire Site is underlain by Triassic bedrock consisting of shale, siltstone, and minor amounts of fine-grained, poorly so1ted sandstone. Most of the proposed operational area is relatively flat and the shale bedrock is covered by a laterally extensive veneer of 25 feet of Quaternary pediment deposits consisting of well sorted eolian sand and sandy-gravelly materials near the bedrock interface. The Mescalero Caliche unit is near the surface and is about 10 feet thick at the Site. The Site is located in an area of low seismic hazard. Risks from landslides, liquefaction, subsidence, and vo lcanism are considered to be low. In addition, areas in vicin ity of the Site contain potash extraction operations and oil/gas wells. Surface soils consist mostly of Simona fine sandy loam and the Simona-Upton association, which are not prime farmland, but are moderately susceptible to wind erosion.

4.3.1 Construction (Phase 1)

The Site terrain ranges in elevation from 3,520 to 3,540 feet above mean sea level (amsl) sloping downward from south to north. Because the CIS Facility requires an area of flat terrain, cut and fill would likely be required for some portions of the Site. Material from the higher portions of the Site would be utilized for fill at the lower areas of the Site to the extent possible. Soil excavated during construction may be utilized for backfill, site grading, or disposed of at an approved offsite disposal fac ility. The resu lting terrain change for the Site from gently sloping to flat topography is HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-2167521 I Rev.4 4-5 174 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts not expected to cause significant environmental impact. Most of the surrounding area contains naturally flat topography (less than 5 percent slope).

CIS Facility construction would disturb soils to a depth of about 25 feet below grade for excavation and grading of the facility. The surficial geologic profile would be permanently altered during construction. However, due to the relatively shallow depth of excavation, construction activity would not induce seismic activity or affect subsurface faults resulting in the accidental discharge of radiological materials or other contaminants to surrounding soils during the operational phase.

Additionally, the groundwater table is located about 90-100 feet deep in the south east corner and 200-300 feet deep in the north east corner, and thus would not likely be impacted by construction (GEi 2017, Section 5.3). Similarly, the excavation for the fac ility would not impact existing oil and gas or mineral deposits because these resources are located at much greater depths. The fac ility components do not overlap active oil and gas wells; however, the proposed rail spur does appear to intersect the edge of two potash "drill island" locations identified as Belco Shallow and Belco Deep. Holtec has concluded that the rail spur would not impact potash mining operations (Holtec 2016a).

Construction activities like c learing and grad ing of soils, may cause sho11-term increases in soil erosion from wind and water. The bulk of construction wou ld occur in the Simona fine sandy loam and Simona-Upton association, which are slightly susceptible to water erosion, and somewhat susceptible to wind erosion. Additionally, surface storm water during constmction could potentially impact nearby waterbodies and drainages by increasing the sediment load to these receptors. Additionally, there would be a long-term loss of the native surficial soil profile, within the disturbed operational footprint of the facility. However, the Lea County Soils Survey describes soils found at the CIS Facility Site as not prime farmland, thus, the construction of the CIS Facility is not anticipated to displace any potential agricultural use (USDA/NRCS 2016).

4.3.2 Concurrent Operatiion and Additional Construction (Phases 2-20)

The construction impacts described in Section 4.3.1 are representative of the CIS Facil ity construction for additional phases. The phased construction approach (for Phases 2-20) would have the same types of impacts as Phase 1 construction and Holtec would have procedures in place to ensure that any concurrent construction activities of Phases 2-20 do not adversely affect operations. Additionally, mitigation measures for soil stabilization and sediment control would be applied during all phases of construction, as described in Chapter 6.

4.3.3 Operation Once facility construction is complete, the exposed soils and excavations would be covered by structures or paved, preventing the creation of new dust sources. Operation of the CIS Facil ity is not expected to affect the underlying geology because the CIS Facility does not have moving parts to affect the subsurface. Although soils may be affected by spills and leaks of radiological and hazardous materials, the CIS Facility is designed to prevent leakage and licensee employees would conduct routine inspections to verify that the CIS Facility is performing as expected. Leaks could result in spills of oil and hazardous material from operating equipment and stormwater runoff carrying grease. However, these activities are monitored and, in the case of stormwater runoff, regulated under National Pollutant Discharge E limination System (NPDES) permit requirements.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Mitigation measures for spill prevention and sto1mwater management would be applied during operations, as described in Chapter 6.

Operation of the CIS Facility would not be expected to be impacted from geologic hazards such as seismic events, subsidence, liquefaction, landslides, or volcanism. The proposed facility is in a flat area of relatively low seismic hazard, thus, earthquakes, liquefaction, and landslides are considered as low risk hazards. Additionally, the CIS Facility would be constructed in accordance with 10 CFR §72. 122, General Design Criteria, Overall Requirements, which requires that structures, systems, and components important to safety must be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, lighting, hurricanes, floods, tsunami, and seiches, without impairing their capability to perform safety functions.

The Site is not in a volcanically active area, and volcanic risk hazards are therefore low. The Site is also not near a water body and tsunami and seiche hazards are also therefore low.

The CIS Facility and associated facilities would not be expected to impact existing potash and oil/gas operations in the area. Access to mineral resources directly underneath the footprint of the CIS Facility would be precluded during the operational life of the facility; however, these resources are widely available e lsewhere in the region.

4.3.4 Comparable NRC Geology and Soils Analysis The impacts to geology and soils from interim storage of SNF were previously analyzed in NUREG-2157 (NRC 2014b, Section 5.6). The analysis in NUREG-2157 indicated the following types of geology and soils impacts could occur.

  • Construction impacts associated with away-from-reactor storage include earth clearing and foundation laying for the ISFSI, both of which may contribute to soil erosion.
  • The environmental impacts on soils would include loss of soi ls as a result of physical alterations to the existing soil profile. These alterations could lead to a reduced availability to support p la nt and an imal life and could lead to changes in erosion patterns and characteristics that affect how water infiltrates into the soil. However, the NRC concluded that these losses are a small percentage of the similar available soils locally. The NRC also noted that so ils used in project construction are recoverable upon faci lity decomm issioning, and that no excess soils would be generated that require shipment or disposal off-site.
  • Similarly, economic geologic resources (such as minerals, oil, and gas, if present) that would be unavailable for exploitation during faci lity construction and operation are widely available elsewhere in the region.
  • The amount of land committed to the away-from-reactor ISFSI is relatively small compared, for examp le, to the land available in a typical county. The methods necessary to contro l soil erosion are well understood and permits typically require the imple mentation of erosion controls.
  • Because of the relative ly small size of the fac ility, restrictions on access to geologic resources under the ISFSI site would also be minimal.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts

  • In general, whi le the geological characteristics of the site and vicinity are essential to the safe design and operation of the ISFSI, continued storage of spent fuel does not have a significant enviromnental impact on geological resources (such as, damage to unstable slopes, adjacent utilities, or nearby structures).

For these reasons, the NRC concluded that the impacts on soils and geologic resources from the building and long-term operation of an away-from-reactor ISFSI would be small. The conclusion in this ER is consistent with the NRC conclusion in NUREG-2157.

4.3.5 Decontamination and Decommissioning The CIS Facility would be designed and constructed in a manner that would minimize the quantity ofradiological-contaminated equipment and facilitate the removal of such materials at the time the CIS Facility is permanent ly decommissioned pursuant to 10 CFR §72. 130. Final radio logical and site surveys and removal of any contaminated soils identified during these surveys (from both radiological and non-radiological contamination) are required under 10 CFR Part 20, Subpart E.

At the time of license termination, the Site would be released for unrestricted use in accordance w ith 10 CFR Part 20, Subpart E.

During D&D, some ground disturbance would occur from the use of machinery such as bulldozers to demolish fac ility buildings. However, ground disturbance would generally be limited to areas previously disturbed during the construction and operation phases. Mitigation measures used during construction would be applied during D&D; therefore, impacts to geology and soils would be similar to or less than during construction, and would be short-term. Because the Project infrastructure would be removed, there would be complete access to mineral resources. After D&D activities are comp lete, the area previously occupied by the CIS Facility would be covered with topsoil, contoured, and replanted w ith native vegetation. Therefore, the impacts to geology and soils fro m D&D would be small.

4.4 ECOLOGICAL RESOURCES This section describes the potential impacts to ecological resources associated with the CIS Facility. Construction impacts for Phase 1 are presented in Section 4.4.1; concurrent impacts from operations and construction of Phases 2-20 are presented in Section 4.4.2; full fac il ity operations are presented in Section 4.4.3; threatened and endangered species are discussed in Section 4.4.4; consultations w ith agencies are discussed in Section 4.4. 5; comparable NRC analysis related to ecology is presented in Section 4.4.6; and D&D impacts are presented in Section 4.4.7. Potential mitigation measures are presented in Chapter 6.

4.4.1 Construction (Phase 1)

As discussed in Section 4.1.1, Phase 1 construction wo uld disturb approximately 119.4 acres w ithin an approximately 1,040 acre site within BLM Section 13. The ecological impacts of this land disturbance are expected to be small given the CIS Facility area size, especially in relation to the vast amount ofuninhabited and undisturbed land found throughout the region. The CIS Facil ity consists entirely of an upland area with no streams, ponds or other water environments to be cleared.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts The proposed CIS Facility consists of one primary vegetation community type. The Apacherian-Chihuahuan mesquite upland scrub vegetation community is identified by the dominant presence of deep-rooted shrubs that are able to access the deep-soil moisture. The Apacherian-Chihuahuan mesquite upland scrub vegetation commun ity is common in the piedmonts of the Chihuahuan Desert. The density of vegetation varies slightly across the proposed Site, due to several low-lying areas that collect water after heavy rain events. Vegetation is intersected by two existing linear features: a telephone line and a water pipeline. Each of these existing right-of-ways are used as two-track roads that are vegetated in between tracks. The non-vegetated area of t he tracks themselves represents a small fraction of the total area and is not considered a habitat type. The majority of the proposed Site is suitable for use by wildlife resources. The Apacherian-Chihuahuan mesquite upland scrub provides potential habitat for an assortment of birds, mammals, and reptiles.

Because the Apacherian-Chihuahuan mesquite upland scrub is common in this region, the disturbance to the biota due to CIS Facility construction would be insignificant.

