ML23041A236

From kanterella
Jump to navigation Jump to search
Enclosure a: Supplemental Environmental Report for the Amendment of Special Nuclear Material License No. SNM-124
ML23041A236
Person / Time
Site: Erwin
Issue date: 01/31/2023
From:
BWXT Nuclear Fuel Services
To:
Office of Nuclear Material Safety and Safeguards
References
21G-23-0005, GOV-01-55-04, ACF-23-0015, ENV-04-03 21T-23-0212, Rev 1
Download: ML23041A236 (1)
v • d • e


Text

21 G-23-0005 GOV-01-55-04 ACF-23-0015 Enclosure A Supplemental Environmental Report (77 pages to follow)

21T-23-0212 LIC-01-02 GOV-01-55-04 ENV-04-03 Nuclear Fuel Services, Inc.

SUPPLEMENTAL ENVIRONMENTAL REPORT FOR THE AMENDMENT OF SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-124 Revision 1 Prepared for:

  • United States Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Division of Fuel Safety and*Safeguards Fuel Cycle Licensing Branch Prepared by:

BWXT Nuclear Fuel Services, Inc.

1205 Banner Hill Road Erwin, TN 37650-9718 November 2021 Revised: January 2023 UNCLASSIFIED*

~,,4£~

Reviewed By 1/3,ojiJ Date

21T-23-0212 Revision 1 Table of Contents Page List of Tables V List of Figures vii List of Abbreviations viii 1.0 Introduction 1 1.1 PURPOSE AND NEED FOR THE PROPOSED ACTION 1 1.2 PROPOSED ACTION 2 2.0 Alternatives 5 2.1 DETAILED DESCRIPTION OF THE ALTERNATIVES 5 2.1.1 No-Action Alternative 5 2.1.2 Proposed Action 5 2.1.3 Reasonable Alternatives 10 3.0 Description of the Affected Environment 16 3.1 LAND USE 16 3.1.1 Adjacent Areas 16 3.2 TRANSPORTATION 17 3.3 GEOLOGY AND SOILS 17 3.3.1 Physiography and Geography 17 3.3.2 Foundation Geol.ogy 17 3.3.3 Mineral Resources 17 3.3.4 Seismicity 18 3.4 WATER RESOURCES 18 3.4.1 Surface Water 18 3.4.2 Groundwater 21 3.5 ECOLOGICAL RESOURCES 23 3.5.1 Terrestrial Biota. 23 3.5.2 Aquatic Biota 24 3.5.3 Threatened and Endangered Species 24 3.6 METEOROLOGY, CLIMATOLOGY, AND AIR QUALITY 25 3.61 Meteorology 25 3.62 Climatology 26 3.63 Air Quality 26 3.7 NOISE 26 3.8 26 3.9 27 3.10 28 ii

21T-23-0212 Revision 1 Table of Contents Page 3.11 PUBLIC AND OCCUPATIONAL HEALTH 30 3.11.1 Background Radiation Exposures 30 3.11.2 Background Radioactivity 30 3.12 WASTE MANAGEMENT 31 3.12.1 Liquid Waste 31 3.12.2 Solid Waste 31 3.12.3 Hazardous and Mixed Waste 31 4.0 Environmental Impact of Proposed Action and Alternative 32 4.1 LAND USE IMPACTS 32 4.2 TRANSPORTATION IMPACTS 32 4.3 GEOLOGY AND SOIL IMPACTS 32 4.4 WATER RESOURCES IMPACTS 33 4.5 ECOLOGICAL RESOURCES IMPACTS 35 4.6 AIR QUALITY IMPACTS 35 4.7 NOISE IMPACTS 37 4.8 HISTORIC AND CULTURAL IMPACTS 38 4.9 VISUAL/SCENIC RESOURCES IMPACTS 38 4.10 SOCIOECONOMIC IMPACTS 39 4.11 ENVIRONMENTAL JUSTICE 41 4.11.1 Local Minority and Low-Income Population Information 41 4.11.2 Evaluation of Disproportional Impacts 41 4.12 PUBLIC AND OCCUPATIONAL HEALTH IMPACTS 42 4.12.1 Non-radiological Impacts 42 4.12.2 Radiological Impacts 43 4.13 WASTE MANAGEMENT so 4.14 CONSTRUCTION 51 4.15 CUMULATIVE ENVIRONMENTAL IMPACT 52 5.0 Mitigation Measures 54 6.0 Environmental Measurements and Monitoring Programs 55 6.1 RADIOLOGICAL MONITORING 55 6.2 PHYSIOCHEMICAL MONITORING 55 6.2.1 Air 55 6.2.2 Surface Water 56 6.23 Soil and Vegetation 58 6.2.4 Groundwater 58 6.3 ECOLOGICAL MONITORING 59 iii

21T-23-0212 Revision 1 Table of Contents Page 7.0 Summary of Environmental Consequences 62 7.1 ADVERSE IMPACTS 62 7.2 BENEFICIAL IMPACTS 64 8.0 List of References 65 iv

21T-23-0212 Revision 1 List of Tables Table No. Title 1A SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" TABLE 1B SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" TABLE 1C SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" TABLE 1D SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" TABLE 1E SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" TABLE 1F SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" TABLE 2 Environmental Releases which Triggered an Outside Notification 3 NFS Erwin Facility Land Use 4 Land Use within a 1-Mile Radius of the NFS Erwin Facility 5 NFS Permitted Outfalls 6 Non-Radiological Surface Water Quality 7 Ambient Non-Radiological Groundwater Quality 8 TN Water Well Desktop Application and DOWR Search within 1 Mile of NFS Erwin Facility 9 TN Water Well Desktop Application and DOWR Search within 3 Miles of NFS Erwin Facility 10 Federal and State Listed Threatened and Endangered Species 11 Johnson City MSA Employment Statistics 12 2021 ROI Economic Data V

21T-23-0212 Revision 1 13 NFS Employee Distribution by Residence 14 Population Distribution and Percent Employment by NFS in Region of Interest 15 Selected Demographic Characteristics for the NFS ROI 16 Background Sources of Radiation Exposure 17 Alpha Background Radiation and Alpha Radioactivity in Vicinity of the NFS Erwin Facility 18 Gaseous Emissions 19 NFS Annual Employment 20 ROI Unemployment Rate 21 2017-2021 ROI Per Capita Income (in 2021 dollars) 22 Permitted and Actual Emissions of Criteria and Hazardous Air Pollutants 23A 2009-2020 Environmental Air Average Gross Radioactivity 23B Stream Sediment Average Radioactivity 2009-2020 23C Soil Average Radioactivity 2009-2020 23D Vegetation Average Radioactivity 2009-2020 23E Martin Creek Downstream -Average Radioactivity 2009-2020 23F 2009-2020 Nolichucky River Downstream Environmental Monitoring Data 24 Radiation Exposure to Members of the Public 25 Gaseous Effluents from the Proposed Action 26 NP DES Outfall Monitoring Data 27 NFS 2009-2020 Storm Water Data vi

21T-23-0212 Revision 1 List of Figures Figure No. Title 1 NFS Erwin Facility Location 2 SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" FIGURE 3 Liquid Effluent Discharge Points 4 Former Waste Disposal & Storage Area 5 Radiological Surface Water Quality 6 2009-2020 Average Off-site Radiological Ambient Air Quality 7 Environmental Air Sample Locations 8 Surface Water Sample Locations vii

21T-23-0212 Revision 1 List of Abbreviations Abbreviation Definition 1,2-DCE 1,2-dichloroethylene ADU Ammonium Diurinate AHF Anhydrous Hydrogen Fluoride ALARA As Low as is Reasonably Achievable ALOHA Area Locations of Hazardous Atmospheres AOC Area of Concern APL Advanced Pilot Line ASCE American Society of Civil Engineers ASHRAE American Society of Heating, Refrigeration and Air-Conditioning Engineers BFE Base Flood Elevation BLEU Blended Low Enriched Uranium BMPs Best Management Practices BPF BLEU Preparation Facility Ca(OH)2 Calcium Hydroxide CEDE Committed Effective Dose Equivalent coc Contaminant of Concern CSX Chessie Seaboard Multiplier (Railroad Transportation Co.)

DOE United States Department of Energy DOWR Division of Water Resources EA Environmental Assessment EPA Environmental Protection Agency EPOTW Erwin Publicly Owned Treatment Works Facility NFS Erwin Facility FAP Facility Action Plan FEMA Federal Emergency Management Agency ft 3/s Cubic feet per second HEPA High Efficiency Particulate Air HEU High Enriched Uranium HF Hydrogen Fluoride HSWA Hazardous and Solid Waste Amendments HVAC Heating, Ventilation, and Air Conditioning kg kilogram lb pound MCL Maximum Contaminant Level MEI Maximally Exposed Individual mg milligram mph miles per hour NMQS National Ambient Air Quality Standards NFS Nuclear Fuel Services, Inc.

NMSS Nuclear Material Safety and Safeguards NNSA National Nuclear Security Agency NOAA National Oceanic and Atmospheric Administration viii

21T-23-0212 Revision 1 Abbreviation Definition NPDES National Pollutant Discharge Elimination System NRC Nuclear Regulatory Commission NRHP National Register of Historic Places PCE Tetrachloroethylene pCi/1 picocuries per liter of air ppm parts per million rem roentgen equivalent man RAI Request for Additional Information ROI Region of Interest SNM Special Nuclear Materials SWMU Solid Waste Management Unit Tc-99 Technetium TCE Trichloroethylene TDEC Tennessee Department of Environment and Conservation TDOT Tennessee Department of Transportation TEDE Total Effective Dose Equivalent u Uranium uCi/ml Microcurie per milliliter UFG Uranium Hexafluoride UNH Uranyl Nitrate Hexahydrate USGS United States Geologic Survey VAGAS Versatile Automated Gamma Assay System VCI Vinyl Chloride WWTF Wastewater Treatment Facility ix

21T-23-0212 Revision 1 1.0 Introduction This Supplemental Environmental Report provides environmental information on Nuclear Fuel Services, Inc. (NFS) facility in Erwin, TN ("NFS Erwin. Facility" or "Facility") to supplement the Special Nuclear Materials (SNM) license amendment request for NFS' Uranium Purification and Conversion Services.

NFS' Supplemental Environmental Report was prepared in accordance with NUREG 1748, Environmental Review Guidance for Licensing Actions Associated with the Office of Nuclear Material Safety and Safeguards (NMSS) Programs.

The contents of this Supplemental Environmental Report address the impacts to human health and the environment required to construct and operate the Uranium Purification and Conversion Services process, and update information last provided by NFS in its 2009 Environmental Report for the Renewal of Special Nuclear Material License No. SNM-124 (May 2009).

  • The following changes have been made to the Facility since 2009:
  • Built new security wall around the perimeter of the main NFS site (started in 2007 and completed in 2012);
  • Modernized the ammonia stripping tower (2012);
  • Replaced exit/entry access control point (2012);
  • Redesigned and installed the main stack (2014);
  • Replaced the fan house (2014);
  • Decommissioned the Blended Low Enriched Uranium (BLEU) Complex (2018);
  • Decommissioned the northern burial ground area and surface water impoundments (2018);
  • Relocated and replaced the meteorological tower (2020);
  • Added a new office building (2020); and,
  • Relocated and modernized the Versatile Automated Gamma Assay System (VAGAS) (2021).

1.1 PURPOSE AND NEED FOR THE PROPOSED ACTION The Proposed Action is the amendment of NFS SNM-124 license to include the Uranium Purification and Conversion Services process.

Legacy uranium processing equipment at the National Nuclear Security Agency's (NNSA) Y-12 plant in Oak Ridge, Tennessee is tentatively planned for shutdown in the 2023 timeframe. Based upon available information, NNSA plans to partially replace this legacy uranium processing system capability with new electrorefining technology to purify high-enriched uranium (HEU) metal. However, this new process will not be available until 2023 at the earliest and will not be capable of converting oxides to metal until completion of a separate future project. Therefore, to maintain the ability to convert oxides to metal, NNSA requires separate HEU purification and conversion capability. To provide both this oxide conversion capability and to hedge against the technology risk associated with the new electrorefining facility, NNSA contracted with NFS to design, license, and demonstrate the capability to perform uranium purification and conversion to uranium metal at the NFS Erwin Facility which is an NRC licensed Category 1 HEU manufacturing facility.

1

21T-23-0212 Revision 1 The SNM-124 license allows the operation of the NFS Erwin Facility. The primary licensed activity is the production of nuclear fuel for the United States Navy. NFS is the only facility that produces naval nuclear fuel in the United States. This license also provides the following services for the United States Government:

  • Chemical processing of high enriched uranium material to produce material for fuel fabrication and uranium recovery;
  • Uranium recovery, conversion, and purification for the U.S. Department of Energy (DOE); and,
  • Reduction of weapons-grade nuclear material into commercial-grade nuclear material for power production.

1.2 PROPOSED ACTION The Proposed Action advocated by this Supplemental Environmental Report is the amendment of the NFS SNM-124 license to include specific new processes associated with Uranium Purification and Conversion Services process. This action would include the receipt, possession, processing, storage, and shipment of authorized special nuclear materials. NFS proposes to construct a new Utilities Building (Building 389) located within the protected area of the site just west of the main processing building and utilize existing facilities which will be decommissioned and renovated.

The new Utilities Building, Building 389, is a combination of masonry and steel construction. It is approximately 3,000 square feet and contains support equipment for main process operations such as a scrubber, solution storage tanks (e.g., wastewater, bulk chemical supply), electrical room, AHF supply room and office areas. Solution storage is contained within a diked containment area. The new Utility Building is adja_c~nt to the west side of the current processing area in the southwest corner of the plant site.

The main material processing area is contained within an existing building (Building 301) inside a Material Access Area that is in its final phase of decontamination and decommissioning, including the removal of processing equipment that is no longer needed, and will be an empty structure prior to the start of construction for the Proposed Action. This portion of the Material Access Area has previously been used for HEU process operations associated with the Commercial Development Line. The main processing area occupies approximately 9,000 square feet of the existing structure and is physically separated from other process operations unrelated to the Proposed Action.