Standard land clearing methods, primarily the use of heavy equipment, would be used during the construction phase of the CIS Facility. The additiona l noise, dust, and other factors associated with the clearing would be short-lived in duration and would represent only a temporary impact to the biota of the CIS Facility. Because there is similar habitat surround the CIS Facility area, biota would have an opportunity to move to undisturbed areas w ithin areas of suitable habitat bordering the Site.

After construction is complete, the Site would be stabilized with native grass species, pavement, and crushed stone to control erosion. Furthermore, any eroded areas that may develop would be repaired and stabilized.

4.4.2 Concurrent Operatiion and Additional Construction (Phases 2-20)

Figure 2.2.1 depicts a view of the proposed Holtec CIS Facility development. The land to be cleared for the full build-out of the CIS Facility is approximately 330 acres, as detailed in Section 4.1. The construction impacts described in Section 4.4. 1 are representative of the CIS Facility construction for additional phases. The phased construction approach (for Phases 2-20) would have the same types of impacts as Phase 1 construction and Holtec would have procedures in place to ensure that any concurrent construction activities of Phases 2-20 do not adversely affect operations.

4.4.3 Operation Once fully operational, the CIS Facility would have minimal impacts to ecological resources. The CIS Facility would not generate significant noise, would not significantly affect the area available for terrestrial wildlife, and would not adversely impact terrestrial environments or their associated plant and animal species.

Roadway and railway maintenance would be employed during operation of the CIS Facility.

However, because road maintenance is currently being employed along the existing roads and railways, this would not represent a substantial new impact to biota. The impacts to biota from maintenance practices during CIS Faci lity construction, operations, and decommissioning wou ld be small.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Herbicides may be used in limited amounts according to government regulations and manufacturer's instructions to control unwanted noxious vegetation during operation ofthe facility.

However, none of the practices are anticipated to permanently affect biota.

The tallest proposed CIS Facility structure would be approximately 60 feet, which is well under the 200 foot threshold that requires lights for aviation safety. This avoidance oflights, which attract species, and the low above-ground level structure height, also reduces the relative potential fo r impacts to wildlife. Additionally, security lighting for all ground level fac ilities and equipment would be down-shielded to keep light within the boundaries of the Site, also helping to minimize t he potential for light pollution impacts.

No important habitats (e.g., marshes, natural areas, bogs) have been identified on the CIS Facility area. Therefore, no special maintenance practices are proposed once the CIS Facility is operational, and there would be no direct discharge of water. Consequently, no sign ificant impacts to aquatic systems are expected.

4.4.4 Threatened and Endangered Species No communities or habitats that have been defined as rare or unique or that support threatened and endangered species have been identified on the CIS Facility. Thus, proposed activities are not expected to impact communities or habitats defined as rare or unique or that support threatened and endangered species within the Site.

4.4.5 Consultations with Agencies The results of the ecological survey have been provided to the New Mexico Environmental Department (NMED) and U nited States Fish and Wild) ife Service (USFWS) for information.

Consultation would be initiated by the Federal agencies, as appropriate, during any subsequent National Environmental Policy Act (NEPA) process.

4.4.6 Comparable NRC Ecological Analysis This analysis is consistent with the NUREG-2157 (NRC 2014b), in which NRC determined that construction and operation of an ISFSI would have minimal impacts on terrestria l resources.

Normal operations and TSFST construction wou ld not generate significant noise, would not significantly affect the area available for terrestrial wildlife, and would not adversely impact terrestrial environments or their associated plant and anima l species (NRC 2014b).

4.4.7 Decontamination and Decommissioning D&D activities would be similar to construction activities, with the exception that land would be restored rather than disturbed. After D&D activities are complete, the area previously occupied by the CIS Facility would be covered with topsoil, contoured, replanted with native vegetation, and released for unrestricted use in accordance w ith l O CFR Part 20, Subpart E.

4.5 WATER RESOURCES This section describes the potential impacts to water resources associated with the Proposed Action. Construction impacts for Phase I are presented in Section 4.5. 1; concurrent impacts from HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-2167521 I Rev.4 4-10 179 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts operations and construction of Phases 2-20 are presented in Section 4. 5.2; full fac ility operations are presented in Section 4.5.3; NRC analysis related to land use is presented in 4.5.4; and D&D impacts are presented in Section 4.5.5. Chapter 6 describes proposed mitigation measures that would be in place to reduce adverse impacts that could occur during construction, routine, and non-routine operation of the CIS Facility.

4.5.1 Construction Impacts (Phase 1)

Water resources are essentia lly nonexistent at the Site. There are no surface water bodies on the Site and groundwater resources are at depths of93.l to 100 feet and 253.4 to 263.7 feet at wells B107 and B101, respectively.(GEI 201 7, Section 5.3). The region has a semi-arid climate, with low precip itation rates and minimal surface water occurrence. Thu s, the potential fo r negative impacts on water resources is very low due to lack of water presence and formidable natural barriers to any surface or subsurface water occmrences.

Construction activities associated with Phase 1, including grading and clearing wou ld result in ground surface disturbance and could cause soil erosion and subsequent transport of sediment via stormwater. As discussed in Chapter 6, implementing erosion and sediment control best management practices (BMPs) during construction would minimize any adverse effects on water resources. BMPs cou ld include silt fencing, sediment traps, applying water sprays for dust control, and revegetating disturbed areas.

Phase I construction wou ld have short-term less than significant effects and long-term effects to water resources. Short-term effects would be due to site-specific temporary changes in surface hydrology, and the potential for soil erosion and transpo1t during construction. Long-term effects would be due to an increase in impervious surfaces. Effects to water resources would not reduce water availability or supply, exceed safe annual yie ld of water supplies, adversely affect water quality, threaten or damage hydrology, or violate water resources laws or regulations. These effects would be less than significant. Although the effects would be less than significant, BMPs would be incorporated into all construction activities to minimize erosion, runoff, and sedimentation.

Permits related to water must be obtained for pre-licensing and site construction and CIS Facility operation. The purpose of these permits is to address the various potential impacts on water and provide mitigation as needed to maintain state water qual ity standards and avoid any degradation to water resources at or near the site. These permits include:

  • A NPDES General Permit fo r Industrial Stormwater: This permit is required for point source discharge of stormwater runoff from industrial or commercial fac ilities to the waters of the State. All new and existing point source industrial stormwater discharges associated with industrial activity require a NPDES Stormwater Permit from the U.S. Environmental Protection Agency (EPA) Region 6 and an oversight review by the New Mexico Water Quality Bureau (NMWQB).
  • NPDES General Permit fo r Construction Stormwater: Because construction of the CIS Facility facility will involve the disturbance of more than one acre of land, an NPDES Construction General Permit from the EPA Region 6 and an oversight review by the NMWQB are required.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts

  • Section 401 Certification: Under Section 40 l of the C lean Water Act (CWA), States can review and approve, condition, or deny all Federal permits or licenses that might result in a discharge to State waters, including wetlands. A 401 certification confirms compliance with the State water quality standards. Activities that require a 40 l certificatio n include Section 404 permits issued by the U.S. Army Corps of Engineers (USACE). The State of New Mexico has a cooperative agreement and joint application process with the USACE re lating to 404 permits and 401 certifications.

Surface Water. There are no surface waters at the Site. The only major natural lakes or ponds within 6 miles of the Site include Laguna Gatuna, Laguna Tonto, Laguna Plata, and Laguna Toston which are ephemeral playas. During construction and operation of the CIS Facility, potable water will be supplied by existing potable water systems. No adverse impacts to surface water are anticipated during construction of the proposed CIS Facility. Surface runoff from the Site would flow into Laguna Gatuna to the east and Laguna Plata to the northwest and would not reach groundwater. Lagw1a Gatuna and Laguna Plata are large enough to accommodate a 100-year return period precipitation event.

Groundwater. Due to the depth of groundwater, excavation during construction wou ld not reach the groundwater. The near surface water table appears to be 35-50 feet deep, where present, and is likely controlled by the water level in the playa lakes. No groundwater was encountered in the test boring on the west side of the Site in the vicinity where the ISFSI would be located (ELEA 2007, Section 2.4.2). The depth of groundwater was measured at two locations, Bl Ol and B 10 l, see Figure 3.5.4. Groundwater was observed in B101 from a depth range of 253.4 to 263.7 feet, and observed in B107 from a depth range of 93.1 to 100 feet from the ground surface (GEi 2017, Section 5.3).

Wetlands. No USACE jurisdictional wetlands were identified on the Site (ELEA 2007, Section 2.5); therefore, there would be no impacts to wetlands during construction of the proposed CIS Facility.

Floodplains. The proposed CIS Facility site or Lea County has no floodplains identified or mapped for Lea County, New Mexico (FEMA 2008, Section 6.0; FEMA 2016); therefore, there would be no impacts to floodplains during construction of the proposed CIS Facility.

4.5.2 Concurrent Operation and Additional Construction (Phases 2-20)

Construction of Phases 2-20 would occur as operations are occurring at any areas previously constructed. Holtec would have procedures in place to ensure that the construction activities of Phases 2-20 do not adversely affect operations. In terms of water resources, this means ensuring an adequate buffer is maintained between operational and construction areas. The construction process fo r additional phases would be the same as that fo r Phase 1 CIS Facility. Water resource impacts during construction activities for Phases 2-20 would be the same as those for Phase 1.

4.5.3 Operation The operation of the CIS Facility at full build-out is not anticipated to result in any appreciable effects to water resources. Potential impacts could result primarily from runoff contamination. The most significant source for runoff during operations would be the concrete ISFSI Pad.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Contamination is highly unl ike ly. The VVM storage system design and construction, a long with environmental monitoring of the ISFSI Pad combine to make the potential for contaminant release from the CIS Facility extremely low. Impacts to groundwater would not be expected, due to the depth of groundwater and the fact that the CIS Fac il ity would not release po llutants, including radionuclides, during normal operations. Similarly, impacts to the near surface water ta ble would be unlikely.