The proposed decommissioning activities would follow the standard safe shutdown approach to place all systems in a purged layup. The systems would then be disconnected from existing site facilities to put the systems (i.e., equipment) in a "cold and dark" condition to facilitate safe removal and disposal. Plans would be to use the Facility for other processes until such time the site is decommissioned.

The Proposed Action would continue for as long as the service is contracted. This timeline has not been specifically defined; however, discussions have indicated a long-term contract. The closest parallel is the down blending operations which has been safely performed by NFS for over 20 years (a routinely renewed contract). The Proposed Action is anticipated to be included in the scope of the next licensing renewal.

2

21T-23-0212 Revision 1 The NFS Erwin Facility is located in the Town of Erwin, Unicoi County in northeast Tennessee. The NFS Erwin Facility occupies approximately 82 acres of land on Carolina Avenue. Carolina Avenue bounds the Facility on the southeastern side, with the Chessie Seaboard Multiplier (CSX) Railroad line on the northwest side, and Martin Creek bounding the northeastern side of the Facility (see Figure 1, NFS Erwin Facility Location and Figure 2, NFS Erwin Facility and Vicinity).

The NFS SNM-124 license amendment application was submitted to the Nuclear Regulatory Commission (NRC) on November 18, 2021. This Supplemental Environmental Report includes NFS's responses to the NRC's Request for Additional Information (RAI) dated April 28, 2022.

Figure 1. NFS Erwin Facility Location 3

21T-23-0212 Revision 1 Figure 2.

SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" FIGURE 4

21T-23-0212 Revision 1 2.0 Alternatives 2.1 DETAILED DESCRIPTION OF THE ALTERNATIVES 2.1.1 No-Action Alternative Failure of the NRC to approve the license amendment request could deprive the NNSA of strategically important nuclear material, and if not conducted by NFS would have to be conducted by another NRC licensed/ DOE Operated facility. The operation of the NFS Facility has produced no significant adverse effects on the local environment. Conduct of this work at another licensed facility would have no net positive effect on the environment but could increase unemployment in the Erwin, Tennessee area and increase the cost to the United States Government for Naval fuel material fabrication.

2.1.2 Proposed Action The proposed action is to amend NFS' SNM-124 license to conduct Uranium Purification and Conversion Services. This action would include the receipt, possession, processing, storage, and shipment of authorized special nuclear materials. Current operations at NFS are described below, which are inclusive of those that are associated with this amendment request:

Description of Current Operations

1. Product Processing: Product processing activities which have been carried out during the current license period and which are expected to continue under the current license, and similar activities which could occur during the amended license, are described below:
  • Fuel Manufacturing - Production of naval fuel containing highly enriched uranium;
  • Uranium Recovery- Recovery and purification of highly enriched uranium from scrap generated either internally or at other facilities, or from surplus or legacy strategic nuclear materials; and
  • Enrichment Blending as liquid uranyl nitrate hexahydrate (UNH)- Enrichment blending of highly enriched uranium with natural uranium or very low enriched uranium to produce low-enriched uranium materials.
2. Laboratory Operations: Laboratory activities include wet chemical and physical testing.
3. General Services: The following general services, ancillary to primary operations occur:
  • Storage of special nuclear material compounds and mixtures in areas with containers arranged specifically for maintenance of radiological and nuclear safety;
  • Decontamination of equipment and materials, including personnel protective clothing and respiratory devices.
4. Research and Development: Research and development work is performed on source and special nuclear material compounds and mixtures.

5

21T-23-0212 Revision 1

5. Radioactive Waste Management: The following radioactive waste management activities occur:
  • Treating basic and acidic waste streams at the National Pollutant Discharge Elimination System (NP DES) permitted wastewater treatment facility (WWTF);
  • Decontamination of liquid waste streams and of process equipment;
  • Packaging and storage of both liquid and solid wastes contaminated with or containing non-recoverable uranium;
  • Shipment of radioactive wastes to licensed facilities or to licensed burial sites for disposal;
  • Volume reduction by compaction, distillation, reuse, and/or evaporation of waste materials containing enriched uranium; and,
  • Solidification.
6. Decommissioning: NFS has been actively engaged in decommissioning portions of the NFS Erwin Facility since the mid-1980s. A number of processing buildings and former waste disposal and storage areas have been either fully or partially decommissioned. The current focus is on legacy building decommissioning.

The impact of decommissioning activities was evaluated and documented in the NRC's 2011 Environmental Assessment (EA) supporting the 1996 renewal of the SNM-124 license.

Decommissioning activities are ongoing and have been previously evaluated by the NRC.

Waste Confinement and Effluent Control

1. Gaseous Effluents: Various control devices are used to remove radioactive particulates and chemicals from gaseous effluents. The primary systems are described below:
  • Main Process Cleaning System - The Facility's main process ventilation system combines air effluents from the primary highly enriched uranium processing areas. This combined effluent is cleaned by venturi and demisting scrubbers and high efficiency particulate air (HEPA) filtration.
  • 30% American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) prefilters - Used on heating, ventilation, and air conditioning (HVAC) recirculation room air handlers in a large portion of the Facility.
  • Packed-bed or Sieve Tray Scrubbers - Used in several buildings. Sodium hydroxide, water, and sulfuric acid are used as scrubbing solutions.
  • HEPA filters - Used throughout the Facility for high-efficiency (99+%) removal of airborne particulates. In some instances, multiple HEPA filters are used in series to achieve higher removal efficiencies.
2. Liquid Waste Storage: NFS' wastewater storage tanks are housed inside secondary containment structures. The majority of the secondary containment structures are designed to hold the contents of the largest structure, or the tank volume is administratively limited. This is a safeguard measure to prevent release of liquid waste to the environment.
3. Liquid Effluents:
  • NFS WWTF - The NFS Erwin Facility produces liquid effluents from a number of different activities: fuel production, highly enriched uranium recovery, UF6 conversion, enrichment 6

21T-23-0212 Revision 1 blending, laboratory operations, laundry activities and Facility decommissioning activities. This wastewater is batch treated, sampled, and then discharged from the on-site WWTF, if levels are below 10 CFR Part 20.1301 and in compliance with the Facility's NPDES Permit. Treatment typically involves adjustment of pH using sodium hydroxide/sulfuric acid, and precipitation and removal offluoride ions and uranium through addition of lime slurry, calcium hydroxide Ca(OH)2.

Dissolved ammonia is removed, as needed; using air stripping and the pH is re-adjusted to discharge levels. Discharges are made directly to the Nolichucky River.

  • Sanitary Wastes Sanitary waste from the Facility consists of bathrooms and showers. The Facility discharges under an Erwin Publicly Owned Treatment Works (EPOTW) permit.
  • Stormwater Run-off - The primary pathway for run-off is from south to north across the Facility and into Banner Spring Branch and Martin Creek. Banner Spring Branch flows into Martin Creek which subsequently flows into North Indian Creek and then into the Nolichucky River. Drainage exits the Facility's Protected Area through two (2) sluice gate valves into Martin Creek. The gates are in place to allow the flow to be stopped in the event of a spill of hazardous material.

Figure 3 (Liquid Effluent Discharge Points) shows the stormwater liquid effluent discharge points for the NFS Erwin Facility.

4. Radioactive Solid Waste Management: The Facility contains various former on-site disposal and storage locations for process wastes and for radioactively contaminated soil and sediment (Figure 4, Former Waste Disposal and Storage Areas). No new waste material has been added to these areas since 1978. Currently waste generated on-site is packaged for off-site burial at a licensed radioactive waste disposal facility. Prior to 1978, several on-site areas were used for radioactive material disposal. These are briefly described below.
  • The Pond 4 Disposal Area - Former process waste burial area. Removal of waste and contaminated soil in this area is complete.
  • Surface Impoundments (ponds) - Three surface impoundments were used for liquid process waste treatment prior to the start-up of the NFS WWTF in 1978. Sludge and sediment from the bottom of these former ponds was removed during the period of 1991 to 1994. They have been drained and excavation of contaminated soil is completed.
  • The North-Site Burial Grounds - This was a former 10 CFR Part 20.304 process waste burial area.

Materials buried in the trench included process wastes, laboratory trash, contaminated equipment, and construction rubble. Remediation of the Demolition Landfill and Radioactive Burial Ground began in April 1997. Excavation of debris and soil is complete.

  • The Southwest Burial Trenches - Two former burial trenches containing low-level uranium and thorium contaminated scrap metals and equipment. Excavation of debris and contaminated soil is complete.

In addition to the above disposal areas, a soil mound that was used for storage of sediment and soil with elevated. radioactivity levels from the relocation of Banner Spring Branch has been removed to a licensed off-site disposal site and excavation is complete.

5. Mixed Waste Management: NFS manages "mixed" waste (hazardous waste which is radioactively contaminated) in accordance with applicable federal and state hazardous waste management regulations. NFS has a Hazardous Waste Management Facility permit, issued by the Tennessee Department of Environment and Conservation's (TDEC) Division of Solid Waste Management, which allows storage of specific kinds of mixed waste in containers. Most of the mixed waste stored on-7

21T-23-0212 Revision 1 site is mercury contaminated waste (waste code: D009) generated by NFS laboratory operations.

Much smaller amounts of other mixed wastes (including waste codes: D008, D038, D039) are also stored.

The corrective action conditions for the solid waste management units (SWM U) and areas of concern (AOC) are also included as part of the permit. NFS is required to notify TDEC and investigate any releases of hazardous waste or hazardous constituents at the facility and to take appropriate corrective action for any such releases.

NFS periodically conducts mixed waste treatability studies in accordance with applicable federal and state regulations. Such studies have been performed on waste generated by NFS.

6. Non-Radioactive Hazardous Waste: NFS generates hazardous waste which is not radiologically contaminated. In accordance with applicable regulations, NFS temporarily stores such waste on-site and then ships it to an authorized off-site treatment, storage or disposal facility.
7. Non-Radioactive/Non-Hazardous Waste: NFS generates non-radioactive/non-hazardous waste (such as waste oil, paper and cafeteria waste) in the normal course of operations. All waste materials are shipped off site for treatment, recycling and/or disposal at appropriate facilities.

Emergency Preparedness NFS maintains a detailed Emergency Plan, which specifies accidents with potential off-site consequences.

The accidents with potential for off-site consequences are: nuclear criticality, UFG release, uranium solution release, major fires, anhydrous hydrogen fluoride (AHF) release, anhydrous ammonia release, natural phenomena and security emergencies. With the exception of a criticality accident, accidents at NFS are of comparable probability, nature and magnitude with those of non-nuclear chemical processing operations.

NFS facilities are designed with extensive engineering and administrative safeguards to preclude most accidents.

SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" SECTION AND TABLES Environmental Releases As discussed in the Emergency Preparedness section above, NFS has engineered and administrative controls in place to prevent and mitigate environmental releases. Implementation of these plans is supported through on-going training of NFS personnel at all levels. The effectiveness of these plans, in combination with NFS' overall operating procedures is demonstrated by the low number of releases that occurred during the current license period and the short- and long-term responses taken when a release occurred or threatened to occur.

Table 2 (Environmental Releases which Triggered an Outside Notification) provides information addressing environmental compliance events that triggered outside notification from June 1996 through December 2021. NFS experienced fifteen (15) events during this period, requiring outside notification. Of these, four (4) events exceeded permit limits (Erwin POTW); however, none of these events resulted in a violation of Federal standards. The August 3, 2000, event was caused by a non-representative sample and thus did not result in a radioactive material release. None of these events had a significant and/or lasting impact on the environment.

8

21T-23-0212 Revision 1 Safeguards NFS provides nuclear material safeguards in accordance with the requirements set forth in 10 CFR Parts 70 and 73.

The NFS material accounting and control program includes facility organization requirements, material control arrangements, accountability measurements, statistical controls, inventory methods, shipping and receiving procedures, material storage practices, records report requirements, and management controls.

The NFS physical security and protection program has provisions for both "fixed site" and "material in transit" and includes: (1) maintaining a trained security organization with armed guards, (2) maintaining physical barriers, and (3) maintaining security response and safeguard contingency plans.

9

21T-23-0212 Revision 1 2.1.3 Reasonable Alternatives The alternative of not amending the SNM-124 license to include the Uranium Purification and Conversion Services will result in the work having to be conducted elsewhere, which provides no environmental benefit, an increase in area unemployment, and a potential increase in United States Naval Fuel manufacturing costs.

Additionally, for this work to be conducted at another site, it is likely that a significant environmental impact might be incurred due to construction and start-up activities, since other currently available licensable facilities are limited.

10

21T-23-0212 Revision 1

2. Environmental Releases which Triggered an Outside Notification Agency Date Event ~FS Response Notified Line leak was caused by weight of a large rock on the discharge line. The 8/29/97 Ground Water leak during transfer to WWTF TDEC NRC line was repaired.

Sewer discharge to Erwin POTW exceeded Gross A sanitary sewer manhole near a building being decommissioned was Erwin Utilities 9/4/98 Beta limits of 300 picocuries per liter of air determined to be the cause. The line was capped and filled with concrete.

NRC

{pCi/I). The action was effective.

Sewer discharge to Erwin POTW exceeded Erwin Utilities The cause was determined to be a leak in a laboratory sump and adjacent 5/12/99 25 pCi/I for 238 U NRC manhole. The items were repaired.

Terminated WWTF discharges. Investigated cause and validity of sample The May 2000 monthly isotopic composite sample 8/3/00 NRC results. The composite sample was not representative. Procedures and result for WWTF discharges was elevated.

training were modified to address the issue.

Groundwater infiltration caused an overflow of TDEC 8/8/00 Sealed the sump to prevent ground water infiltration lab wastewater pit NRC A defect in the floor trench of the WWTF was 11/29/00 TDEC Repaired defects identified during an inspection The WWTF discharged a batch with elevated 9/22/03 TDEC Reinstruction of operation nitrite plus nitrate attributes Sewer discharge to the EPOTW exceeded the EPOTW 2/05 & 3/05 Technical Review Criteria and the monthly Plugged abandoned sanitary sewer line.