To estimate the potential effects of rainfall-induced stormwater runoff, Holtec reviewed precipitation data for the area spam1ing more than 50-years as well as other available data developed for other nuclear facilities in the area. As discussed in Section 3.6.1.7, the highest daily precipitation in the area was 3.6 inches, which occurred in December of 2015. Based on the data reviews, Holtec determined that the maximum flood at the CIS Facility site would be similar to the maximum flood developed by NRC in 2012 for the International Isotopes Fluorine Products (IIFP) facility. located approximately 23 miles northeast of the proposed CIS Facility. Given the proximity of the IIFP facility to the CIS Facility site (approximately 23 miles northeast), the maximum flood at the IIFP facil ity site reasonably represents the maximum flood that could occur at the CIS Facility site.

In the Safety Evaluation Report for the IIFP faci lity (NUREG-2116; NRC 2012b), the NRC estimated the 1-hour, 24-hour, and 48-hour all-season precipitation corresponding to a 100,000-year return period by extrapolating the National Oceanic and Atmospheric Administration (NOAA) precipitation data. Considering the 1- hour, 24-hour, and 48-hour all-season precipitation for a 100,000-year return period, the NRC concluded that the estimated maximum flood (standing water) level would be 4.8 inches (NRC 2012b, Section 1.3.3.4.4). The topography of the Site shows a high point located on the southern border of the Site and gentle slopes leading to the two drainages (Laguna P lata and Laguna Gatuna). Both of these drainages would be able to accept a one day severe storm total within the 7.5 inch range with excess free board space. The natural drainage of the CIS Facility site is useful by providing a natural area for impoundment of excess runoff during severe storms (ELEA 2007).

4.5.4 Comparable NRC Infrastructure Analysis This analysis is consistent w ith NUREG-2157 (NRC 201 4b), in which NRC determined that construction and operation of an ISFSI would have minimal impacts on water resources. Normal operation and ISFSI construction would not significantly affect water resources.

4.5.5 Decontamination and Decommissioning A Decommissioning Plan would be prepared at the end of CIS Facility fac ility life and would include decontamination, dismantlement, and clean-up procedures; methodology and general decontamination and cleaning methods; and waste management protocol. These procedures, methods, and protocol would be designed to prevent impacts to groundwater quality; therefore, impacts to groundwater quality during decommissioning would be minimal. Sampling wou ld also be integral to t he D&D process to demonstrate that any residual impacts, as compared to the baseline sampling results, meet NRC and EPA guidelines. The overall impact to water resources from D&D activities would be minimal.

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts 4.6 AIR QUALITY AND NOISE This section describes the air quality (Section 4.6.1) and noise (Section 4.6.2) impacts of the Proposed Action during construction, operations, and decommissioning, and compares those impacts to standards for evaluation. With in the section, the potential impacts associated w ith Phase 1 construction, concurrent operation and construction (Phases 2-20), and operations at fu ll build-out are presented. Potential mitigation measures are presented in Chapter 6.

4.6.1 Air Quality Impacts Overall, the impacts on a ir quality during both construction and operations are expected to be minimal. Although the initia l, temporary impacts from construction would be greater than operations, the impacts would be minimal in both cases.

4.6.1.1 Construction (Phases 1-20)

The primary air emissions during construction would be fugitive dust. Fugitive dust is airborne PM that is not emitted :from a definable point source, such as a combustion unit stack or a process vent, but rather is em itted :from natural and manmade area sources open to the atmosphere (e.g.,

earthmoving activities, unpaved roadways, and cement plants). Engine exhaust air emissions would be produced by heavy duty, off-road construction equipment, vehicle emissions :from workers commuting to the Site, and deliveries of materials to the Site. These emissions are typically products ofcombust ion which includes carbon monoxide (CO), oxides of nitrogen (NOx),

sulfur dioxide (S02), and the Greenhouse Gas (GHG) compound of carbon dioxide equivalent (C02e), with minimal emissions of volatile organic compounds (VOCs), particulate matter less than or equal to 10 microns (PM10), and particulate matter less than or equal to 2.5 microns (PM2.s).

Small quantities of VOC emissions would be released from the refueling and on-site maintenance of the off-road construction equipment used for construction. There is the potential for additiona l VOC emissions from certain painting and other construction-finishing activities, depending on the amounts of organic solvent-based paints and architectural coatings that would be used for the buildings and other structures. All emissions would result in minimal impacts to the air quality.

The fugitive dust emissions would be derived from three main sources: earthmoving activities, unpaved roadways, and cement plants. In order to provide a conservative and bounding analysis of potential air quality impacts, the emissions associated with earthmoving activities. were calculated using generally accepted methods for the full 330 acres ofland that would be disturbed over the construction period (WRAP 2006, Section 3.2.1 ). The road emissions were estimated using a mix of vehicles, such as cranes, fork lift s, and dump trucks, traveling up to one-half mile trips up to five trips per day with generally accepted emission factors and methods (AP42 2006, Section 13 .2.2) and (TCEQ 200 I). 1 The cement plant emissions were calculated using generally accepted air emission calculations with an estimate of four hundred thousand tons of cement being used per year (AP42 2006, Section 13.2.4).

1 New Mexico has not created air emission factors and calculation methodology guidance documents, and generally accepts calculation methodologies from other states like Texas and Cali fornia which are used here.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Of the combustion sources, vehicle exhaust would be the dominant source. Vehicles that would be operating on the Site during construction would consist of a variety of vehicles and construction equipment. A mix of these vehicles was used to estimate emissions (CARB 201 6). Also evaluated were emissions from vehicles fo r workers trave ling to the Site and materials being de livered to the Site. The emissions were estimated based on an annual period using generally accepted emission factors and methods (CARB 2016).

Other VOC emissions from the project would be from the storage and loading of diesel fue l and gasoline for on-site construction equipment and architectural coatings. The emissions for fuel loading were estimated using the TANKS4.09 emissions modeling software that uses generally accepted emission factors and methods based on estimated activities of similar sites over a six month period (AP42 2006, Section 7. 1). The emissions for painting were estimated using generally accepted emission factors and methods based on estimated activities of similar sites over a six month period (TCEQ 20 11 ).

Tables 4.6-1 and 4.6-2 present the hourly emissions and annual emission from construction, respectively, of the criteria pollutants CO, NOx, S02, PM, PM10, PM2.s, VOCs, and C02e based on emission estimates developed for the construction activities. All sources are from temporary activities during construction. Emissions from a ll criteria pollutants would be less than 10 pounds per hour (PPH) and 10 tons per year (TPY). Emissions from greenhouse gas (GHG) emission would be less than 25,000 TPY. These emission rates are below regulatory standards requiring regulation, whic h further indicates the min imal impact that emissions would have on the environment. In accordance with New Mexico Air Regulations, sources with emissions less than 10 PPH and 10 TPY of each criteria pollutant in counties that are in attainment of National Ambient Air Quality Standards (NAAQS) are not required to obtain an air permit (NMAC 2016, Section 20.2.73). The proposed CIS Facility Site would be in Lea County, an attainme nt county for NAAQS; and would have emissions less 10 PPH and 10 TPY. This "no permit required" status is presumed to be protective of the environment and to meet NAAQS and New Mexico Air Quality Standards (NMAAQS). Due to this, no modeling or further impacts evaluation was performed, and the impacts of emissions from the Proposed Action on air quality wou ld be minimal.

GHG compounds are typically evaluated at sites with stationary equipment that emit more than 25,000 TPY of C0 2e (40 CFR 98, Section 98.2). Though emissions from activities at the CIS Facility Site would be fro m non-stationary sources, the GHG emissions would be well below this minimal standard ; thus, impacts of GHG em issions from this project on air quality would be minimal.

4.6.1.2 Operation (Includes Phases 2-20 Construction)

During operations, the primary source of emissions would be from deliveries of materials to be stored onsite. There is expected to be emissions of fugitive dust, wh ich is PM that is not emitted from a definable point source, such as a combustion unit stack or a process vent, but rather is emitted from natural and manmade area sources open to the atmosphere from unpaved roadways.

Emissions from engine exhaust would also be produced by vehicles delivering materials to the Site and workers commuting to the Site. These emissions are typically products of combustion that includes CO, NOx, S02, and C02e, with mini mal emissions of VOC, PM10, and PM2.s. No radiological emissions would occur during operations.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Fugitive dust emissions derived from road emissions were estimated using a mix of vehicles, such as cranes, forklifts, and dump trucks, traveling up to one-half mile trips up to five trip s per day over a one year month period with generally accepted emission factors and methods (AP42 2006, Section 13.2) and (TCEQ 2001).

Emissions from vehicles for workers traveling to the Site and materials being delivered to the Site were evaluated. The emissions were estimated based on an annual period using generally accepted emission facto rs and methods (CARB 2016). Until fu ll build-out is achieved, ongoing construction would occur. It is estimated that emissions from ongoing construction would only be a fraction, approximately fifteen percent, of the initial constmction. Emission estimates were created based on activities to operate the facility plus fifteen percent of the initial construction emissions for ongoing construction. (Because the air quality impacts fo r operations are essentially independent of the capacity of SNF stored at the CIS Facility, the analysis which follows provides a bounding air quality analysis because it accounts for both concurrent construction and operation). Tables 4.6.3 and 4.6.4 present the hourly emissions and annua l emission from both operations and ongo ing construction, respective ly, of the criteria pollutants CO, NOx, S02, PM, PM1 0, PM2.s, and VOCs; and the GHG compound ofC02e.

All sources are activities that wou ld occur once t he CIS Facility Site is in operation along with the ongoing construction. Emissions from all criteria pollutants would be less than 10 PPH and 10 TPY. Emissions from GHG emission would be less than 25,000 TPY. These emission rates are be low regu latory standards requiring regu lation, which further ind icates the minima l impact that emissions would have on the environment.

As presented above, air emissions during the operational and ongoing construction phase are expected to be less than 10 PPH and 10 TPY for all criteria po llutants expected to be emitted. In accordance w ith New Mexico Air Regu Jations, sources w ith emissions less than IO PPH and 10 TPY of each criteria pollutant in counties that are in attainment of NAAQS are not required to obtain an a ir permit (NMAC 2016, Section 20.2.73). The proposed CIS Facility Site would be in Lea County, an attainment county for NAAQS; and would have emissions Jess 10 PPH and 10 TPY. This "no permit required" status is presumed to be protective of the environment a nd to meet NAAQS and NMAAQS. Due to this, no modeling or furt her impacts evaluation was performed, and the impacts of emissions from the Proposed Action on air quality would be minimal.