NRC Average permit limit for U-238 in March 05.

Sanitary sewage leak was caused by freezing temperatures. The following corrective actions were taken:

1. Portable toilet removed from plant site; Sanitary sewage leak from a portable toilet into 2. Freeze protection implemented on portable structures with exposed 2/5/09 TDEC the storm water drainage system. piping;
3. Enhanced monitoring schedule on portable structures; and
4. Storm Water Pollution Prevention Plan reviewed and no revision necessary.

A 1% molasses and 99% water solution injected into groundwater monitoring wells migrated into a storm water ditch. The following Water and molasses leached from a ground water corrective actions were taken:

4/28/10 monitoring well into the storm water drainage TDEC 1. Well injection stopped;

2. Solution pumped from storm water ditch; system.
3. Absorbent materials applied;
4. pH and radiological samples collected; and
5. Investigation implemented.

11

21T-23-0212 Revision 1 Agency Date Event NFS Response Notified A 3% molasses and 97% water solution injected into groundwater monitoring wells migrated into a storm water ditch. The following Water and molasses leached from a ground water corrective actions were taken:

10/4/10 monitoring well into storm water drainage 1. Well injection stopped; TDEC

2. Solution pumped from storm water ditch; system.
3. Absorbent materials applied;
4. pH and radiological samples collected; and
5. Investigation implemented.

A break in a fire water line caused city water and soil to be discharged into a storm water ditch. The following corrective actions were taken:

City water and soil were discharged into a storm 1. Storm water sluice gates were closed; 5/3/18 TDEC water drainage system. 2. City water shut off;

3. Water and soil removed from storm water drainage ditch; and
4. pH and radiological samples collected.

A 3% emulsified vegetable oil and 97% water solution injected into to a groundwater monitoring well migrated into a storm water ditch. The following corrective actions were taken:

Water and emulsified vegetable oil leached into 1. Well injection stopped; 8/29/18 TDEC the storm water drainage system. 2. Solution pumped from storm water ditch;

3. Absorbent materials applied;
4. pH and radiological samples collected; and
5. Investigation implemented.

The following corrective actions were taken:

1. pH samples were analyzed twice; Sanitary Sewer pH of 9.14 standard units (su) 2. Maintenance activities and facility boiler discards for 12/6-8/2019 were 12/9/19 Erwin Utilities exceeded the permit limit of 9.0 su. evaluated;
3. Analytical quality control verified; and
4. Follow-up samples collected and analyzed from 12/10-16/20.

The following corrective actions were taken:

Rupture of a hydraulic seal on a facility elevator, 1. Spill containment measures were immediately implemented in the storm water drainage system, in Banner Spring Branch and Martin Creek; released hydraulic fluid into the storm water 7/23/20 TDEC 2. Elevator placed out of service until repaired; and drainage system. The hydraulic seal ruptured

3. Investigation into cause of seal rupture and overflow discharge point occurred during a large rain event.

location.

4.

12

21T-23-0212 Revision 1 Agency Date Event NFS Response Notified A groundwater treatment injection mixture leached into the storm water drainage system. The following corrective actions were taken:

1. Well injections stopped; Groundwater treatment injection mixture leached 2. Solution pumped from storm water ditch; 9/9/2021 into the storm water drainage system TDEC
3. Absorbent materials applied;
4. pH and radiological samples collected;
5. Investigation implemented Source:

Various NFS notifications to outside agencies 13

21T-23-0212 Revision 1 Figure 3. Liquid Effluent Discharge Points EftWJlllni:'Selfst.Jltm!DS l.EAS'EO PllC.F'ERT"r RAJLRCAD "OHOOSTAATIJE REVIEW rea/,;.W <<u:m Wit 31M

,,,, ~

LEGEND a.,

@:XID:9 STOAMWIITER OUTFALLS

_.,. 000-CG137-D FE.Dian;ll'~'1£111-*

14

21T-23-0212 Revision 1

_f.i~~re 4. Formi:r_Waste Disposal & Stor,a~f! .t\rf!a LEGEND (D PONO 4

@ PONDS l, 2 II. 3 DEMOLl Tl ON LANDFILL SOUTHWEST BURIAL TRENCH NORTH SITE BURIAL GROUND 15

21T-23-0212 Revision 1 3.0 Description of the Affected Environment 3.1 LAND USE The NFS Erwin Facility utilizes about 78.1 percent of the 81.9-acres site area for licensed activities and includes process buildings, warehouses, offices, parking lots, and waste management areas. The remainder of the NFS Erwin Facility consists of open fields and small areas of woods and/or brush. Table 3 (NFS Erwin Facility Land Use} provides a breakdown of the land use by size and percent of total Facility area.

Table 3. NFS Erwin Facility Land Use Use Size (acres} Percent of Site Buildings and grounds 38.1 46.5 Former waste ponds and solid waste burial grounds 17.3 21.1 Parking lot 8.6 10.5 Open fields 17.0 20.8 Woods and brush 0.9 1.1 Total 81.9 100 Source:

Google Earth Imagery, October 17, 2019 3.1.1 Adjacent Areas The land within a one-mile radius of the NFS Erwin Facility is dominated mainly by residential use, followed by public and semi-public uses, and agriculture. The Riverview Industrial Park is located west of the NFS Erwin Facility adjacent to the CSX railroad, which bounds the western side of the Facility. Interstate 26 lies west of the industrial park and is adjacent to the east bank of the Nolichucky River, a popular recreational area. The northern portion of the Facility is bounded by Martin Creek and a small woodlot that separates the NFS Erwin Facility from residential properties. The area east of the Facility consists of various residential and commercial properties, including the Erwin State Trout Hatchery that is located approximately 600 feet east of the Facility. The area south and west of the NFS Erwin Facility is bounded by Jackson Love Highway and further residential and commercial development. Table 4 (Land Use within a 1-Mile Radius of the NFS Erwin Facility} provides a breakdown of the percent land use within this area.

Table 4. Land Use within a 1-Mile Radius of the NFS Erwin Facility Use Percent of Area Residential 23.7 Public and Semi-public Uses 19.2 Agricultural 16.3 Timber/Forest 9.5 Vacant 8.5 Transportation 8.4 Industrial 6.2 Commercial 5.1 Water 3.1 Total 100 Source:

TN Comptroller Digital Parcel and CAMA Data 2/4/2019 16

21T-23-0212 Revision 1 Locally important crops include hay, corn, tomatoes, strawberries, and apples (USDA 2017). In 2015, total direct agricultural output was estimated to be $15.7 million and 148 people were employed in county agriculture (UT 2018).

3.2 TRANSPORTATION The NFS Erwin Facility is located in the Town of Erwin, in Unicoi County, which is in the northeastern portion of the State of Tennessee (Figure 1, NFS Erwin Facility Location). The Facility is accessed by Interstate 26 via Jackson Love Highway and Carolina Avenue from the southwest; a CSX Railroad line on the northwest boundary (to support licensed activities including radioactive waste shipments); and Banner Hill Road on the southeast boundary. The NFS Erwin Facility is approximately 0.6-mile, by road, to Interstate 26.

3.3 GEOLOGY AND SOILS 3.3.1 Physiography and Geography The NFS Erwin Facility lies in the Valley and Ridge physiographic province of northeastern Tennessee. The stratigraphy ofthe area is very complex because much folding and faulting has occurred. The topography consists of a series of alternating valleys and ridges that have a northeast-southwest trend, with the Facility occupying a valley (USDA 1985).

Three dolomite formations underlie the valley: the Shady, Knox, and Honaker Formations. They are associated with a large band of sandstone, siltstone,, shale, dolomite, and limestone called the Rome Formation. Large areas of these formations are covered by deep soils found in the colluvium from the adjacent mountains and alluvium from larger streams. The present topography of the valleys is the result of stream erosion of softer shales and limestones; the ridges are underlain by the more resistant shale, sandstone, and quartzite. Metamorphic and intrusive rocks of the Blue Ridge physiographic province lie southwest and southeast of the NFS Erwin Facility (USDA 1985).

3.3.2 Foundation Geology The bedrock strata at the NFS Erwin Facility are consolidated, providing firm foundations for buildings that lie directly on the strata or that are supported by footings. Structures that are constructed on the unconsolidated alluvium from the former flood plain and terraces of the Nolichucky River are subject to settlement during the first 2 to 3 years after construction (NRC 1991).

The NFS Erwin Facility is not likely to experience slope failure. Such failures are common in the mountainous terrain surrounding the site, but not on the former flood plain where slopes are flat.

Structures are set back sufficiently from the Nolichucky River to avoid destabilization by erosion or slope failures along the riverbank (NRC 1991).

3.3.3 Mineral Resources The principal mineral resources of Unicoi County are sand and gravel used by the construction industry, and metallurgical grade manganese, and iron ore (NRC 1991d). Extraction of sand and gravel from the bed and flood plain of the Nolichucky River and North Indian Creek began in the 1940s and was more or 17

21T-23-0212 Revision 1 less continuous until the mid-1970s when large-scale operations ceased. Manganese deposits are contained mostly in the clay rich residual soils of the Shady Dolomite. Manganese is also found in residual soils of the Honaker Dolomite and lower portions of the Rome Formation. Manganese mines began producing near the end of World War II. Many manganese deposits in the area remain untapped. Small iron ore deposits were mined before World War I, but the industry was unable to sustain itself.

3.3.4 Seismicity The NFS Erwin Facility lies in the moderately active Appalachian Tectonic Belt. The United States National Seismic Hazard Model indicates the NFS site is located in an area of moderate seismic hazard (USGS 2018).

The Facility is cut by many inactive faults formed during the late Paleozoic Era. There is no evidence of capable faults (as defined by 10 CFR Part 100) in the immediate area of the NFS Erwin Facility. The nearest capable faults are located 62.1 miles southwest and 124 miles northeast of the Facility. Strong earthquakes originating in more active regions southwest of the Facility have been felt in eastern Tennessee, but no damage has been experienced at the Facility (DOE 1996). A maximum horizontal ground surface acceleration of 0.18 gravity at the Facility is estimated to result from an earthquake that could occur once every 2,000 years. The buildings at the NFS Erwin Facility that are utilized for processing significant quantities of radioactivity were designed to withstand an earthquake with an acceleration of 0.18 gravity (NFS 1996b and 2007 ISA Summary Report).

3.4 WATER RESOURCES 3.4.1 Surface Water There are four major surface water bodies in the vicinity of the NFS Erwin Facility: Banner Spring Branch, North Indian Creek, Martin Creek, and the Nolichucky River. Banner Spring Branch is located entirely within the Facility and is completely enclosed inside an underground pipe. North Indian Creek is located north of the Facility boundary; Martin Creek is just beyond the Facilitis north bounda*ry; and the Nolichucky River is located west of the Facility boundary (Figure 5, Surface Water Bodies in the Vicinity of the NFS Erwin Facility).

In 2005, Banner Spring Branch was enclosed inside an underground pipe to prevent contamination, during decommissioning activities. It is a small spring-fed stream that flows east at a rate of approximately 0.35 to 0.71 cubed feet per second (ft3/s). It empties into Martin Creek at the NFS Erwin Facility boundary.

Banner Spring Branch is approximately 1,700 feet in length from source to confluence with Martin Creek.

Banner Spring Branch receives input from the NFS Erwir:, Facility surface water run-off.

Martin Creek is fed from mountain springs, rain, and snow melt drainage from Martin Creek Hollow. The flow of the creek varies seasonally from 2.11 to 11.0 ft3/s. iytartin Creek empties into North Indian Creek approximately 3,500 feet north of the NFS Erwin Facility, and North Indian Creek empties into the Nolichucky River approximately 4,000 feet downstream of the Facility.

The Nolichucky River is formed by the North Toe River and the Cane River in Yancey and Mitchell Counties.

The river flows west from North Carolina and southwest through Tennessee to join the French Broad River, whose watershed forms part of the upper Tennessee River Basin.

18

21T-23-0212 Revision 1 The 99-year average flow of the Nolichucky River is 1,394 ft 3/s as measured at the Embreeville USGS gauge station located approximately 2.2 miles (mile 96.8) downstream of the NFS NPDES permitted WWTF Outfall 001. The highest peak flow since May of 1901 was on Nqvember 6, 1977, when the Nolichucky River reached a gauge height of 21.52 feet with a flow velocity of 110,000 ft 3/s. The lowest annual mean stream flow recorded at the Er:nbreeville gage station was 656.9 ft 3/s in 1988 (USGS 2021). A thirty-year low annual river flow at Outfall 001 was calculated to be 589 ft 3/s (16.7 m 3/s) (NFS 2001d).

The NFS Erwin Facility is not within the 100-year floodplain of the Nolichucky River. Development and related activities over the last 30 years have changed the topography in such a way to preclude the Facility from being within the 100-year floodplain for the river. For example, the construction of US Routes 19/23, and the re-channeling/increase in depth of the river, which accompanied the highway construction combined with the re-routing of Martin Creek to enter the Nolichucky River downstream of the Facility,

.have had the indirect effect of protecting the Facility from a 100-year flood of the Nolichucky River. A significant flood of the Nolichucky River (92% of greatest recorded flow) which occurred in 1977 did not result in the flooding of any building at the Facility.

Currently, the northern portion of the NFS Erwin Facility is depicted as being within the 100-year floodplain of Martin Creek (which flows adjacent to the northern boundary) on 2008 National Flood Insurance Maps issued by FEMA. Martin Creek passes through a culvert at the CSX Railroad to the north of the NFS Erwin Facility. In the past, the size of this culvert was inadequate during high flow floods, causing a backwater or damming effect on the northern portion of the Facility nearest the culvert. In 1990, the culvert was enlarged to accommodate expansion of the railroad. Additionally, grading has been performed on the north side since 1979 which is year the survey was performed to develop the effective Base Flood Elevation. Finally, newer more accurate field survey and LIDAR data was used to perform the 2021 ARCADIS floodplain analysis. This analysis shows the 100-year Base Flood Elevation (BFE) immediately upstream of the railroad is 3.38 feet higher than the effective BFE at this location and is 3.03 feet lower than the effective BFE approximately 1,500 feet upstream of the railroad near Spar Mill Road.

The effective Flood Insurance Rate Map 47171C0068C depicts the Facility within the 100-year floodplain of Martin Creek (FEMA 2008). The 2021 ARCADIS Floodplain study shows that the Facility's Protected Area is completely outside of the 100-year floodplain and that much of the northern portion of the NFS property is also outside of the 100-year floodplain. A portion of the northern part of the site, 600 feet off Martin Creek along the railroad, and a small section along the Protected Area wall is within the 100-year floodplain based on 2021 ARCADIS floodplain analysis.

As part of decommissioning activities in 2010, two (2) small wetlands totaling approximately 0.35-acre were filled under an Aquatic Resource Alteration Permit (NRS09.332). As conditions of the permit, NFS was required to restore 0.7 acre of wetlands at a nearby site and to purchase 0.7 acre of credits from a wetland mitigation bank (Shady Valley Wetland Mitigation Bank).

USFWS National Wetland Inventory mapping indicates the presence of three riverine wetlands and one freshwater pond at the NFS Erwin Facility, however this map is out of date (it is based on color infrared imagery from 1983) and not consistent with changes to the site characteristics discussed above. There are currently no jurisdictional wetlands located on the NFS Erwin Facility.

19

21T-23-0212 Revision 1 Quality The streams and creeks of Tennessee are classified by the TDEC. The classifications are defined in the State of Tennessee Water Quality Standards. Classifications are based on water quality, designated uses, and resident aquatic biota. Banner Spring Branch, Martin Creek, and the Nolichucky River are all classified for fish and aquatic life, livestock watering and wildlife, irrigation, and recreation. The Nolichucky River is also classified for industrial use and as a domestic water supply (TDEC 2019).

NFS has three outfalls covered by NPDES permits. One outfall carries process-related effluents while the two others carry (covered by separate permits) storm water. In addition, NFS discharges sanitary wastewater to the EPOTW in accordance with Industrial Pretreatment Permit (013) issued by Erwin Utilities. Table 5 gives the approximate discharge volumes and, where applicable, the volume allowed to be discharged under each permit.

Table 5. NFS Permitted Outfalls Average Outfall Output Discharge Location (L/yr} .

Wastewater Treatment Facility (NFS) 7,043,437 Nolichucky River (TN0002038)

Storm water (NFS) N/A Banner Spring Branch & Martin Creek (TNR0S0873)

Sanitary Sewer (NFS) 41,837,157 Erwin POTW (013)

Source:

NFS EDMS 2009-2020 The ambient non-radiological water quality characteristics are summarized in Table 6 (Non-Radiological Surface Water Quality). Non-radiological characteristics for Banner Spring Branch, Martin Creek, and the Nolichucky River are not routinely measured; however, 2002 chemical data is presented in Table 6. The results are typical for the area. Martin Creek water quality is likely to be affected by the Creek's passage through the Erwin Fish Hatchery located approximately 600 feet upstream from the NFS Erwin Facility.

Table 6. Non-Radiological Surface Water Quality Water Quality Nolichucky , Banner Spring Martin Parameter Benchmark a River c Branch c Creek*

.(mg/I), (mg/I) '(mg/I) (mg/I)

Ammonia N/A <0.36 <0.333 <0.331 Fluoride 4d 0.417 0.387 0.303 Mercury 0.002 e <0.0002 <0.0002 <0.0002 Nitrate/Nitrite 10 d 0.424 1.821 1.059 Notes:

' For comparison only, unless noted referenced value is from applicable TDEC water qualfty criteria and standard

  • Data from 2002 water samples downstream of NFS discharge c National Secondary Drinking Water Standard (40 CFR Part 141) d National Primary Drinking Water Standard (40 CFR Part 143)

Tennessee State Water Quality Standards Banner Spring Branch and its source, Banner Hill Spring, are located entirely on the NFS Erwin Facility within the Owner Controlled Area. The Branch receives discharge from the NFS storm water system at a 20

21t-23-0212 Revision 1 point near its confluence with Martin Creek. Banner Spring Branch is completely enclosed inside a pipe and discharges into Martin Creek on the northside of the NFS Erwin Facility.

The main portion of Martin Creek, which is upstream of NFS, is used for recreational fishing. Fishing in the portion of Martin Creek near the NFS Erwin Facility is infrequent due to limited access. About 600 feet upstream from NFS is a State-operated fish hatchery located on Love Spring Branch, a tributary to Martin Creek. The hatchery requires over 1 million gallons per day to operate. The creek is not classified as a trout stream by the State of Tennessee, nor is it used as a potable water source. It is, however, classified for fishing, recreation, irrigation, livestock watering, and wildlife use.

The Nolichucky River in the vicinity of the NFS outfall is classified for domestic water supply, industrial, fishing, recreation, irrigation, livestock watering, and wildlife use. The City of Jonesborough is the nearest municipal user of the water as a source of drinking water (approximately 1 million gallons/day). The City of Jonesborough Treatment Plant's water intake is approximately 8 miles downstream from the NFS discharge point. The closest known crop irrigation use of river water occurs over 10 miles downstream of the NFS discharge. Irrigation is rare due to the adequacy of rainfall in this area for crop production.

Irrigation is primarily used in the spring and fall to reduce crop damage from frost (e.g., strawberries and tomatoes) and to extend the growing season and preserve the quality of tomato crops. Recreational use of the Nolichucky River includes fishing (bass, walleye, and catfish), boating (canoeing/rafting), swimming, and picnicking. The Erwin Utilities POTW discharges into the same reach of the Nolichucky River, as does NFS.

3.4.2 Groundwater Quality The groundwater quality in the area is generally good. The principal dissolved constituents of the groundwater are calcium, magnesium carbonate, and bicarbonate, regardless of the production zone geology. This reflects the regional influence of dolomitic host rocks on groundwater quality.

Data on the ambient non-radiological water quality is summarized in Table 7 (Ambient Non-Radiological Groundwater Quality). Ambient non-radiological characteristics for groundwater are assessed routinely by measurements of an up-gradient well (NFS well #52).

Table 7. Ambient Non-Radiological Groundwater Quality Parameter ,, Unit Water Quality Benchmark a Up-gradient Well b Fluoride mg/I 4c 0.14 Mercury mg/I 0.002* 0.0002 Sulfate mg/I 250d 12.0 Tetrachloroethylene (PCE) mg/I 0.005 C 0.6922 Temperature oc N/A 14.40 Total organic carbon mg/I N/A 1.0 Notes:

  • For comparison only b Average of available data for well #52 from June 1996 through 2008. Nitrate/Nitrite, chloride, and Phosphate were not collected during this time period,

' National Primary Drinking Water Standards {40 CFR Part 141) d National Secondary Drinking Water Standards (40 CFR Part 143)

21T-23-0212 Revision 1 Use Groundwater elevation measurements and modeling indicate that, generally, groundwater flows in a northwest direction towards the Nolichucky River, which is a major discharge zone for the groundwater flowing beneath the NFS site. There are no known household, public, or industrial users of groundwater down gradient of the site (GMI 1996).

Most drinking water sources are provided by the local municipality; however, wells and springs are an important source of water supply for individuals and several communities in the area (Erwin and Chestoa quadrangles). A water-well survey has been performed for the NFS Erwin Facility consisting of a TDEC -

TN Water Well Desktop Application [3.0-PUBLIC] records search for the surrounding area. The TDEC records are the most comprehensive water well survey in Tennessee, are traceable to individual users, and provide sufficient information to evaluate well installation practices. The state ofTennessee requires domestic wells to be cased and to be developed in the most favorable water quality source available.

Review of the TDEC records indicate that domestic wells are cased and installed in bedrock formations to tap water present in the deeper portions of the aquifer. Because public water well locations are considered confidential, a separate wellhead/source water request was sent to the TDEC Division of Water Resources (DOWR).

The well search consisted of determining water wells located within a 1-mile radius and 3-mile radius of the NFS Erwin Facility. One public water system wellhead protection area (DOWR 2021) and two residential wells were listed within 1 mile from the NFS Erwin Facility (Table 8, TN Water Well Desktop Application and DOWR Search within 1 Mile of NFS Erwin Facility). The public groundwater well, approximately 0.75-mile northeast (up gradient) of the NFS Erwin Facility, is owned by Erwin Utilities and is listed as the Railroad Well. Modeling done in 1996 indicated that groundwater withdrawn from the Railroad Well does not originate beneath or down-gradient from the NFS Erwin Facility (GMI 1996). The two residential wells are located approximately 0.9-mile (Resident 1) and 1-mile (Resident 2) south of the NFS Erwin Facility. No other wells were identified from the database within 1 mile from the Facility. The DOWR also noted that the 1-mile area of interest around the NFS Erwin Facility falls within the Jonesborough Water Department Source Water Protection Area.

Table 8. TN Water Well Desktop Application and DOWR Search within 1 Mile of NFS Erwin Facility Name Source Water Source Type Erwin Utilities Railroad Well Groundwater Resident 1 Residential Well (April 22, 2021) Groundwater Resident 2 Residential Well (May 30, 2002) Groundwater Note:

Five NFS monitoring wells have been excluded from the results presented in Table 8.

Sources:

Tennessee Department of Environment and Conservation - TN Water Well Desktop Application, July 16, 2021 Division of Water Resources 2021 Four public wellhead protection areas within a 3-mile radius of the NFS Erwin Facility were identified by the DOWR (DOWR 2021) (Table 9, TN Water Well Desktop Application and DOWR Search Within 3 Miles of NFS Erwin Facility). The four public water intakes are listed as a groundwater source or groundwater under the direct influence of surface water source. Erwin Utilities obtains water from two wells (one of which is the Railroad Well) and one spring located northeast of the Facility. In addition to the two residential wells, noted above, located within one mile of the Facility there were seven residential wells, two test wells, one commercial well, one irrigation well, and one well with an undefined use within three 22

21T-23-0212 Revision 1 miles of the Facility. The DOWR also noted the 3-mile area of interest around the Facility falls within the Jonesborough Water Department, USA Raft, and Nolichucky Gorge Campground Source Water Protection Areas.

Table 9. TN Water Well Desktop Application and DOWR Search within 3 Miles of NFS Erwin Facility Name Source Water Source Type Groundwater Under Direct Erwin Utilities Birchfield Well Influence of Surface Water Groundwater Under Direct Erwin Utilities O'Brien Spring Influence of Surface Water Erwin Utilities Railroad Well Groundwater Resident 3 Residential Well (October 21, 2009) Groundwater Resident 4 Residential Well (September 8, 1994) Groundwater Unicoi County School Board/

Commercial Well (February 19, 2008) Groundwater New Middle School Resident 5 Residential Well (May 21, 2019) Groundwater Erwin Utility District Test Well (February 11, 1993) Groundwater Erwin Utility District Test Well (October 28, 1993) Groundwater Resident 6 Residential Well (July 29, 1998) Groundwater Resident 7 Residential Well (July 28, 2019) Groundwater Resident 7 Undefined (July 31, 2019) Groundwater Resident 8 Residential Well (March 21, 1995) Groundwater Resident 9 Residential Well (April 30, 1995) Groundwater Unicoi County School Systems Irrigation Well (April 30, 2009) Groundwater Note:

Five NFS monitoring wells have been excluded from the results presented in Table 9.

Source:

Tennessee Department of Environment and Conservation - TN Water Well Desktop Application, July 16, 2021 3.5 ECOLOGICAL RESOURCES 3.5.1 Terrestrial Biota Plant communities at the NFS Erwin Facility are characteristic of the intermountain regions of central and southern Appalachia. The USDA-NRCS Land Resource Regions and Major Land Resource Areas (MLRA)

(2022) indicates the NFS Erwin Facility is located in the Southern Blue Ridge MLRA. The most common forest trees in this region include white oak, black oak, scarlet oak, chestnut oak, hickory, eastern white pine, Virginia pine, pitch pine, yellow poplar, and northern red oak. Higher elevations also include black cherry, black birch, and sugar maple (USDA-NRCS 2022).

The NFS Erwin Facility lies within Indian Creek Valley. Plant communities in this valley consist of second growth forests and open grassy areas. Most of the Facility is occupied by buildings, building grounds, and open fields. Limited areas consist of woods and brush. Nearby mountainous areas, which are part of the Unaka Mountains Recreation Zone of the Cherokee National Forest, are largely undisturbed and support extensive forests and wildlife resources (USFS 2022a) ..

The terrestrial fauna of the Erwin region includes a large number of vertebrate species; however, most of these species would not be expected to occur in the Indian Creek Valley because of extensive disturbance and lack of natural habitats. Species in this area are likely to include small rodents, eastern cottontail, Virginia opossum, red fox, and white-tailed deer (TWRA 2022a). Common bird species in this area are 23

21T-23-0212 Revision 1 likely to include mourning dove, northern flicker, blue jay, Carolina chickadee, American robin, European starling, Northern cardinal, red-tailed hawk, and house sparrow (TWRA 2022b). Many of these species are well adapted to developed urban and suburban areas. Undeveloped areas of the NFS Erwin Facility are likely to support some of the smaller wildlife species. Important game species of the region include whitetail deer, eastern gray squirrel, ruffed grouse, and wild turkey, which occur in the forests of the surrounding mountains (USFS 2022b) but are not common on site.