GHG compounds are typically evaluated at sites with stationary equipment that emit more than 25,000 TPY of C02e (40 CFR 98, Section 98.2). Though emissions from activities at the CIS Facility Site would be from non-stationary sources, the GHG emissions would be well below this minimal standard; thus, imp acts of GHG emissions from this project on air quality would be minimal.

4.6.1.3 Comparable NRC Air Quality Analyses This analysis is consistent with the NUREG-2 157 (NRC 2014b), in which NRC determined that the air emission impacts from SNF storage activities would be substantially smaller than air emissions during power generation. The NRC also concluded that construction of an IFSFI, dming ongoing operation and maintenance of the storage fac ilities, would result in minor and temporary HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-216752 1 I Rev.4 4-16 185 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts air emissions. Additionally, the NRC concluded that greenhouse gas emissions would be a small fraction of the overall level in the U.S. (NRC 2014b).

4.6.1.4 Decontamination and Decommissioning Activities required for D&D include the removal of equipment from inside of buildings and demolishing the CIS Facility Site. This activity is not expected to produce any significant levels of fug itive dust or other air emiss ions. Heavy duty, off-road construction equ ipment would be required for the demo lition of the structures and loading of demolition debris into trucks for off-site disposal. These demolition activities would produce fugitive dust emissions that could be mitigated using water sprays and other dust suppression work practices. Shipping destinations for disposa l oft he demo lition debris removed from the CIS Facility Site would depend on the locations of the land disposal, recycling, or other facilities open and accepting material at the time of fac ility closure. However; emissions and impacts are expected to be similar or less than those emissions from construction. Thus, the impacts are expected to be minimal from D&D.

4.6.2 Noise Noise is defined as unwanted sound. H igh leve ls of noise can damage hearing, cause sleep deprivation, interfere w ith communication, and disrupt concentration. Even at low levels, noise can be a source of irritation, annoyance, and disturbance to people and communities when it significantly exceeds normal background sound levels. In the context of protecting the public health and welfare, no ise implies adverse effects on people and the environment. Th is section presents the impacts of noise during construction, operations, and D&D.

4.6.2.1 Construction (Phases 1-20)

Construction activities at the CIS Facility Site would require the use of heavy equipment such as excavators, front loaders, bulldozers, and dump trucks; and materials-handling equipment, such as cement mixers and cranes. Noise generated from this type of equipment would range from 80 to 95 dBA at approximately 50 feet (IIFP 2009, Section 4.7), which would be equivalent of 50 to 66 A-weighted decibels (dBA) at approximately 1,200 feet. Most of the construction activities would occur during weekday, daylight hours; however, construction could occur during nights and weekends, if necessary. Large trucks would produce noise levels around 85 dBA at approximately 50 feet, which is equivalent of 56 dBA at approximately 1,200 feet (see Table 4.6.5).

The CIS Facility Site would be built approximately 1,350 feet from either U.S. 62/ 180 or NM 243.

Considering the sound pressure level from an outdoor noise source decreases 6 decibel units ( dB) per doubling of distance, the highest noise level predicted at either road during construction is expected to be within the range of 44 dBA to 59 dBA. In general, the highest no ise level is predicted to be less than 44 dBA to 59 dBA from any public area. Further, finishing work within the building structures would create noise levels slightly above normal background levels, but well below the construction levels. Sound levels wou ld be expected to dissipate to near background levels by the time they reach the property boundaries.

No sens itive noise resources are located in the immediate vicinity of the Site. As shown in Table 3.6.8 "Department of Housing and Urban Development (HUD) Noise Assessment Gu idelines",

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts

( dB) (HUD 2016). Due to the temporary and episodic nature of construction, the significant distance to the nearest residence being over one mile from the CIS Facility Site, and since construction activities largely would be during weekday daylight hours, actual construction noise at the Site is not expected to have a significant effect on the area, the public, or the closest resident.

Vehicle traffic would be the most noticeable cause of construction noise. There are no sensitive receptors (hospitals, schools, residences) located close to the Site. Due to this, minimal impacts from noise from construction are expected. As documented in Sections 3.7 and 4.7, there are no cultural resources that could be affected by noise from the CIS Facility.

4.6.2.2 Concurrent Operatiion and Construction (Phases 2-20)

As presented in Section 4.6.2.1, construction noise is expected to have a minimal impact on the area. Any construction associated with Phases 2-20 would be similar to that of Phase 1 construction, and, when combined with noise from operations, would not be expected to be significant given the remoteness of the Site. As a result, minimal impacts from concurrent operations and construction are expected.

4.6.2.3 Operation Noise point sources from the plant during operation would include: coolers, rooftop fans, air conditioners, transformers, and traffic from delivery trucks, employee and Site vehicles. Noise sources for the plant during operation would consist only of Site vehicle traffic entering and leaving the Site. Ambient background noise sources in the area include vehicle traffic a long U.S.

Highway 62/180 and New Mexico State Road 243, and low flying aircraft traffic from the Hobbs Regional Airport.

Because actual noise estimates are not available for the operation ofthe CIS Facility Site, measured noise levels around an automobile assembly plant were u sed to estimate potential noise impacts conservatively high. These noise levels are 55 to 60 dBA at about 200 feet from the plant property.

These noise levels would be inaudible at the nearest highway (U.S. Highway 62/ 180), even with low background noise levels. EPA has identified 55 dBA as a nearly average outdoor noise leve l that, if not exceeded, wou ld prevent activity interference a nd annoyance (IIFP 2009, Section 4.7).

Further, as shown in Table 3.6.8 "HUD Noise Assessment Guidelines"; acceptable ranges for residential areas, the lowest acceptability area, is between 60 and 65 dB (HUD 2016). Sound levels from CIS Facility Site operations are expected to dissipate to background levels by the time they reach the prope1ty boundary. Certain phases of operation, weather, time of day, w ind direction, traffic patterns, season, and the location of the receptor would all impact perceived operational noise levels. Although the noise from the plant and the additional traffic would generally be noticeable on the surround ing U.S. Highway 62/ 180 and New Mexico State Road 243, the operational noise from the pla nt is not expected to have a significant noise impact on nearby traffic or the surrounding area. Due to this, minimal impacts from noise from operations are expected.

4.6.2.4 Comparable NRC Noise Analyses This analysis is consistent with the NUREG-2157 (NRC 2014b), in which NRC determined that dry cask storage noise levels, noise duration, and distance between noise sources and receptors would generally not be expected to produce noise impacts noticeable to the surrounding HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-216752 1 I Rev.4 4-18 187 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts community. The NRC also concluded that construction ofan ISFSI could result in noise levels that exceed EPA-recommended noise levels, but noted that such impacts would be temporary. Because the proposed CIS Facility Site is located in a relatively isolated area, with no sensitive receptors located close to the Site, construction noise would not exceed EPA-recommended noise levels.

4.6.2.5 Decontamination and Decommissioning D&D of the CIS Facility Site would produce sound levels similar to or lower than those generated during construction activities. The majority of activities would involve D&D facility equipment and hauling the materials off-site. As a result, the majority of the noise impacting the community would relate to the noise of hauling traffic. Because the anticipated noise emissions would be similar to those during construction, the estimated noise impact is expected to be minimal.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Table 4.6.1:

TOT AL CONSTRUCTION EM ISSIONS - POUNDS PER HOUR Source co NO, S01 PM10 PM1.s voe C01e PM Construction 2.70 6.06 0.01 0.21 0.21 0.73 1,056.87 <0.01 Equipment Construction Worker 0.3 1 0.03 <0.01 <0.01 <0.01 0.03 55.17 <0.01 Commuting Material Delivery 0.77 2.12 <0.0 1 0.10 0.09 0.18 421.11 <0.01 Earthmoving Activities <0.01 <0.0 1 <0.01 0.97 0.10 <0.01 <0.01 <O.Ol Road Emissions <0.01 <0.01 <0.01 0.03 <0.01 <0.01 <0.01 0.24 Cement Plant <0.0] <0.0 1 <0.01 2.63 0.43 <0.01 <0.01 8.82 Other VOC (Paint and

<0.0] <0.01 <0.01 <0.01 <0.01 8.30 <0.01 <0.01 Fuel)

Total 3.78 8.21 0.01 3.95 0.83 9.24 1,533.15 9.06 Sources: CARB 2016; WRAP 2006; Section 3.2.1; AP42 2006; Sections 7.1 , 13.2.2, and 13.2.4; TCEQ 2001, and TCEQ 201 1.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Table 4.6.2:

TOT AL CONSTRUCTION EMISSIONS - TONS PER YEAR Source co NO, S02 PM10 PM2.s voe C02e PM Construction Equipment 2.53 5.67 0.01 0.20 0.20 0.68 990.71 <0.01 Construction Worker 3.99 0.39 0.01 0.06 0.04 0.43 717.22 <0.01 Commuting Material Delivery 1.40 3.87 0.01 0.19 0.16 0.33 768.53 <0.01 Ea1thmoving Activities <0.01 <0.01 <0.01 1.52 0. 15 <0.0 1 <0.01 <0.01 Road Emissions <0.01 <0.01 <0.01 0.06 0.01 <0.01 <0.01 0.52 Cement Plant <0.01 <0.01 <0.01 2.63 0.43 <0.0 1 <0.01 8.82 Other voe (Paint and

<0.01 <0.01 <0.01 <0.01 <0.01 3.41 <0.01 <0.01 Fuel)

Total 7.92 9.94 o.oz 4.66 0.99 4.85 2,476.45 9.34 Sources: CARB 2016; WRAP 2006; Section 3.2. 1; AP42 2006; Sections 7.1 , 13.2.2, and 13.2.4; TCEQ 200 1, and TCEQ 2011 .

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Table 4.6.3:

CONCURRENT OPERATION AND PHASED CONSTRUCTION EMISSIONS - POUNDS PER HOUR Source co NO, S02 PM10 PM2.s voe C02e PM Worker 0.31 0.03 <0.01 <0.01 <0.01 0.03 55.17 <0.01 Commuting Deliveries 0.77 2.12 <0.01 0.10 0.09 0.18 421.11 <0.01 Road Emissions <0.01 <0.01 <0.01 0.05 0.01 <0.01 <0.01 0.50 Ongoing 0.57 1.23 <0.01 0.59 0.12 1.39 229.97 1.36 Construction Total 1.64 3.38 <0.01 0.75 0.22 1.60 706.25 1.86 Sources: CARB 2016; WRAP 2006; Section 3.2.1 ; AP42 2006; Sections 7. 1, 13.2.2, and 13.2.4; TCEQ 2001, and TCEQ 2011 .

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Table 4.6.4:

CONCURRENT OPERATION AND PHASED CONSTRUCTION EMISSIONS - TONS PER YEAR Source co NO, S02 PM10 PM2.s voe C02e PM Worker 5.60 0.55 0.01 0.08 0.05 0.6 1 1006.86 <0.01 Commuting Deliveries 2.80 7.75 0.01 0.38 0.32 0.65 1537.06 <0.01 Road Emissions <O.Ol <0.01 <0.01 0.12 0.01 <0.01 <0.01 1.09 Ongoing 1.1 9 l.49 <0.01 0.70 0.15 0.73 371.47 1.40 Construction Total 9.59 9.79 o.oi 1.28 0.39 1.26 2,543.92 1.09 Sources: CARB 2016; WRAP 2006; Section 3.2. 1; AP42 2006; Sections 7. 1, 13.2.2, and 13.2.4; TCEQ 2001 , and TCEQ 2011 .

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ATTAC HMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Table 4.6.5:

ATTENUATED NOISE LE VELS (dBA) EXPECTED FOR OPERATION OF CONSTRUCTION EQUIPM ENT Distance from Source Source 50 feet 100 feet 150 feet 200 feet 400 feet 1 200 feet Heavy Truck 85 79 76 73 68 56 Dump Truck 84 78 75 72 67 55 Concrete Mixer 85 79 76 73 68 56 Jackhammer 85 79 76 73 68 56 Scraper 85 79 76 73 68 56 Dozer 85 79 76 73 68 56 Crane 85 79 76 73 68 56 Loader 80 74 71 68 62 50 Paver 85 79 76 73 68 56 Excavator 85 79 76 73 68 56 Claw Shovel 93 87 73 81 75 66 Pile Driver 95 89 86 83 77 6 Source: l!FP 2009; Section 4.7.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts 4.7 CULTURAL RESOURCES This section describes the potential impacts to historic properties associated with the CIS Facility construction, o perations, and decommissioning. Potential mitigation measures are presented in Chapter 6.

4.7.1 Construction (All Phases)

Direct Impacts. Direct impacts to historic properties are actions directly associated with the project that can destroy, alter, or isolate historic properties. A records search was conducted of the Archaeo logical Records Management Section (ARMS) New Mexico Cultural Resources Info rmation System (NMCRIS), maintained by the New Mexico Historic Preservation Division (NMHPD), for previously recorded cultural resources w ithin the APE of direct impacts, or the project footprint. The results of the ARMS NMCRIS records search indicated that two known cultural resources existed w ithin the direct Area of Potentia l Effects (APE). Subsequently, a cultural resource survey of the direct APE was conducted in December 2016 (see Appendix C).

The survey resulted in the identification of 17 isolates, 1 previously recorded archaeological site, 1 newly discovered archaeological site, 1 previously recorded historical-period linear resource, and 1 new ly d iscovered historical-period linear resource. A ll fou r cu ltural resources were evaluated for Natio na l Register of Historic Places (NRHP) eligibility. Of these fom cultural resources, two are historic properties that could be directly affected by this project.

Indirect Impacts. Indirect impacts to cultural resources result from activities that are not directly associated with project actions but that contribute to the modification of the environmental setting of historic properties. Examples of indirect impacts to cultural resources include visual, audible, or atmospheric effects that are out of character with the setting of historic properties (primarily considered for the built environment), vandalism that results from improved access to areas where historic properties are located (primarily considered for archaeological sites), induced growth in the region from roads and in:frastructure, or alteration of the regional landscape that affects water drainage around known and buried archaeological sites. In addition to resources located within the indirect APE, the proposed project could have the potential for unanticipated impacts to the communities from which the stored nuclear-waste items are being acquired, if the development of the project leads to additional development in those communities that would not otherwise occur.

A records search was conducted of the ARMS NMCRIS, maintained by NMHPD, for previously recorded cu ltural resources within the APE for indirect impacts, or a 1-mile radius around the project footprint. The ARMS NMCRIS records search indicated that 40 cultural resources are documented within the indirect APE (see Table 3.7.2). Of these 40 resources, 14 are e ligible for listing in the NRHP and are therefore considered historic properties. It sho uld be noted that another 19 cultural resources have an undetermined or unknown NRHP status.

The historic properties within the APE of indirect impacts are archaeo logical sites. Because most archaeological sites in this regio n are surficial, the visua l, audible, and atmospheric effects of this project do not impact those sites. Because the CIS Facility site would be fenced and not open to the public, the potential for vandalism is considered to be minimal and would not be considered an indirect impact for this ER. Construction-design strategies cou ld mitigate potential alteration of HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-216752 1 I Rev.4 4-25 194 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts t he regional landscape that could affect water drainage around known and buried archaeological sites. As an SNF storage facility, the CIS Facility would not have the potential to induce growth.

Potential for Human Remains. There is a low potential for human remains to be present within the APE of direct impacts. Previous work in the region suggests that burials tend to occur in rock shelters and w it hin archaeological sites that have architectural features. Upon the inadvertent discovery of human remains during construction, work would cease immediately in the vicinity of the human remains. Additionally, an area within 100 feet of the remains would be protected from further disturbance. The appropriate agency (New Mexico BLM Field Office or New Mexico State Historic Preservation Officer [SHPO]) would be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the unanticipated discovery of human remains. The agency would determine the appropriate measures to identify, evaluate, and treat such a discovery. If excavation of the human remains proves necessary, then excavation would be conducted pursuant to the guidelines appropriate for the land-managing agency. The agency would conduct the appropriate and necessary consultation with descendent communities and other consulting parties. Construction activities could resume only after the appropriate consultations and notifications have occurred and agency require ments have been comp leted and approved.

4.7.2 Operations (Including Concurrent Operation and Construction)

Operation of the proposed CIS Facility is not expected to result in impacts to any potentia l archaeological site; therefore, impacts of facility operations are expected to be small for cultural resources. Concmrent construction and operation would not introduce any potential for additiona l impacts to cultural resources.

4.7.3 Comparable NRC Cultural Analyses This analysis is consistent with NUREG-2157, in w hich the NRC determined that the in1pacts to cultural resources from SNF storage would be small (NRC 2014b, Section ES.16.1.12), For any construction activities, the NRC recognized that there would be uncertainty associated with the degree of prior disturbance and the resources, if any, present in areas where future ground-disturbing activities (i.e., construct ion of an ISFSI) could occur. The NRC acknowledged the possibility that cultural resources could be affected by construction activities, because the ISFSI could be located in an area with cultural resources in close proximity (NRC 2014b, Section ES.16. l.l 2).

4.7.4 Decontamination and Decommissioning D&D activities would take place on land previously distmbed and any potential to encounter cultural resources would be considerably less than during construction activities. Consequent ly, D&D impacts on cultmal resources would be small.

4.7 .5 Agency Consultation Following the pedestrian survey, the draft cultural resource inventory and evaluation report and completed resource records were sent to the New Mexico SHPO and the BLM - Carlsbad Field Officer (CFO) for the ir review and requested concurrence of eligibility recommendations (see Appendix C). Consultation would be initiated by the Federal agencies, as appropriate, during any HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-2 16752 1 I Rev.4 4-26 195 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts subsequent NEPA process. Subsequent consultation with tribes associated with the area (such as the Apache Tribe of Oklahoma, the Comanche Indian Tribe, the Hopi Tribal Council, the Kiowa Tribe of Oklahoma, the Mescalero Apache Tribe, the Pueblo of lsleta, and the Ysleta del Sur Pueblo) w ill be requ ired by the NRC or their designee. Through consultat ion w ith the aforementioned tribes, Tradit ional Cultural Prope1ties (TCPs) that could be potentially affected by the project can be identified.

4.8 SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE This section describes the potential impacts to socioeconomics and environmental justice associated with the Proposed Action. Socioeconomic impacts from construction are presented in Section 4.8.1 ; socioeconomic impacts from operations are presented in Section 4.8.2; environmental justice impacts are presented in Section 4.8.3; NRC analysis related to socioeconomics and environmental justice is presented in Section 4.8.4; and D&D impacts are presented in Section 4.8.5. Potential mitigation measures are presented in Chapter 6.

Socioeconomic impacts are not only important in themselves, but also for the secondary environmental or distributional effects they may have. For example, economic growth can sometimes attract enough new people to an area that it places pressure on housing, schools, water supply, and other infrastructure. Environmental effects of any new construction, facility improvements required, or infrastructure overloads that result from such a population increase should also be evaluated as induced effects of the development. The purpose is not to forecast economic activity but to make sure that reasonably foreseeable indirect effects are appropriately identified and considered.

4.8.1 Construction (Phase 1)

Construction of Phase 1 of the CIS Facility would begin in the first quarter of 2020 and take between 1-1.5 years to complete. Construction activities are estimated to require upwards of 80 construction personnel (50 craft, 30 oversight/management) (Holtec 2016a). The 2020 population in the region of influence (ROI) is projected to be 172,829. The add ition of 80 construction personnel would increase the population by 0.05 percent.

Construction of Phase 1 CIS Facility would include short-term economic benefits from construction activities; however, such fract ional effects would be less than significant on a regional scale. There would be less than significant permanent change in sales volume, income, employment, or population.

Economy. In terms of employment and income, it is estimated that 80 construction personnel would be needed for 1 to 1.5 years during Phase 1 construction. The 2015 labor force within the ROI was 77,433 (BLS 20 16a). The addition of 80 workers would result in a 0.1 percent increase to regional emp loyment. The mean annual salary for a construction worker in New Mexico is

$28,320 and the mean annual salary for a construction manager is $86,970 (BLS 2016b}. One year of construction activities would generate a total increase in income from direct jobs of about $4 million and approximately $409,000 in personal income tax and New Mexico Gross Receipts Tax.