3.5.2 Aquatic Biota Aquatic habitat on or adjacent to the NFS Erwin Facility ranges from the Nolichucky River to several small streams. Banner Spring Branch contains several species of minnows where it converges with Martin Creek. Martin Creek is typical of creeks in eastern Tennessee. The stream bed is composed of sand, pebbles, rocks, and some organic matter. A state-operated fish hatchery is located on a tributary to Martin Creek approximately 600 feet upstream of the Facility. The Nolichucky River in the Erwin vicinity contains a substrate of rocks, sand, boulders, and some aquatic moss. The Tennessee Wildlife Resources Agency (TWRA) Region IV Warmwater Streams and Rivers Fisheries Report'provides baseline information on game and non-game fish and macroinvertebrate populations for the region including the NFS Erwin Facility. The most recent available report is from 2017. This report indicates that sportfish present in the Nolichucky River include all species of black bass as well as rock bass, muskellunge, channel catfish, flathead catfish and various sunfish. During the winter months the river is stocked with rainbow trout from the USFWS hatchery in Erwin. The report further indicates the river has historically supported 50 species of fish and at least 21 species of mussels (TWRA 2017).

3.5.3 Threatened and Endangered Species No state or federally listed threatened or endangered species are known to occur on-site. The United States Fish and Wildlife Service's (USFWS) Information for Planning and Consultation (IPaC) database was consulted to determine the potential presence of federally listed threatened and endangered species in the vicinity of the NFS Erwin Facility. A Request for Environmental Review was submitted to the TDEC on July 15, 2021, to obtain information on any documented occurrences of state or federally listed threatened or endangered species in the vicinity of the Facility. The IPaC database indicates that five listed animal species and one listed plant species could potentially be impacted by activities at the Facility (USFWS 2021). The TDEC's August 20, 2021, response indicates that seven state-listed plant and animal species have been documented within one mile of the. Facility. Additional species are documented by TDEC within four miles of the Facility; however, no impacts to any species are anticipated at such a great distance from the NFS Erwin Facility. The TDEC species list does not document occurrences of any IPaC identified species within one mile of the Facility. Listed plant species are not afforded legal protection unless located on TDEC lands (in the case of state listed species) or federal lands (in the case of federally listed species). The seven federal and/or state listed threatened or endangered species that potentially occur in the region are presented in Table 10 (Federal and State Listed Threatened and Endangered Animal Species). IPaC did not indicate a need to analyze potential effects to established critical habitat(s) for any of these species.

24

21T-23-0212 Revision 1 Table 10. Federal and State Listed Threatened and Endangered Species Common Name Scientific Name' Status - Federal Status - State Gray bat Myotis grisescens E Indiana bat Myotis soda/is E Northern long-eared bat Myotis septentrionalis T Appalachian elktoe Alasmidonta raveneliana Ea E Villosa trabalis/Venustaconcha Ea Cumberland bean E trabalis Virginia Spiraea Spiraea virginiana r* E Mountain bush-honeysuckle Diervil/a sessilifo/ia var. rivularis Cow-parsnip Heracleum maximum Southern nodding trillium Trillium rugelii Carolina hemlock Tsuga caroliniana Highfin carpsucker Carpiodes vehfer Allegheny wood rat Neotoma magister Tangerine darter Percina aurantiaca Notes:

  • Listed as potentially occurring in the vicinity of the NFS site by IPaC.

b Occurrence records indicated by TDEC within one mile of the site.

Status codes: E = endangered; NL= not listed; T = threatened; S = Special Concern; D = Deemed in Need of Management.

Sources:

50 CFR Part 17.11 TWRA 2016 3.6 METEOROLOGY, CLIMATOLOGY, AND AIR QUALITY 3.6.1 Meteorology The average annual precipitation in the Erwin area is 47.0 inches. The average annual snowfall in the Erwin area is 9.3 inches (NOAA 2021a). Prevailing winds tend to follow the southwest to northeast orientation of the valley and the average wind speed (as measured at the nearby Tri-Cities Airport over the period from 1984 to 2018) is 6.9 miles per hour (mph) (NOAA 2019).

Winds, Tornadoes and Storms Severe storm conditions are rare in the Erwin region, which is east of the center of tornado activity, south of most blizzard conditions, and too far inland to be affected by hurricanes (NRC 1991a). Only two tornadoes have been recorded in Unicoi County since 1950 (NOAA 2021b). One tornado occurred on July 10, 1980, on the eastern end of Unicoi County approximately 6 miles from the NFS Erwin Facility. The tornado magnitude was an F3, with wind gusts of between 162-209 mph, twelve (12) individual injuries occurred, no deaths were reported, with property damage of $250K, and with no crop damage occurring (NOAA 2021b). A second tornado occurred on April 09, 2011, on the southern end of Unicoi County approximately 8 miles from the NFS Erwin Facility. The tornado magnitude was an F0, with a maximum wind speed of 70 mph, no injuries occurred, no deaths were reported, with property damage of $15K, and with no crop damage occurring (NOAA 2021b).

25

21T-23-0212 Revision 1 3.6.2 Climatology The climate in the vicinity of the NFS Erwin Facility is characterized by warm, humid summers and relatively mild winters. Cooler, drier weather in the area is usually associated with polar continental air masses, whereas warmer, wetter weather is associated with gulf maritime masses (NRC 1991).

The average annual temperature is 55.4°F; the lowest average daily temperature is 35.52F in January; and the highest average daily temperature is 74.0°F in July (NOAA 2021a).

3.6.3 Air Quality As of June 2021, Unicoi, Washington, and Carter Counties were designated as in attainment with respect to National Ambient Air Quality Standards (NAAQS), as specified in 40 CFR Part 81.343. Sullivan County was in nonattainment status for the lead standard between 2010 and 2016 and has been in nonattainment status for the sulfur dioxide standard since 2013 (EPA 2021).

There are no Prevention of Significant Deterioration (PSD) Class I areas (as defined by 40 CFR § 52.21) within two (2) miles of the NFS Erwin Facility. The nearest Class I area is Great Smoky Mountains National Park, located approximately 47 miles southwest of the NFS Erwin Facility. The Andrew Johnson Memorial (National Historic Site), Appalachian Trail (National Scenic Trail), Over Mountain Victory Trail (National Scenic Trail), Tennessee Civil War National Heritage Area, New River (South Fork) (Wild and Scenic River),

and Obed River (Wild and Scenic River) are in proximity of the NFS Erwin Facility but do not appear to meet the requirements for classification as Class I areas. Since the promulgation of the PSD regulations (40 CFR Part 52.21) in 1977, no PSD permits have been required for any emission source at the Facility.

3.7 NOISE The noise environment near the NFS Erwin Facility is typical of a rural location. Major noise emission sources within the NFS Erwin Facility include various alarm systems, fixed plant equipment (e.g., pumps, blowers), and heavy equipment (tractor trailers, front-end loaders, back-hoes, etc.). The primary source of noise at the Facility boundary is from traffic, with other sources occasionally audible above background.

During shift changes, the Facility traffic may be a significant contributor to noise levels in the area. The Town of Erwin limits construction operations to occur between 7:00 am and 6:00 PM within residential areas; however, the Facility is zoned as Industrial. The State of Tennessee and Unicoi County have not established specific numerical environmental noise standards applicable to the Facility. No changes to local noise ordinances or standards have occurred since 2011.

3.8 HISTORIC AND CULTURAL RESOURCES No pre-historic or historic archaeological sites have been identified on the NFS Erwin Facility. The National Register of Historic Places (NRHP) lists three sites in the Town of Erwin located in Unicoi County (NPS 2020): the Clarksville Iron Furnace on Tennessee State Highway 107 in the Cherokee National Forest, approximately 10 miles west of the Facility; the Clinchfield Depot located at the junction of Nolichucky Avenue and Union Street, approximately one (1) mile from the Facility; and, the A.R. Brown tiouse located at 241 South Main Avenue, approximately 1 mile from the Facility.

26

21T-23-0212 Revision 1 3.9 VISUAL/SCENIC RESOURCES The visual/scenic resources of the NFS Erwin Facility are identified in Figure 2. The following changes have been made to the NFS Erwin Facility since the 1980s:

  • Decommissioning of portions of the Facility that started in the mid-1980s;
  • Construction of the AREVA NP (BLEU Complex) on the southwest side ofthe Facility in August 2002;
  • Security wall around the perimeter of the Facility started in 2007 and completed in 2012;
  • Modernization of ammonia stripping tower (2012);
  • Replaced exit/entry access control point (2012);
  • Redesign and installation of the main stack (2014);
  • Replacement of fan house (2014);
  • Decommissioning of the BLEU Complex (2018);
  • Decommissioning of the northern burial ground area and surface water impoundments (2018);
  • Relocation of the meteorological tower (2020);
  • Addition of a new office building (2020); and,
  • Relocation and modernization of Versatile Automated Gamma Assay System (VAGAS) in 2021.

The protection and preservation of scenic and environmental resources on the NFS Erwin Facility and surrounding community are part of all construction projects.

Previously identified scenic resources in the vicinity of the NFS Erwin Facility include (NRC 2011):

  • Nolichucky River: While it is not an officially designated scenic resource, the river is a popular recreational feature located approximately 0.2-mile from the NFS Erwin Facility. The NFS Erwin Facility may be partially seen from the river as it flows nearby. An approximately 8-mile stretch of the river located upstream from the NFS Erwin Facility and extending from Poplar, North Carolina to Unaka Springs, Tennessee is listed in the Nationwide Rivers Inventory for its scenic, recreational, and geological values. The NFS Erwin Facility is not visible from this stretch of the river because of the mountainous terrain between these areas.
  • Appalachian Trail: The trail crosses the Nolichucky River approximately 1.7-miles southwest of the NFS Erwin Facility. Intervening vegetation effectively screens the NFS Erwin Facility from view along this section of the Appalachian Trail. The Town of Erwin is visible on the trail along Cliff Ridge; however, viewers would not be able to identify the NFS Erwin Facility from this vantagepoint.
  • Erwin Linear Trail: The Erwin Linear Trail runs parallel to Interstate 26 along North Indian Creek and the Nolichucky River. The NFS Erwin Facility may be partially visible at various locations along this trail.

The following resources were consulted to determine if additional scenic resources have been designated in the vicinity of the NFS Erwin Facility since 2011:

  • State and National Scenic Byways (Scenic America 2022)
  • National Wild and Scenic Rivers (National Wild and Scenic Rivers System 2022) 27

21T-23-0212 Revision 1

  • National Scenic Trails (National Park Service 2022)
  • National Scenic Areas (Wikipedia 2022)
  • National Wilderness Areas (Wilderness Connect 2022)
  • Trails.com
  • Unicoi County Hiking Trails & Greenways (Unicoi County Chamber of Commerce 2022)

No additional designated scenic resources were identified using these resources.

3.10 DEMOGRAPHY AND SOCIOECONOMIC The NFS Erwin Facility is located approximately fifty (SO) miles north-northeast of Asheville, North Carolina and twenty (20) miles south of Johnson City, Tennessee. The NFS Erwin Facility is located near the southwest boundary of the Town of Erwin, Tennessee, which has a population of 5,994 people (USCB 2021). The current population of the Town of Erwin represents an approximately 1.6 percent decrease from the estimated 2010 population of 6,091 (USCB 2019).

Table 11 (Johnson City MSA Employment Statistics) provides employment and economic information from the Johnson City Metropolitan Statistical Area (MSA).

Table 11. Johnson City MSA Employment Statistics Regional Economic Area May 2022 Civilian labor force 94,600 Employment 91,500 Unemployment 3,100 Unemployment Rate 3.3 Source:

United States Department of Labor, Bureau of Labor, Statistics, May 2022 Region of Interest (ROI) for the NFS Erwin Facility includes four Tennessee Counties: Carter, Sullivan, Unicoi, and Washington. The ROI economic data for 2021 is presented in Table 12 (2021 ROI Economic Data). For comparison, the median household income for the State of Tennessee is $58,516 and 13.6% of the population is below the poverty level.

Table 12. 2021 ROI Economic Data

~--------~---------~

Median Persons Location Household Below Income (2017-2021) Poverty Level (%)

Unicoi County 47,610 14.5 Carter County 44,280 17.1 Washington County 52,503 14.3 Sullivan County 49,661 17.1 Source:

US Census Bureau, Census 2021 QuickFacts 28

21T-23-0212 Revision 1 Table 13 (NFS Employee Distribution by Residence) represents the distribution of NFS employees among the ROI counties in December 2022.

Table 13. NFS Employee Distribution by Residence County Number Percent of Employment by NFS Carter 140 14.97%

Sullivan 104 11.12%

Unicoi 242 25.88%

Washington 395 42.25%

Total in ROI 881 94.22%

Total Employees 935 100%

Source:

NFS Department of Human Resources December 2022 Table 14 (Population Distribution and Percent Employment by NFS in Region of Interest) provides the population breakdown by County and the NFS current employment percent in each of the Counties. The total population in the ROI is 367,333 (USCB 2021). NFS provides for approximately 0.19% of the regional employment. Unicoi County has the largest percentage, at 1.12%.

Table 14. Population Distribution and Percent Employment by NFS in Region of Interest County Number Percent of Employment by NFS Carter 56,134 0.17%

Sullivan 159,265 0.05%

Unicoi 17,698 1.12%

Washington 134,236 0.24%

Total in ROI 367,333 0.19%

Source:

U.S. Census Bureau, Census 2021 QuickFacts Table 15 (Selected Demographic Characteristics for the NFS ROI) summarizes certain demographic characteristics for the ROI. The data was obtained from the U.S. Census Bureau (USCB 2021).

Table 15. Selected Demographic Characteristics for the NFS ROI Carter Sullivan

(%)

'(%) (%) (%) (%)

White 95.8 94.6 96.8 91.2 93.6 Black or African America 1.8 2.5 0.6 4.4 3.0 Hispanic or Latino (of any race) 2.2 2.3 6.1 4.0 3.1 American Indian and Alaska Native 0.04 0.4 0.7 0.5 0.4 Asian 0.04 0.8 0.3 1.6 1.0 Native Hawaiian and other Pacific 0.00 0.1 0.00 0.1 0.1 Islander Two or more races 1.5 1.7 1.5 2.2 1.8 Median household money income c $44,280 $49,661 $47,610 $52,503 $48,514 b Total 2021 Population c 56,134 159,265 17,698 134,236 367,333 Notes:

  • Totals may add up to more than the total population (100%), because individuals may report more than one race.

b Average median household money income for the ROI counties.