In addition, construction activities could result in beneficial impacts from increased local revenue from commercial activities, and sales taxes.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Population. Based on the number of estimated jobs created for Phase 1 and the assumption that all direct and indirect jobs created would be filled by employees in the ROI labor force, no impact on population is antic ipated.

Housing. Based on the estimated number of jobs for Phase 1 and the assumption that workers in the existing labor force in the ROI would fill all direct and indirect jobs, there would be no need for additional housing. However, if there was need for temporary housing, the current housing market would be able to meet that need. Therefore, there would be no impact to housing, including sales, foreclosures, and price stability.

Community Services. Based on the number of estimated jobs created for Phase 1 and the assumption that all direct and indirect jobs would be fi lled by workers from the ROI's existing labor force, no impact to public schools, law enforcement, or firefight ing capabil ities is anticipated.

4.8.2 Concurrent Operatiion and Additional Construction (Phases 2-20)

The operation of the CIS Facility would require an estimated work force of less than 40 personnel and less than 15 security force personnel (Holtec 2016a). Construction activities during Phases 2-20 would occur as operations are occurring at any areas previously constructed. Phases 2-20 construction would take place over 20 years, but would require fewer annual construction personnel than Phase 1, as all support structures would be constructed during the Phase 1. There would be an addition of less than 80 workers during each year of construction for Phases 2-20.

When combined with the o perating workforce, t he total number ofannua l workers at the Site could be as many as 135. The 2015 labor force within the ROI was 77,433 (BLS 2016a). The addition of 135 workers would result in a 0.2 percent increase to regional employment.

The mean annual salary for engineering operations in New Mexico is $85,730 and the mean annual salary for security guards is $29,880 (BLS 2016b). One year ofoperation activities would generate a total increase in income from direct jobs of nearly $3.9 million and approximately $411 ,000 in personal income tax and New Mexico Gross Receipts Tax would be recognized . In addition, operation activities could resu lt in beneficia l impacts from increased local revenue from commercial activities, and sales taxes. When combined w ith the annual salaries associated with construction workers for Phases 2-20, one year of concurrent operation and construction would generate a total increase in income from direct jobs of about $7.9 million and approximate ly

$820,000 in persona l income tax and New Mexico Gross Receipts Tax. On a regiona l scale, concurrent operation and Phases 2-20 construction would result in a less than significant impact on population, housing, and community services.

4.8.3 Operation Operation of the CIS Facility at full build-out would not require any notable difference in the number of operating personnel compared to Phase 1 operations. Consequently, operation of the CIS Facility at fu ll build-out wou ld require an estimated work force of less than 40 personnel and less than 15 security force personnel (Holtec 2016a). The 2015 labor force w ithin the ROI was 77,433 (BLS 2016a). The addition of 55 workers would result in a 0.05 percent increase to regional employment. The mean annua l salary for engineering operations in New Mexico is $85,730 and the mean annua l salary for security guards is $29,880 (BLS 2016b). One year of operation activities would generate a total increase in income from direct jobs of nearly $3.9 million and HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-216752 1 I Rev.4 4-28 197 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts approximately $4 11 ,000 in personal income tax and New Mexico Gross Receipts Tax wou ld be recognized. In addition, operation activities could result in beneficial impacts from increased local revenue from commercial activities, and sales taxes.

The number of permanent jobs created would not result in appreciable change in population, and therefore it would not be likely to affect housing availability or community services or have long-term fiscal impacts in the region. Therefore, the socioeconomic impacts would be short-term and beneficial.

4.8.4 Environmental Justice Section 3.8.5 of this ER discusses environmental justice populations located within the counties encompassing a 50-mile radius around the Site (three counties in New Mexico and six counties in Texas). There were 35 block groups identified to contain minority populations that exceed the site-specific thresholds for minority populations. No minority populations were identified that exceeded the site-specific threshold within a 4-mile or a 25-mile radius of the Site. The closest minority populations that exceeded the site-specific threshold were located in the population centers of Artesia and Carlsbad in Eddy County and Hobbs in Lea County. There were no low-income populations identified that exceeded the site-specific threshold for low-income populations within the same ROI.

As discussed in Sections 4.9, 4.12, and 4.13, no high and adverse human health or environmental impacts are expected from the construction or operatio n of the CIS Facility. Environmental impacts from most projects tend to be highly concentrated within the project site boundaries and tend to decrease as distance from the site increases. No effects on environmental justice would be expected, and the Proposed Action wou ld not result in dispro portionate adverse environmental or health effects on low-income or minority populations.

4.8.5 Comparable NRC Socioeconomics and Environmental Justice Analysis This analysis is consistent with NUREG-2157 (NRC 2014b, Sections 4.2 and 4.3), in which N RC determined that construction and operation of an ISFSI would have minimal impacts on socioeconomic resources and environmental justice. The NRC concluded that: (1) the workforce for ISFSI construction and operations would be small; (2) tax payments would continue and would remain relatively constant; (3) there would be no increased demand for housing and public services; and (4) maintenance and monitoring ofSNF in ISFSis would have minimal human health and environmental effects on all populations, including minority and low-income populations near these storage fac ilities.

4.8.6 Decontamination and Decommissioning D&D of the CIS Faci lity wou ld consist of decontaminating and removing equ ipment from the fac ility, while leaving the building, parking area, and access roads in p lace. No reliable information could be obtained regarding labor market conditions 120 years in the future; therefore, it is not apparent how employment fro m D&D act ivities wou ld specifically impact the labor market.

However, it is antic ipated that the annual workforce for D&D activities would not exceed the number of workers needed for construction of the CIS Facility. Assuming the population within HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-216752 1 I Rev.4 4-29 198 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts t he ROI would continue to grow in t he future, it is unlikely that the introduction of a sma ll number of individuals would create appreciable impacts to the population or community services.

Closing the operation of the CIS Facility would have a minimal economic impact to the community, some of which would be offset by the D&D activities and site closure. It is anticipated that t he overall economic impacts of D&D would be minimal.

4.9 TRANSPORTATION This section presents the potential impacts of transportation activities associated with the Proposed Act ion. Both rad iological and non-radiological transportation impacts are addressed. Potential mitigation measures are presented in Chapter 6.

4.9.1 Construction (Phase 1)

Construction of Phase 1 of the CIS Facility would require a new access road from U.S. Highway 62/180 and a new railroad spur from the existing Carlsbad railroad spur that ends at the Intrepid Mining LLC No1t h fac ility 3.8 miles due west of the Site (see F igure 2.2.1). The environmental impacts of constructing the access road and railroad spur (e.g., impacts to land use, air quality, cultural, etc.) are included in the Phase 1 construction estimates and are presented in the applicable resource sections of this chapter.

Holtec plans to use trucks and common carrier to make shipments during construction. Therefore, the impacts of rail traffic are not evaluated. If rail shipments are needed for construction to bring large items to the CIS Facility, they are not expected to be a significant impact since they would be infrequent and would be managed as routine railroad traffic. Construction of Phase 1 of the CIS Facility is estimated to require up to 80 construction personnel and the delivery of equipment and supplies, most of which wou ld arrive via U.S. Highway 62/ 180. The mode of transportation for construction would consist of over-the-road h*ucks, ranging fro m heavy-duty 18-wheeled delivery trucks, and dump trucks, to box and flatbed type light-duty delivery trucks. The primary transportation mode for the workforce to and from the site will be by car, truck, or van.

U.S. Highway 62/ l 80 would provide access to the Site. Considering that U.S. Highway 62/ 180 is a divided 4-lane highway and serves as a main east-west trucking thoroughfare for local industry, it would be able to handle the increased heavy-duty traffic adequately since the traffic count is significantly less at the CIS Facility site than in the urban ends of the highway at the Hobbs and Carlsbad areas (see Section 3.9). Approximately 43 percent of vehicles in the vicinity of the proposed Site were associated with commercial trucks 4.9.2 Concurrent Operatiions and Additional Construction (Phases 2-20)

Once Phase 1 is operational, transportation impacts associated with workers would have minimal environmental impacts. In 201 5, the annual average daily traffic (AADT) on U.S. Highway 62/ 180 was approximately 5,696 vehicles per day in the vic inity of the proposed Site. Given the estimated steady-state work force of less t han 40 personnel and the estimated steady-state security force of less than 15 personnel, the additional traffic on U.S. Highway 62/ 180 and the access road would be insignificant (less than one percent).

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Concurrent operations and additional construction (Phases 2-20) would result in a maximum of 135 construction and operating personnel and the delivery of equipment and supplies, most of which would arrive via U.S. Highway 62/180. The concurrent impacts would not be significantly different than the impacts discussed in Section 4.9.1.

SNF is expected to be transported to the CIS Facility via rail. The railroad spur would cross one existing road (New Mexico State Road 243) and would contain appropriate active traffic control devices (i.e., warning lights and automatic gates serving as a barrier across the road when a train is approaching or occupying the crossing). Section 4.9.3 discusses the potential environmental impacts associated with SNF transpo1tation.

4.9.3 Operations The analysis in this section focuses on transportation of SNF, as worker transportation associated with operations are expected to be minimal, as addressed in Section 4.9.2. For SNF transportation, incident-free impacts (Section 4.9.3.1) and potential accident impacts (Section 4.9.3.2) are presented .

4.9.3.1 Incident Free Impacts Over the course of the operational life of the CIS Facility, Holtec would receive up to 100,000 MTUs of SNF in approximately l 0,000 canisters from decommissioned shutdown sites and operating reactor sites. Except for the potential use of heavy-haul trucks (or barges for certain decommissioned shutdown sites) to move SNF, this analysis assumes SNF would be transported nationally by rail.

The U.S. Department of Energy (DOE) would be responsible for transporting SNF to the CIS Facility in transportation casks licensed by the NRC pursuant to 10 Part CFR 71. The preparation of such shipments would be conducted in accordance with written procedures prepared by the commercial nuclear power p lant, DOE, or their contractors. DOE would also be responsible for coordinating with other Federal agencies, such as the U.S. Department of Transportation (DOT),

U.S. Depaitment of Homeland Security, EPA, and the Federal Emergency Management Agency (FEMA). The Federal government, through DOE, is responsible for providing emergency training to states, tribes, and local emergency responders along the transportation routes where SNF would be transported to the CIS Facility. Given its proximity to the Waste Isolation Pilot Plant (WIPP),

local fire fighters, law enforcement, and emergency medical staff have been trained to respond to any emergency response actions that may be needed to reduce the severity of events related to transpo1tation inc idents invo lving the CIS Facility.

If the option is selected for a reactor licensee to ship the fuel to HI-STORE, the licensee would use transportation casks licensed by the NRC pursuant to 10 CFR Part 71. The licensee would also coordinate shipments w ith federal agencies, such as the U.S. Department of Transpo1tation (DOT),

US Department of Homeland Security, Environmental Protection Agency (EPA), and the Federa l Emergency Management Agency (FEMA), and potentially affected states and applicable state agencies. These interactions would ensure that all necessary emergency responders along the route are properly prepared.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts The incident-free radio logical transportation ana lysis in this ER tiers from the analysis prepared for the proposed WCS CIS Facility in Andrews County, Texas (WCS 2016). The WCS CIS Facility site is approximately 39 miles from the proposed Holtec CIS Facility Site. This difference in distance fo r SNF transportation would be insignificant w ith respect to potential impacts. The most significant difference involves the amount of SNF that would be received at the Holtec CIS Facility compared to the WCS CIS Facility. The WCS CIS Facility transportation analysis was based on the receipt of 40,000 MTUs of SNF in approximately 4,000 canisters from decommiss ioned shutdown sites and o perating reactor sites, which is 2.5 times less than the Holtec proposal to receive 100,000 MTUs ofSNF in approximate ly 10,000 canisters. Consequently, this ER ana lysis accounts fo r that greater amount of SNF transpo1tation for the Holtec CIS Facility.

Background. Radio logical impacts oftranspo1ting SNF were estimated using RADTRAN, which is a computer model developed by Sandia National Laboratories for the NRC to calculate the radiological impacts of transporting radiological materials (NRC 2014a). RADTRAN, which was initially used fo r NUREG-0 170 (NRC 1977), models both the risks of routine, inc ident-free transportation and transpottation acc ide nts. Since publication of NUREG-0170, RADTRAN has been periodically updated and is widely used to estimate the risk of radiological material transportation for environmental impact statements and risk assessments published by NRC, DOE, and other U.S. Federal and state agencies.

RADTRAN assumes the maximum dose rate allowed for exclusive use shipments under NRC regu lations (10 CFR 71.47 (b) (3)) and estimates the potential impacts to the populatio ns located within one-half mile along e ither side of the transportation routes. WebTRAGIS was used to determine the route length and population density ( e.g., rural, suburban, and urban) for each route segment. Using the maximum dose rate (10 rnrem/hour at a distance of 6.5 feet from the cask) assures that the doses calculated by RADTRAN bound those of the proposed SNF shipments to and from the CIS Facility.

Transportation Routes. The analysis assumed SNF would be along three representative routes:

(1) from the east coast to the CIS Facility (assumed to be from Maine Yankee Nuclear Power Plant to the CIS Facility); (2) from the west coast to the CIS Facility (assumed to be from the San Onofre N uclear Generating Station [SONGS] to the CIS Facility; and (3) from the CIS Facility to the assumed repository at Yucca Mountain in Nye County, Nevada (see Figure 4.9.1).

The ana lysis also analyzed the transportation routes needed to remove and transport SNF from the decommissioned shutdown sites at twelve locations across the U.S. to the CIS Facility. At these sites, SNF would require to be transported short distances by heavy haul trucks or barge to a rail transfer facil ity where the SNF could be subsequently transported to the CIS Facility. The mode of transport of SNF from the twe lve decommiss ioned shutdown sites were obtained from "Preliminary Evaluation of Re moving Used Nuclear Fue l from Shutdown Sites" (DOE 2014).

Impacts. Radiological dose calcu lations were performed along each of the three transpottation routes for a single shipment of SNF by rail. Holtec estimated that approximately 10,000 canisters ofSNF would be transported to the CIS Facility over the next 20 years, an average of 500 canisters received annua lly. The max imum dose for one shipment of SNF along the transportation routes was estimated at 1.79 x 10-3 rnrem. For perspective, the average radiation dose from background HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-2167521 I Rev.4 4-32 201 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts radiation is estimated at 3 11 mrem per year as reported by the National Counc il of Radiation Protection and Measurements ( see Table 3 .1 1.1 ).

The radiological impacts of transporting 500 canisters of SNF annually from the Maine Yankee Nuclear Power Plant to the CIS Facility were estimated to be 92.5 person-rem. From SONGS to the CIS Facility, the radiological impacts of transporting 500 canisters of SNF annually was estimated to be 22.3 person-rem. The impacts of transpo1ting 500 canisters from the CIS Facility to a geologic repository at Yucca Mountain were estimated at 57.5 person-rem.

An additional radio logical dose could result from the need to transpo1t SNF short distances from the twe lve decommissioned shutdown sites by heavy ha ul truck or barge. The effects of these additional doses would be small (generally less than I person-rem) when added to the doses estimated for shipment on the three analyzed rail routes. In addition, the NRC previously analyzed the environmenta l impacts associated with using heavy-haul trucks and barges to transport SNF from reactors to a rail transfer fac ility to an interim storage facil ity in NUREG-17 14 (NRC 200 I).

In that study, the NRC concluded that the impacts of rail transport from the representative route conservatively characterize the nationwide incident-free transportation risks of that proposed action, including potentia l intermoda l transfers (NRC 2001, Section 5.7.2.6). That conclusion remains valid for the proposed action evaluated in this ER. Similarly, in the event that spur is not constructed, Holtec would transport the SNF the final 3.8 miles by heavy haul truck. The impacts of transporting SNF short distances by heavy haul truck would be small (generally less than 1 person-rem) when added to t he doses estimated for shipme nt on the three analyzed rail routes.

Results of the incident-free analysis of transporting 500 canisters of SNF annually are presented in Table 4.9.1. As shown, the annual doses to the public a long the transportation route would be much small.

With respect to potential impacts to transportation workers, a prior study by DOE for the transport of up to 70,000 metric tons of SNF to the Yucca Mountain repos itory from nuclear power plants across the U.S. determined that annual doses to workers would be maintained at less than 500 mrem/year (which is considered an administrative dose limit) (DOE 2008, Table 2-3).

Transpo1tation impacts of SNF to the CIS Facil ity wou ld not exceed this est imate.

As discussed in Section 4.11 of this ER, the operation of the CIS Facility cou ld generate a small amount of LLW that would result in infrequent waste shipments to a licensed disposal facility. The small and infrequent number of shipments and compliance with NRC and the DOT packaging and transportation regu lations would also limit potential worker and public rad iological and non-rad io logical impacts from these waste shipments. This conclusion is consistent w ith t he NRC's conclusion that public and worker radiological and non-radiological safety from LLW shipments resulting from SNF storage activities would be small (NRC 2014b, Section 4.16).

With the exception of occupational and public health and safety impacts evaluated in this section, because shipments of SNF would comprise only small fractions of total national highway and rai l traffic, t he environmental impacts of the shipments on land use and ownership; hydro logy; bio logical resources and soils; cultural resources; socioeconomics; climate change; noise and vibration; aesthetics; utilities, energy, and materials; and waste management would be small in comparison with the impacts. of other nationwide transpo1tation activities.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts 4.9.3.2 Accident Impacts The radiological transportation impacts that could potentially occur during accidents were also analyzed. Type B transportation casks licensed in accordance with 10 CFR Part 71 are constructed to withstand severe accidents so that most transport accidents would not result in damage to the cask body or seals that could result in a radiological re lease.

The analysis ofrad io logical risks of accidents considered a spectrum of accidents that ra nged from high-probabil ity accidents of low severity and consequences to severe accidents with radiological consequences that have a low probability of occurrence. They included accidents in which the functional performance of a cask would not be degraded, accidents in which no radiological material wou ld be released but shie lding would be deformed because of lead shield disp lacement, and accidents that released radiological material. Radiological accident risks are defined as the sum over a complete spectrum of transportation accidents of each accident's probability multiplied by its radiological consequences.

Table 4.9.2 presents the radiological and non-radiological accident risks of rail transport of approximately 100,000 metric tons of SNF over a 20-year period, tiered from the analysis in DOE 2008. The data in Table 4.9.2 provide a reasonable approximation of the accidents risks associated w ith SNF transportation to the CIS Fac il ity. As shown, the radiolog ical accident risks to the population would be approximately 5.9 person-rem, which is small. The larger impact would be associated with potential traffic fatalities. Statistically, 2.9 fatalities from traffic accidents would be expected over the 20-year transportation period. Because the risks are for the entire popu lation of individuals along the transportation routes, the risk to any single individual would be small.

About 99.99 percent of transportation accidents would not be severe enough to result in a re lease of radio logical materia l from t he transportation cask or dlegradation in the cask's shielding. The 0.0 l percent of accidents that could result in a release of radiological material or degradation of shie lding are known as severe transportation accidents (DOE 2008, Section 6.3.3.2).

Table 4.9.3 presents the impacts of the maximum reasonably foreseeable accident associated w ith SNF transport to the CIS Facility. If the accident occurred in an urban area, the estimated population radiation dose would be about 16,000 person-rem. If the accident occurred in a rural area, the estimated population radiation dose would be about 2 1 person-rem. Because these risks are for the entire population exposed during the accident, t he risk to any single individual would be small. In an urban area or rural area, the radiation dose from the accident for the maximally exposed individual would be 34 rem; this is based on the individual being 1,100 feet downwind from the accident, where the maximum dose would occur (DOE 2008, Section 6.3.3.2).

4.9.4 Comparable NRC Transportation Analyses The radiological impacts of transporting SNF have been extensive ly studied for nearly 40 years.