Source:

< U.S. Census Bureau, Census 2021 QuickFacts 29

21T-23-0212

  • Revision 1 3.11 PUBLIC AND OCCUPATIONAL HEALTH 3.11.1 Background Radiation Exposures All residents in the vicinity ofthe NFS Erwin Facility are exposed to background radiation from a variety of natural and man-made sources. The major sources of background radiation exposure in the vicinity of the Facility are shown in Table 16 (Background Sources of Radiation Exposure).

Table 16. Background Sources of Radiation Exposure Source CEDE (mrem/yr)

Cosmic radiation 27 External terrestrial radiation 28 Internal terrestrial radiation 39 Radon in homes 200 Diagnostic X-rays and nuclear medicine 52 Weapons test fallout <1 Air travel 1 Consumer and industrial products 10 Total 358 Note:

CEDE= Committed effective dose equivalent Source:

NCRP 93 3.11.2 Background Radioactivity NFS' routine radiological surveillance program includes determining the local background level of radioactivity in media that could potentially be affected by Facility operations. Table 17 (Alpha Background Radiation and Alpha Radioactivity in Vicinity of NFS Erwin Facility) presents data for background monitoring locations from NFS' surveillance program.

Table 17. Alpha Background Radiation and Alpha Radioactivity in Vicinity of the NFS Erwin Facility Station Media Background Level

--i Ambient air 3.12 x10- 5 pCi/1 Asheville Highway Soil 45.32 pCi/g Vegetation 3.95 pCi/g --<

Water 0.517 pCi/1 Martin Creek Upstream Sediment 15.27 pCi/g

--i Water 1.53 pCi/1 Nolichucky River Upstream Sediment 21.53 pCi/g Groundwater (Well 52) Water 0.63* pCi/1 Note:

'Gross alpha data 2009-2016. From 2017 to present radiological data is isotopic data.

Source:

NFS Environmental Data Management System 30

21T-23-0212 Revision 1 3.12 WASTE MANAGEMENT 3.12.1 Liquid Waste Liquid waste is treated, measured, and sampled. When all parameters are in accordance with the NPDES Permit and 10 CFR 20 the waste effluent is released. The processes are described in Section 2.1.2.

3.12.2 Solid Waste

  • Non-Radiological/Non-Hazardous - Non-Radiological/Non-Hazardous solid waste (such as waste oil and paper) is shipped off-site for treatment, recycling and /or disposal at appropriate facilities.
  • Radioactive Solid Waste - The disposal and storage of radioactive solid waste is described in Section 2.1.2.

3.12.3 Hazardous and Mixed Waste

  • Hazardous Waste - The disposal and storage of hazardous solid waste is described in Section 2.1.2 (Non-Radiological/Hazardous Waste).
  • Mixed Waste - The disposal and storage of mixed solid waste is described in Section 2.1.2.

31

21T-23-0212 Revision 1 4.0 Environmental Impact of Proposed Action and Alternative 4.1 LAND USE IMPACTS Land use on-site (as described in Table 3) is not anticipated to change significantly in the near future if NFS' SNM-124 license is amended. All major operations will continue to be conducted within the NFS Erwin Facility's Protected Area, with the exception of certain environmental remediation projects. The proposed license amendment will not impact land use at the Facility.

Off-site land use will not be affected by continued licensed operation or the license amendment.

Emissions, both chemical and radiological, to air and water have been shown to have an insignificant effect on local air and water quality ..

The alternative to license amendment would not impact land usage at the NFS Erwin Facility. However, because the work would have to be conducted elsewhere, not amending the license would likely require land use impacts at another site resulting from construction and start-up activities, since other currently available licensable facilities are limited.

4.2 TRANSPORTATION IMPACTS The transportation of radioactive material to and from the NFS Erwin Facility is not anticipated to change due to the license amendment. Currently, over 1,200 personnel work at the NFS site (combination of NFS employees and contract staff). The incremental impact of the Proposed Action will not significantly increase the current level of traffic due to personnel vehicles or material transport. Transportation routes will not change for construction or operation of the Proposed Action. The quantities and types of materials will not significantly change, and there will be no additional entrances for construction. There is estimated to be 30-50 additional personal vehicles to support construction activities and 50-90 personal vehicles distributed over three eight-hour shifts Monday through Friday (approximately 17 to 30 vehicles at the beginning of the shift) for facility operations. NFS staggers shift start times in 30-minute segments to min.imize traffic impacts and allow for security access.

The alternative to the SNM-124 license amendment would result in the transportation of authorized special nuclear materials to an alternative site which could result in some impacts to transportation routes.

4.3 GEOLOGY AND SOIL IMPACTS License amendment will not negatively impact the geology or seismology of the NFS Erwin Facility. No major land use changes exist that will adversely affect geology or soil on the Facility.

The alternative of not amending the SNM-124 license to include the Uranium Purification and Conversion Services will result in the work having to be conducted elsewhere, resulting in potential impacts to geology and soil from construction, since other currently available licensable facilities are limited.

32

21T-23-0212 Revision 1 4.4 WATER RESOURCES IMPACTS.

Due to the operations and controls already established at NFS, the impact of the additional Uranium Purification and Conversion Services process on liquid effluent and/or runoff will be minimal. The amount of additional runoff due to the Uranium Purification and Conversion Services process will be minor compared to that of the existing NFS Erwin Facility. The proposed process will not generate any new chemical or radiological attributes with the potential to enter surface waterways. Liquid effluent sampling or treatment will not require any changes to support the Uranium Purification and Conversion Services process.

The volume/amount that NFS discharges will not significantly increase. Therefore, the NPDES permits for the WWTF (TN0002038), Storm Water (TNR050873), and Industrial Storm Water (TNR050873) will not require modification to support the Proposed Action.

In addition, NFS will be evaluating the construction activities for the new process. If an area of land greater than one (1) acre is disturbed, then it may become necessary to apply for a Storm Water Construction Permit, however this is not anticipated. If construction is held to less than 1 acre, then storm water controls will be governed by the current NPDES permit. The NFS Storm Water Pollution Prevention Plan (NFS-GH-906) will be revised to include information concerning the construction of the Utility Building.

This plan is revised annually to capture any change to the plant site.

Background radiological concentrations in surface water are compared with downstream concentrations, which are measured against the regulatory limit of 300 pCi/1 in 10 CFR Part 20. The comparison is shown in Figure 5 (Radiological Surface Water Quality). The data in Figure 5 consist of total uranium concentrations in Martin Creek Upstream, Martin Creek Downstream, Nolichucky River Upstream and Nolichucky River Downstream for years 2009-2020. The data indicate that the radiological concentrations in surface water are below the 300 pCi/1 limit with the highest concentration of 30 pCi/1 (Martin Creek Downstream) being an order of magnitude less that the regulatory limit.

The 2009 Environmental Report identified no significant chemical impacts to surface water from the NFS Erwin Facility, as compared to Federal and State Drinking Water standards. Collection of surface water chemical data was terminated in 2003, because the statistical background of this data demonstrated no significant trends or changes due to plant operation.

33

21T-23-0212 Revision 1 Figure 5 Radiological Surface Water Quality Regulatory Limit 300 ,,,.

250 ,,,.--

200

i 150 '

~ 100 ,.,

uC.

so /

a ~ ~~.,__ _GL JL...-;.;;[l_, J1l= .EL_ ..J1_ @1 _rii...-

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Year Source: NFS Environmental Data l!ll Martin Creek Up Martin Creek Down Nolichucky River Up Nolichucky River Down Management System 2009-2020 Data Operations at the NFS Erwin Facility resulted in the presence of radionuclides and organic constituents in the groundwater beneath the Facility. The primary sources of contamination were: i) three unlined surface impoundments (formerly Ponds 1, 2, and 3), ii) the "Pond 4" disposal area and iii) radiological burial grounds, all of which were located in the northern portion of the Facility (GMI 1996) in an area referred to as the "North Site". For remediation purposes, the primary groundwater contaminants of concern (COCs) include tetrachloroethylene (PCE), uranium (U), and technetium (Tc-99). Bioremediation of PCE has created byproduct contaminants including trichloroethylene (TCE), 1,2-dichloroethylene (1,2-DCE), and vinyl chloride (VCI). NFS has completed corrective actions involving the excavation, transport, and removal of over 5 million cubic feet of contaminated soil and debris to remove PCE, Tc-99, and uranium sources at the North Site. In 2018, NFS obtained NRC concurrence that final status survey requirements were achieved at the North Site for subsurface and surface soil. NFS is currently continuing corrective actions to address the residual groundwater contamination remaining now that the main contributing sources have been excavated and removed.

There are no known users of the groundwater between the NFS Erwin Facility and the Nolichucky River.

Groundwater collected in monitoring wells on the down-gradient (Plant west) boundary indicates that TCE, PCE, 1,2-DCE and VCI periodically exceed drinking water standards at one or more locations near the western boundary. NFS is actively working to remediate the off-site plumes and has achieved significant plume reductions. The goal of groundwater remediation is to meet the EPAs drinking water MCLs for all the COCs.

PCE levels are measured above MCLs in wells near the down-gradient boundary of the NFS Erwin Facility.

Groundwater modeling has shown that contamination from the Facility should have no impact on the local drinking water supply well. The Erwin Utilities' "Railroad Well," located approximately one mile northeast of, and cross-gradient from, the Facility is the local drinking water supply well for a portion of the Town of Erwin that includes the NFS Erwin Facility. The capture zone for this water supply well does not appear to intersect the simulated contaminant plume from the Facility. Uranium monitoring indicates that uranium does not appear to be migrating off-site and that source removal actions and groundwater bioremediation has had a significant impact on shrinking the uranium plumes at the North Site.

34

21T-23-0212 Revision 1 Excavation required for the new Utility Building foundation, subsurface utility lines, and new stack foundation will not exceed approximately eight (8) feet, and subsurface utility lines will be connected to the current plant systems (e.g., city water, city sewer, fire main). Groundwater is not expected to be impacted by either construction or normal process activities as it has historically been measured at depths greater than 10 feet below the ground surface in the proposed construction area. The groundwater monitoring wells will be continually maintained, and measurements reviewed periodically during NRC inspections.

There are no jurisdictional wetlands located on the NFS site and none will be impacted by the Proposed Action.

4.5 ECOLOGICAL RESOURCES IMPACTS The proposed license amendment will not result in significant land use changes at the NFS Erwin Facility or adversely impact plant or animal communities. More specifically, there will be no impacts to state or federal listed threatened or endangered species habitats. The Proposed Action and all associated ground disturbance will take place within previously disturbed areas within the Protected Area.

Natural, undisturbed, or ecological sensitive areas will not be affected by the proposed action during construction or operation.

Process water discharges (from the NFS WWTF) are only to the Nolichucky River. Since the NFS discharges are consistently in compliance with its NPDES permit, and since the input represents less than 1% of the flow volume of the river, the potential ecological impact is minimal. The proposed license amendment will not increase the potential for negative ecological impacts from process water discharge.

Storm water discharges enter the off-site environment at Banner Spring Branch and Martin Creek. These discharges have no process water content and no potential for significant radiological or chemical effect on the ecology of the creek or spring. Storm water associated with the Proposed Action will be managed in the same way as other storm water at the NFS Erwin Facility and will discharge to Martin Creek. During construction, Best Management Practices (BMPs) and erosion and sediment control measures consistent with TDECs Erosion and Sediment Control Handbook will be installed prior to any ground-disturbing activities and will remain in place until final restoration of the site. BMPs utilized may include, but are not limited to, scheduling a sequence of construction, proper vehicular maintenance, designated storage areas, use of check dams (as needed), silt fencing, and crane pad stabilization.

The alternative of not amending the SNM-124 license to include the Uranium Purification and Conversion Services will result in the work having to be conducted elsewhere, resulting in potential impacts to ecological resources from construction at another location, since other currently available licensable facilities are limited.

4.6 AIR QUALITY IMPACTS The radiological air quality impact is depicted in Figure 6 (2009-2020 Off-site Radiological Ambient Air Quality). Figure 6 shows monitoring results for both the background location (Asheville Highway) and the off-site locations in the near vicinity of the NFS Erwin Facility. As depicted by Figure 6, the radioactivity 15 levels at the designed monitoring stations are less than the internal NFS average action level of 5.0 E-35

21T-23-0212 Revision 1 uCi/ml and the 10 CFR 20 regulatory limit of 5 E- 14 microcurie per milliliter (uCi/ml). As shown by Figure 6 the effluent concentrations in the vicinity of the NFS Erwin Facility are typically a factor lower than the regulatory limit.

NFS is not a "major source" of air contaminants (radiological or non-radiological). In addition, many of NFS' emissions are further reduced by the use of effluent control equipment, which minimizes the amount of air contaminants that reach the environment. As demonstrated by Table 21 (Permitted and Actual Emissions of Criteria and Hazardous Air Pollutants), NFS' actual emissions of air contaminants are significantly less than its permitted emissions. Accordingly, NFS' emissions of non-radiological air contaminants do not have a significant impact on local air quality.

Figure 6 2009N2020 Average OffNsite Radiological Ambient Air Quality SE-14 .r----------------------------------

Regulatory Limit E 4E-14 u:::,

3E-14
c 0.
}_* 2E-14 V'>

V'>

0 fl5 lE-14 o ;a..._",:a~~~~~-===-=-:.&:::"D-El.:a-ic:r~~-~-=-::.-

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 YEAR If Little Mountain ml Asheville HWY  ;:J Stalling Ln. Highland Ave./lst St.

Spar Mill Rd. Images West Training Center Source:

NFS Environmental Data Management System To support the Uranium Purification and Conversion Services process, a new air emission unit equipped with an air control device system will be installed. Installing a new system required that NFS evaluate the potential gaseous and particulate emissions to determine the impact to the environment. In addition to the Proposed Action, this new emission point will be supporting emissions from the current BLEU Preparation Facility (BPF) Bldg. 333 operations and a recently approved insignificant emissions unit for Advanced Pilot Line (APL) operations. The emission calculations for this new source considers all three (3) operations. Currently both BPF and APL planned emissions are released through a permitted stack system. Once the new emission unit and control device system is completed, a permit modification request will be submitted to remove these sources from the current permitted stack prior to the new system becoming operational.

NFS calculated the potential emissions from the source to the public and determined it to be less than five tons per year of each chemical air contaminant and each regulated air pollutant that is not a hazardous air pollutant, and less than 1,000 pounds per year of each hazardous air pollutant. The 36

21T-23-0212 Revision 1 potential to emit emissions include Particulate (0.05 tons/year), Carbon Monoxide (1.7 tons/year, NOx (2.4 tons/year), Nitric Acid (1.3 tons/year), Ammonia (2.3 tons/year), and Hydrogen Fluoride (0.24 tons/year).

A conservative estimate of the radiological emissions and the effective dose equivalent to the most exposed member of the public is 0.005 mrem/year. NFS calculated the potential emissions from the source to the public and determined it to be equivalent to less than 0.1 millirem per year (mrem/yr.).

Of the total Particulate emissions (0.05 tons/year), 10% is expected from the Uranium Purification and Conversion Services process. Plant wide, the estimated particulate emission is approximately 18 tons/year. The addition of particulates from the Uranium Purification and Conversion Services process equates to an increase of 0.025%.

All potential gaseous emissions are summarized in Table 18 below.

Table 18. Gaseous Emissions

):mission Total BPF APL Uranium Purification (tons/yr) (tons/yr) (tons/yr) and Conversion Services (tons/yr)

Particulate 0.05 0.04 0.00 0.004 Carbon Monoxide 1.7 - - 1.7 NOx 2.4 1.07 0.09 1.23 Nitric Acid 1.3 1.16 0.00 0.17

~mmonia 2.3 - 0.01 2.29 Hydrogen Fluoride 0.24 - - 0.24 As defined in parts 1200-3-9-.04(4)(a) and 1200-3-9-.04(4)(d)9 of the Tennessee Air Pollution Control (TAPC) Regulations, all gaseous emissions fall within the bounds of "Insignificant Emission Source."

Process off-gas and room ventilation streams are filtered with high efficiency particulate air (HEPA) filters before passing to the process scrubber and emission stack.

NFS submitted a request to the State of Tennessee, Division of Air Pollution Control for a permit exemption for an insignificant emission unit designation per the TAPC Regulation noted above on 13 June 2022. TDEC responded requesting additional information which was provided on 3 October 2022. If this designation request is not granted by TDEC, then a new construction permit will be obtained for the Proposed Action.

There are no Prevention of Significant Deterioration (PSD) Class I areas (as defined by 40 CFR § 52.21) within two (2) miles of the NFS site and therefore, no impacts to Class I areas are anticipated.

4.7 NOISE IMPACTS The amendment of the SNM-124 license for the proposed action will not increase noise levels associated with the construction and operation of the new Utilities Building (Building 389). It is anticipated that noise levels during construction will be similar to the current noise levels of ongoing operations and remedial activities occurring at the NFS Erwin Facility. The alternative to license amendment, however, is likely to 37

21T-23-0212 Revision 1 increase noise levels at an alternative site as a result of construction and operation of a new facility, since other currently available licensable facilities are limited.

4.8 HISTORIC AND CULTURAL IMPACTS Under the license amendment alternative, operations at the NFS Erwin Facility would continue essentially as they are today with respect to historic and cultural resources. All construction will occur in previously disturbed areas within the Protected Area. If an artifact is uncovered, an unanticipated discoveries plan would be implemented, and applicable agencies would be notified for further investigation.

The effects considered include those resulting directly from land disturbance during construction, visual intrusion on the settings or environmental context of historical structures, visual and audio intrusions on Native American sacred sites, reduced access to Native American traditional use areas, unauthorized artifact collection, and vandalism.

No current or potential impacts to potentially significant pre-historic, historic, or cultural resources have been identified by NFS.

Under the alternative to license amendment, a new facility would likely have to be constructed at an alternative location, since other currently available licensable facilities are limited. The presence of historic and cultural resources at an alternative site would have to be evaluated and, if present, could be potentially impacted.

4.9 VISUAL/SCENIC RESOURCES IMPACTS The license amendment, including actions or physical attributes of the Proposed Action, during either construction or operation, will have no impact on visual/scenic resources. New construction will occur within previously developed areas ofthe NFS Erwin Facility and will be comparable in character to existing infrastructure at the Facility. As such, any construction during or resulting from license amendment will not significantly alter views from surrounding areas. A new stack (height of 85 feet and a tapered diameter of 46 inches at the base and 32 inches at the top) is planned for the Utility Building.

However, it will replace an existing stack (height of 75 feet and a tapered diameter of 32.125 inches at the base and 27 inches at the top) and be of similar appearance and construction. The new stack will be located within 15 ft of the existing stack and the existing stack wi.11 be removed.

I A 60-foot crawler crane will be used to replace HVAC units on the roof of Building 301 and to assist in the construction of Building 389. The crane will be utilized for a short duration and will need to be removed to allow for continued construction. This type of crane has been utilized by the site for prior work activities.

The new Utility Building is of equivalent height to the adjacent existing process facility; approximately 30 feet high (above finished floor) on the east side and 28 feet high on the west side (monosloped roof).

There is a nearby structure adjacent to the roof of Building 301 that extends to a height of 62 feet; this is one of the tallest structures on the NFS Erwin Facility. The roof of Building 301 is at the same height as an equipment platform that will span the distance between Building 301 and Building 389. The roof of Building 389 is approximately 15 feet higher than the roof of Building 301, however is of similar height to 38

21T-23-0212 Revision 1 other adjacent structures. The equipment platform will house the HVAC blowers associated with the scrubber (located in Utility Building 389), a 12-ton chiller unit and several small roof top units (RTUs);

additionally, several pipe chases will span the distance between Utility Building 389 and Building 301 suspended from the bottom of the equipment platform. The elevation of the equipment on the platform will not extend higher than the roof height for Utility Building 389.

Since the development of the 2009 ER, the main discharge stack was replaced within the protected area in 2014. The location and height of the new stack did not change, however, the diameter of the new stack (54 inches) is slightly smaller than the previous stack (60 inches). Otherwise, no other changes that have occurred since 2009 have presented any significant or adverse change to the visual character of the surrounding community. The alternative of no license amendment could potentially impact visual and scenic resources at an alternative site depending on the specific site characteristics.

4.10 SOCIOECONOMIC IMPACTS Employment at the NFS Erwin Facility has remained relatively steady since 2009 as shown in Table 19 (NFS Annual Employment).

Table 19. NFS Annual Employment Year No of Employees 2009 809 2010 762 2011 748 2012 731 2013 708 2014 705 2015 714 2016 706 2017 707 2018 703 2019 719 2020 732 2021 734 2022 935 Notes:

Totals do not include temporary and part-time workers 2009-2020 is as of Dec. 31 2022 data is as of December 11 Increase in personnel between 2021 and 2022 represents a number of contract staff transitioning to BWXT employees The projected 2022 employment is approximately 935 individuals. The unemployment rates for the ROI from April 2020 to April 2021 are described in Table 20 (ROI Unemployment Rate).

39

21T-23-0212 Revision 1 Table 20. ROI Unemployment Rate April 2020 April 2021 Change ROI

(%) (%) (%)

Carter County 12.4 4.6 -7.8 Sullivan County 14.4 4.7 -9.7 Unicoi County 13.0 5.9 -7.1 Washington County 13.2 3.9 -9.3 Sources:

Tennessee Department of Labor & Workforce Development, July 2021 These rates likely reflect the impact of the COVID-19 pandemic, however, NFS employment was not impacted by the pandemic.

NFS estimates the Proposed Action will add 30-50 additional jobs during construction above current staffing, which will fluctuate .. Operation of the Proposed Action could produce 50-90 additional jobs for the site. Current contract projections indicate a reduction in workforce associated with the loss of the downblending scope; the addition of the jobs as a result of the Proposed Action will offset this potential downsize. If this offset were to occur, there would be no net effect on housing, the job market or the school systems within the immediate area of the NFS Site. If the positions associated with the Proposed Action were required to be filled from external candidates, NFS preferentially recruits from the local population; the added operations positions associated with the Proposed Action will follow this same methodology.

The average per capita income in Tennessee in 2021 was $32,908. Table 21 (2017-2021 ROI Per Capita Income) shows the per capita income in 2021 dollars for the ROI. The average NFS 2021 salary is $96,100 (with benefits) or $73,350 (without benefits), which greatly exceeds the ROI per capita income. This demonstrates NFS' positive influence on the socioeconomics of the ROI.

Table 21. 2017-2021 ROI Per Capita Income (in 2021 dollars)

Counties Income Carter $25,267 Sullivan $31,300 Unicoi $25,670 Washington $32,225 Source:

U.S. Census Bureau Quick Facts 2021 The job market in Unicoi County and the surrounding area would not be impacted by either the construction or operations phase of the Proposed Action; the addition of personnel available for employment associated with employees of the Proposed Action are anticipated to be a portion of the total number of personnel actively working. This would be less than 100 potential candidates entering the job market in a large area.

Housing availability in Unicoi County and the surrounding area (e.g., Johnson City, Gray, Jonesborough, Asheville, NC} provides for local housing options. The addition of less than 100 employees and associated family members would not make housing options any more or less available than the current housing market. Additionally, the addition of less than 100 employees and associated family members would not be anticipated to drive housing prices higher than current market rates.

40

21T-23-0212 Revision 1 The school system local to the NFS Site is a county wide school system (Unicoi County); however, children of NFS employees are enrolled throughout several surrounding school systems in addition to Unicoi County. A portion of the employees associated with the Proposed Action would have students; even if all the employee's students were enrolled in the Unicoi County School System, they would not all be in.the same grade and would not represent an overwhelming impact on the local school system.

The addition of jobs associated with either construction or operations are not expected to impact the housing, job market, or school system within the immediate area.

Under the "No Amendment Alternative,'1 the potential exists for a portion of the current 935 NFS employees to lose their jobs, as the only confirmed operational activity would be naval fuel production.

This would further increase the unemployment rate as well as negatively impacting the tax revenues in the ROI. The Counties within the ROI would experience negative socioeconomic impacts due to NFS downsizing.

4.11 ENVIRONMENTAL JUSTICE NFS, in accordance with the NRC's Environmental Justice Strategy (NRC 1995) and Executive Order 12898 (EXO 1994), has evaluated whether any of its programs, policies and activities have disproportionately high and adverse effects on low-income and minority populations.

4.11.1 Local Minority and Low-Income Population Information The local minority and low-income populations in Carter, Sullivan, Unicoi, and Washington Counties and demographic characterizations are shown in Table 15. The total minority population in the ROI represents 27.4% of the total population. The area surrounding the NFS Erwin Facility is predominately non-minority.

NFS provides approximately 0.19% of the regional employment within the ROI. Table 12 identifies Carter County (19.3%), Unicoi County (15.8%), and Washington County (15.8%) with the highest percent of individuals living below the poverty level. Washington County population is the most positively influenced by the NFS employment trends.

Review of the above socioeconomic data and land use information demonstrates that no disproportionate adverse economic impact to the minorities or low-income population in the ROI will occur from this license amendment.

4.11.2 Evaluation of Disproportional Impacts Any impacts to the communities surrounding the NFS Erwin Facility would most likely be the result of hazardous and/or radioactive air emissions or accidents. No significant adverse human health or environmental impacts have been identified by NFS as being associated with its activities. In addition, NFS facilities are designed with extensive safeguards to prevent accidents, and should an accident occur, no acute health impacts would be expected to result. Because the area surrounding the Facility is predominately non-minority and is not low-income, significant adverse human health or environmental impacts, if any, would not disproportionately affect minority or low-income populations.

41

21T-23-0212 Revision 1 4.12 PUBLIC AND OCCUPATIONAL HEALTH IMPACTS 4.12.1 Non-radiological Impacts No routine monitoring is currently required for non-radiological constituents. However, Table 22 (Permitted and Actual Emissions of Criteria and Hazardous Air Pollutants) estimates the NFS contribution of pollutants to ambient air. Table 22 demonstrates that the estimated concentrations comply with applicable guidelines, regulations, and permits.

Table 22. Permitted and Actual Emissions of Criteria and Hazardous Air Pollutants Emission Limitations Pollutant (tons/yr)

Actual Allowable Particulate 0.339 16.98 Sulfur dioxide 0 .0204 10.25 Carbon monoxide 2.921 14.62 Volatile organic compounds 2.8 12.39 Nitrogen oxides 15.554 45.90 Hydrogen chloride 0 .467 1.43 Mercury 0 .00002 0.00002 Ammonia 1 7.466 74.31 Nitric Acid 0.361 0.363 Note:

Air permit monitoring for the following attributes is no longer required: Hydrogen Fluoride, Vinyl Chloride, Tetrachloroethylene, Trichloroethylene, and Bis-2-ethylhexylphthalate.

"Actual" values are based upon calculations provided to the State of Tennessee as part of the air permit applications.

Source:

2021 NFS Air Permits Surface Water Three (3) surface water bodies that are potentially affected by NFS Erwin Facility operations are: Banner Spring Branch, Martin Creek and Nolichucky River. Historical data associated with these water bodies has identified (2009 Environmental Report) that water quality and sampling data are below National Primary Drinking Water Standards and demonstrate no significant trends or changes due to Facility operations.

The chemical monitoring of these water bodies was discontinued during the second half of 2003, because the statistical background of this data demonstrated no significant trends or changes due to plant operation.

Soil and Vegetation No routine monitoring of soil and vegetation is conducted for chemical parameters.