Several transportation risk studies have been published by NRC during that time, including:

  • Spent Nuc lear Fuel Risk Transportation, NUREG-2125 (NRC 2014a);
  • Generic Environmental Impact Statement of Continued Storage of Spent Nuc lear Fuel, NUREG-2157 (NRC 2014b).

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts

  • Fina l Environmental Statement on the Transportation of Radioactive Material by Air and Other Modes, NUREG-0170 (NRC 1977).

All of NRC's assessments have concluded that the risk from radiation emitted from a transportation cask during routine, incident-free transportation is a small fraction of the radiation dose received from t he natural background.

In the most recent of these analyses (NUREG-2125), the NRC also concluded that:

The co llective dose risks from routine transportation are very small. These doses are approximately four to five orders of magnitude less than the collective background radiation dose.

2 The routes selected for this study adequately represent the routes for SNF transport, and there was relative ly little variation in the risks per m ile over these routes.

3 Radioactive material would not be released in an accident if the fuel is contained in an inner welded canister inside the cask.

4 Only rail casks w it hout inner welded canisters would release radioactive material, and only then in exceptionally severe accidents.

5 lfthere were an accident during a spent fuel shipment, there is only about one-in-a billion chance that the accident would result in a re lease of radioactive material.

6 If there were a release of radioactive material in a spent fuel shipment accident, the dose to the MEI would be less than 200 rem and would not be expected to result in an acute lethality.

7 The collective dose risks for the two types of extremely severe accidents (accidents involving a release of radioactive material and loss of lead shielding [LOS] accidents) are negligible compared to the risk from a no-release, no-loss of shielding accident.

8 The risk of gamma shielding loss from a fire is negligible.

9 None of the fire accidents investigated in this study resulted in a release of radioactive material (NRC 2014a, Executive Summary).

The NRC has a lso analyzed the radiological impacts from transporting SNF in several EIS's supporting other licensing actions and found the radiological impacts to be small. In licensing the Private Fuel Storage SNF Storage facility, the NRC analyzed the radiological impacts associated w ith transporting 40,000 MTUs of SNF from Maine Yankee to Goshute Indian Reservation near Salt Lake City, Utah and found the radiological impacts to be small (NRC 2001, Section 5. 1.2).

In addition, in NUREG-2157, t he NRC concluded that the radiological impacts from SNF transportation conducted in compliance with NRC regulations are low, and that the regulations for transportation of radiological material are adequate to protect the public against unreasonable risk of exposure to radiation fro m SNF packages in t ransport (NRC 2014b, Section 4.16).

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts In assessing the Yucca Mountain repository, DOE also evaluated the national impacts of transporting SNF from commercial reactors across the U.S. to the repository. DOE determined that transporting up to 70,000 metric tons of SNF would result in a total dose of 1, 100-1,200 person-rem to the population along the transportation routes (DOE 2008, Table 6-4). Those results coffelate well with the results presented Table 4.9. l of this ER, when the results in that table (which represent the impacts of transporting 500 canisters) are integrated to account for a similar overall quantity of SNF transpott 4.9.5 Decontamination and Decommissioning Prior to D&D activities, all canisters of SNF would be removed and transported to a permanent repository. For purposes of this ER, it is assumed that the repos itory would be at Yucca Mountain in Nye County, Nevada. The impacts associated with transporting the SNF from the CIS Facility to Yucca Mountain are presented in Table 4.9.1. Those impacts represent the annual impacts of transpot1ing 500 canisters. The impacts of transporting the fu ll inventory of the CIS Facility (10,000 canisters) would be 20 times the impacts presented in Table 4.9 .1.

Following the removal of the canisters containing SNF, the empty storage system would be surveyed to determine their levels ofresidual radioactivity. If the contamination levels were fo und to be below the applicable NRC limits for unrestricted release, then the empty storage casks would be disposed of as non-controlled material. Any contaminated storage casks would be decontaminated to levels below applicable NRC limits for unrestricted use. The fate of these items would be identified as part of the Final Decommissioning Plan.

While some radiological wastes would be generated during D&D that would require transport to an off-site licensed d isposal faci lity, the NRC has previously determined that these wastes wou ld be small and wou ld have a sma ll impact (NRC 2014b, Section 4. 15). Consequently, the transpo11ation impacts of these wastes are expected to be small.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Table 4.9.1:

ANNUAL INCIDENT-FREE TRANSPORTATION IMPACTS" Transportation Route Dose to Public (person-rem/year)

Maine Yankee uclear Power Plant to CIS Facility 92.5 so GS to CIS Facility 22 .3 CIS Facility to Yucca Mountain 57.5 a Based on trans port of 500 cani ters of SNF.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Table 4.9.2:

ACCIDENT RISKS FOR TRANSPORTATION OF 10,000 CANISTERS TO CIS Facility Radiological Accident Dose Risk Traffic Fatalities Total Fatalities (person-rem)

Rail Transport 5.9 2.9 2.9 Source: derived from DOE 2008.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 HI-STORE CIS Facility Environmental Report Chapter 4: Environmental Impacts Table 4.9.3:

RADIOLOGICAL IMPACTS FROM THE MAXIMUM REASONABLY FORESEEABLE TRANSPORTATION ACCIDENT IN URBAN AND RURAL AREAS" Impact Urban Areab Rural Areab Population dose (person-rem) 16,000 21 Maximally exposed individual (MEI) dose (rem) 34 34 Maximally exposed first responder dose (rem) 0.14-2.0 0.14-2.0 a Analysis assumes the maximum reasonably foreseeable accident occurs (e.g., probabilities that accident wou ld occur is l).

b Urban areas have a population density greater than 3,326 people per square mil e. Rural areas have a population density less than 139 people per square mile.

Source: DOE 2008.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 4: Environmental Impacts Maine Yankee to CISF Transportation Routes CISF lo Yucca Mountain San Onofre to C ISF Figure 4.9.1: TRANSPORTATION ROUTES FOR SNF HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL HI-2 167521 I Rev.4 4-40 209 of 558

ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 4 : Environmental Impacts 4.10 INFRASTRUCTURE This section describes the potential impact from the Proposed Action on infrastructure (water and e lectric ity) assoc iated wit h construction and operation of t he CIS Faci lity. Construction impacts for Phase 1 are presented in Sectio n 4.10.1; concurrent impacts from o perations and construction of Phases 2-20 are presented in Section 4.10.2; full facility operations are presented in Section 4.10.3; comparable NRC analyses related to infrastructure are discussed in Section 4.10.4; and D&D impacts for the CIS Faci lity are presented in Section 4.10. 5. The CIS Facility would be designed to minimize the use of natural resources, including water and electricity. Chapter 6 describes mitigation measures that would minimize infrastructure impacts during construction and operation of the CIS Facility.

4.10.1 Construction (Phase I)

During Phase l construction of the CIS Facility all supporting fac ilities (e.g., Cask Transfer Building, Security Building, and Administrative Building) and supporting infrastructure (e.g.,

railroad spur and Site access road) would be constructed. Phase 1 would contain space for 500 can isters of SNF in a vertical underground configuration.

Peak potable water requirements for the CIS Facility would be 20 gallons/minute during any construction or operation scenarios. Potable water would be provided by the City of Hobbs Water Department (Holtec 2016a). The City of Hobbs has municipa l well fields that withdraw potable water from the Ogallala Aqu ifer (IIFP 2009, Section 2.4.15). Because there is an existing potable water supply pipe already in-place at the Site, no notable construction would be required to provide water to the CIS Faci lity. There would be minimal impacts to water resources on the Site as a result of the small demand of potable water during Phase 1 construction.

Average electrical demand for the CIS Facility would be approximately 200 kW-hours during any construction o r operation scenarios (Ho ltec 2016a). There is existing electrical service along the southern border of the Site and no notable construction would be required to provide power to the CIS Facility. E lectrical demand for the CIS Facility during both construction and operation is expected to be sma ll and the existing electrica l distribution system would be expected to support the energy demands w ith minima l impacts.

4.10.2 Concurrent Operatiion and Additional Construction (Phases 2-20)

The construction process for Phases 2-20 would occur as operations are occurring at any areas previously constructed. Holtec would have procedures in place to ensure that the construction activities of Phases 2-20 do not adversely affect o peratio ns. The existing potable water system would be expected to support the demands of all support buildings, along w ith the concrete batch plant that would be utilized during construction. The construction process fo r additional phases would be the same as that for Phase l CIS Facility. There wou ld be slightly hig her demand for potable water during concurrent operations and construction of Phases 2-20 compared to Phase l construction, but the overall demand would not exceed 20 gallons/minute. There would be min imal impacts to water resources on the Site and in the vicinity as a result of the small demand of potable water during concurrent operation and construction of Phases 2-20.

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ATTACHMENT 5 TO HOLTEC LETTER 5025040 Holtec CIS Facility Environmental Report Chapter 4 : Environmental Impacts The construction process for additiona l phases wo uld be the same as that for Phase I CIS Facility.

There would be slightly more demand for electricity during Phases 2-20 construction than Phase 1 construction, but the average electrical demand would not exceed 200 kW-hours. Power usage would be minimized by efficient design of lig hting systems, selection of high-efficiency motors, use ofappropriate building insulation materials, and other good engineering practices. The existing electrical distribution system would be expected to support the standard energy demands of all suppot1 faci lities, along with the security fencing and lighting and temperature monitoring system.

It is expected that the energy provider, wou ld be Xce l E nergy, w hich currently provides service in the area. Due to the necessity to maintain power to security and alarm systems at all times, the CIS Facility would inc lude backup diesel generators.

4.10.3 Operation Potable water and electricity demands would not exceed the values presented in Section 4.10.1 and no significant impacts are expected to support operation of the CIS Facility once fu lly operational.

4.10.4 Comparable NRC Infrastructure Analysis This analysis is consistent with NUREG-2157 (NRC 2014b, Section 4.8), in which NRC determined that water demands for SNF storage would be minimal and not cause water-use conflicts. In addition, limited electrical power would be needed.

4.10.5 Decontamination and Decommissioning D&D activities are similar in nature to the construction activities, however, the D&D activities would be expected to be completed within a few years compared to the phased CIS Facility constmction over 20 years. Because D&D activities would not require significant quantities of water or electricity compared to construction, infrastructure impacts would be minimal.

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