Groundwater NFS has conducted groundwater investigations, remedial actions on groundwater, and routine monitoring since 1990 in conjunction with its Resource Conservation and Recovery Act (RCRA) Part B Hazardous and Solid Waste Amendment (HSWA) Permit. Routine monitoring is performed for AOC 42

21T-23-0212 Revision 1 groundwater which is mainly focused on the down-gradient border of the Facility property. As part of the routine groundwater monitoring program required by SNM-124, 13 wells are routinely sampled and analyzed for radiological parameters on either a quarterly or monthly basis. Additional wells (the number varies from ~2s-12s in any given year) are monitored annually by the groundwater remediation contractor to determine the effectiveness of groundwater remedial actions across the Facility. A summary of this monitoring and remediation progress is shared and discussed with TDEC Hazardous Waste Management Division at the annual facility action plan workshop and additionally is captured in a Facility Action Plan (FAP) document that is updated and submitted after the annual meeting.

4.12.2 Radiological Impacts Pathway Assessment: Air, Soil Vegetation, Sediment, and Surface Water Tables 23A-23F present the annual average environmental surveillance program data for 2009-2020:

Table 23A (2009-2020 Environmental Air Average Gross Alpha Radioactivity), Table 23B (Stream Sediment Average Radioactivity 2009-2020), Table 23C (Soil Average Radioactivity 2009-2020), Table 23D (Vegetation Average Radioactivity 2009-2020), Table 23E (Martin Creek Downstream Average Radioactivity 2009-2020) and Table 23F (Nolichucky River Downstream Average Radioactivity 2009-2020).

There are no impacts above criteria to the air, stream sediment, soil, vegetation or surface waters as indicated in the tables below. These tables do not include data associated with samples collected within the Plant Protected Area, which are not representative of off-site conditions.

43

21T-23-0212 Revision 1 Table 23A. 2009-2020 Environmental Air Average Gross Radioactivity Sampler Station/ 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 location (uCi/ml) (uCi/ml) (uCi/ml) (uCi/ml) (uCi/ml) (uCi/ml) (uCi/ml) (uCi/ml) (uCl/ml) (uO/ml) {uCi/ml) (uCi/ml) 171-Perimeter W 1.61E-15 1.82E-15 1.70E-15 1.31E-15 1.24E-15 2.12E-15 2.SSE-15 l.68E-15 1.SlE-15 1.37E-15 1.67E-15 l.75E-15 174-Perimeter E #1 l.57E-15 l.62E-15 1.48E-15 1.27E-15 1.45E-15 2.45E-15 2.71E-15 1.78E-15 1.SSE-15 1.28E-15 1.88E-15 1.76E-15 322-Little Mountain 1.30E-15 1.57E-15 1.62E-15 1.22E-15 1.20E-15 2.38E-15 2.S0E-15 1.61E-15 1.43E-15 1.37E-15 1.65E-15 1.78E-15 323-Banner Hill Road 1.46E-15 1.61E-15 l.67E-15 1.33E-15 l.45E-15 2.42E-15 2.58E-15 1.68E-15 1.54E-15 1.56E-15 1.90E-15 1.76E-15 324-Asheville Hwy. 1.17E-15 1.60E-15 1.45E-15 l.lOE-15 1.23E-15 2.27E-15 2.67E-15 1.65E-15 l.SlE-15 6.65E-16 l.75E-15 l.66E-15 372-Parking Lot Entrance 1.49E-15 1.81E-15 1.70E-15 1.40E-15 1.16E-15 2.44E-15 2.79E-15 1.64E-15 1.SlE-15 1.S0E-15 2.02E-15 1.65E-15 381-BH Road/Stalling l.66E-15 l.77E-15 1.49E-15 1.30E-15 l.29E-15 2.47E-15 2.82E-15 1.59E-15 1.48E-15 1.34E-15 1.94E-15 1.65E-15 Notes:

Air Sampler 170 was removed from service at the end of 2014.

Air Sampler 172 was removed from service at the end of 1st half of 2016.

Air Sampler 218 was removed from service at the end of 2012.

44

21T-23-0212 Revision 1 Table 238. Stream Sediment Average Radioactivity 2009-2020 Martin Creek Down Linear Nolichucky River Nolichucky River Martin Creek RR Trestle Martin Creek Upstream Park Downstream Upstream Year Gross Gross Total Gross Gross Total Gros~ Gross Total Gross Gross Total Gross Gross Total Alpha Beta u Alpha Beta u Alpha Beta u Alpha Beta u Alpha Beta u (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) 2009 11.36 13.46 2.23 12.30 15.70 4.16 6.20 7.27 0.63 27.43 25.15 2.22 6.51 17.38 1.30 2010 14.08 22.58 2.29 16.19 13.31 4.17 6.82 10.26 1.02 12.18 18.90 2.14 8.25 17.50 2.16 2011 9.88 16.28 2.75 10.20 9.58 3.05 9.30 7.71 0.89 9.57 18.18 1.75 6.85 22.15 1.03 2012 20.33 20.73 2.28 5.66 7.62 0.86 14.91 21.58 1.46 13.43 39.93 1.28 15.56 17.63 1.07 2013 13.98 18.58 2.90 4.18 6.34 0.82 7.12 5.61 0.87 16.69 20.63 1.89 9.70 17.93 1.31 2014 18.85 19.43 2.05 9.14 12.38 0.88 7.33 12.74 0.77 16.81 20.90 1.41 9.88 20.25 1.04 2015 18.70 27.00 4.09 6.79 6.58 1.62 6.16 9.89 1.00 10.02 20.87 1.55 8.42 16.10 1.38 2016 16.66 23.10 2.09 3.72 7.92 1.45 3.90 6.59 0.92 18.60 22.50 2.19 11.90 17.60 1.48 2017 21.78 18.48 3.37 7.28 9.80 1.03 12.63 9.19 1.23 18.73 23.86 1.22 15.83 21.08 1.19 2018 14.50 17.20 1.84 6.17 8.48 0.95 6.65 9.78 1.00 13.33 19.80 1.13 11.95 17.68 1.28 2019 14.41 12.37 1.18 11.63 7.51 1.09 6.35 9.43 0.54 16.65 19.05 1.11 14.84 20.83 0.81 2020 7.83 9.55 2.03 7.59 9.54 2.25 4.30 6.35 1.03 10.47 18.45 1.24 9.52 14.38 0.98 Note:

Total U = U-233/234 + U-235/236 + U-238 Source:

NFS Environmental Database Management System (EDMS) 2021 45

21T-23-O212 Revision 1 Table 23C. Soil Average Radioactivity 2009-2020 Asheville Highway Banner Hill Road Burial Ground First Street Little Mountain Year Gross Gross Total Gross

  • Gross Total Gross Gross Total Gross Gross Total Gross Gross Total Alpha Beta u Alpha Beta u Alpha Beta u Alpha Beta u Alpha Beta u (pCi/g) (pCl/g) (pCi/g) (pCi/g) (pCl/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCl/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) 2009 22.50 29.80 2.30 19.20 21.93 3.15 19.63 25.45 4.14 16.68 18.93 2.88 14.18 21.40 3.02 2010 15.59 22.80 1.54 22.25 21.50 3.34 21.93 28.90 3.73 18.20 17.48 2.73 15.40 11.48 3.17 2011 14.48 22.70 1.30 22.33 16.74 3.10 19.83 22.03 4.23 17.18 17.58 2.68 15.70 12.94 3.07 2012 25.43 31.13 0.97 24.48 24.20 3.30 25.95 26.73 3.71 24.13 21.28 2.19 17.53 16.56 3.04 2013 23.73 29.95 1.53 21.35 28.35 3.17 21.85 45.85 3.19 18.25 16.73 2.71 24.95 17.61 3.75 2014 23.38 29.63 1.55 27.98 27.65 4.10 20.65 71.53 2.48 22.90 26.03 2.26 23.55 16.73 3.71 2015 21.00 28.75 1.76 28.05 29.88 3.87 26.20 59.15 6.56 20.83 17.90 2.52 18.05 20.70 4.07 2016 22.30 36.78 2.41 26.25 18.20 3.46 36.95 39.15 8.85 21.75 19.05 2.69 20.93 14.88 3.90 2017 29.33 38.60 1.97 28.93 22.43 3.46 26.70 28.25 6.22 33.43 25.00 2.67 24.13 13.58 3.64 2018 28.00 41.88 2.36 27.35 25.13 3.59 23.83 54.88 5.31 23.00 20.00 2.37 22.13 15.83 2.93 2019 25.73 31.20 1.48 28.73 19.58 2.27 26.35 32.65 4.37 22.05 21.75 1.92 21.88 13.78 2.73 2020 20.50 31.33 1.95 21.95 18.45 2.88 22.10 33.53 5.51 20.53 17.65 2.38 22.30 13.45 3.48 Note:

Total U = U-233/234 + U-235/236 + U-238 Source:

NFS EDMS 2021 46

21T-23-0212 Revision 1 Table 23D. Vegetation Average Radioactivity 2009-2020 Asheville Highway Banner Hill Road Burial Ground First Street Little Mountain Gross Gross Total Gross Gross Total Gross Gross Total Gross Gross Total Gross Gross Total Year Alpha Beta* u Alpha Beta u Alpha Beta u Alpha Beta u .Alpha Beta u (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g) (pCi/g). (pCi/g) (pCi/g) (pCi/g) 2009 1.06 16.06 0.22 1.41 14.66 0.16 3.53 15.05 0.07 2.37 34.53 0.28 2.66 17.98 0.14 2010 1.13 12.15 0.29 1.16 18.04 0.36 2.36 24.85 0.40 2.87 15.42 0.65 4.24 16.57 0.36 2011 2.21 14.25 0.29 1.45 15.05 0.18 4.70 15.98 1.08 1.20 15.49 0.26 3.37 17.88 0.56 2012 5.25 18.39 0.21 15.58 34.74 0.17 1.95 22.27 0.45 8.57 26.08 0.15 2.06 18.20 0.10 2013 1.85 12.33 0.13 6.24 25.88 0.52 5.02 23.08 0.44 4.97 18.42 0.34 1.78 20.19 0.13 2014 0.53 9.89 0.25 4.61 29.78 0.59 4.41 25.28 0.75 9.96 30.13 0.58 2.10 20.75 0.14 2015 2.98 15.00 0.46 7.12 20.73 1.16 5.85 27.48 1.05 3.28 23.93 0.65 4.36 23.03 0.29 2016 1.43 27.52 0.60 3.09 22.18 1.04 5.94 17.28 0.86 1.88 28.93 0.80 1.96 19.46 0.49 2017 1.91 23.98 0.22 5.52 34.35 0.50 4.24 19.17 0.66 4.01 30.53 0.32 4.11 19.49 0.28 2018 1.39 21.22 0.54 8.25 24.15 0.65 5.97 25.58 1.74 9.62 36.08 0.45 3.97 22.70 0.57 2019 2.46 15.93 0.20 4.04 23.40 0.44 4.11 23.50 0.74 3.38 26.28 0.25 0.25 16.20 0.12 2020 1.93 20.60 0.14 3.66 24.70 0.33 4.08 20.53 1.13 2.93 29.63 0.29 1.61 12.12 0.09 Note:

Total U = U-233/234 + U-235/236 + U-238 Source:

NFS EDMS 2021 47

21T-23-0212 Revision 1 Table 23E. Martin Creek Downstream -Average Radioactivity 2009-2020 Gross Alpha Gross Beta Total U Year (pCi/g) (pCi/g) (pCi/1) 2009 3.83 2.74 3.51 2010 6.04 3.49 4.75 2011 6.21 3.41 5.36 2012 5.17 2.89 4.57 2013 9.96 3.82 9.45 2014 14.49 4.85 12.49 2015 16.51 5.91 14.33 2016 17.45 4.85 13.80 2017 13.77 4.40 11.28 2018 15.57 5.45 12.40 2019 16.87 5.32 15.03 2020 12.01 5.73 10.49 Notes:

Total U = U-233/234 + U-235/236 + U-238 Based on water samples taken in Martin Creek.

Source:

NFS EDMS 2021 Table 23F. 2009-2020 Nolichucky River Downstream - Environmental Monitoring Data Gross Alpha Gross Beta Total U Year (pCi/g) (pCi/g) (pC:i/g) 2009 0.79 2.53 0.17 2010 1.95 2.27 0.20 2011 0.43 1.46 0.13 2012 0.51 1.26 0.08 2013 0.73 2.22 0.20 2014 0.23 1.68 0.19 2015 0.09 1.24 0.25 2016 0.14 0.99 0.22 2017 0.21 1.28 0.23 2018 1.21 1.98 0.42 2019 1.50 2.26 0.41 2020 0.90 2.71 0.19 Note:

Total U = U-233/234 + U-235/236 + U-238 Source:

NFS EDMS 2021 Pathway Assessment: Groundwater NFS maintains a large array of groundwater monitoring wells. The primary function of these wells is to allow monitoring for COCs including uranium contamination, which is the major radiological constituent of interest for NFS. Some of these wells are included specifically to comply with license requirements to monitor the groundwater in the vicinity of previous activity sites involving contamination sources which have been excavated, packaged, and shipped for disposal.

Other wells are in place to monitor the conditions of groundwater both on- and off-site.

48

21T-23-0212 Revision 1 Public and Occupational Exposure: Public Radiation Exposure As required by NRC regulations, NFS strives to ensure that all releases, emissions, etc., of radioactive material remain "As Low As is Reasonably Achievable" (ALARA). The measured off-site air quality (discussed in Section 4.2) confirms the success of these efforts and that off-site exposure to the public from NFS Erwin Facility radiological emissions is minimal. However, in order to document compliance with federal and state standards for exposure to members of the public, NFS routinely prepares formal estimates of the exposure.

Table 24 (Radiation Exposure to Members of the Public) shows the results for the period 2008 through 2020, as compared to the permissible public exposure limit.

Radiation exposure to members of the public is estimated using local wind speed and direction frequency information, combined with effluent release data. The data are used in standard atmospheric dispersion modeling techniques to estimate the exposures to members of the public. These calculated exposures, based on site-specific data, confirm that exposures to the "maximally exposed individual" consistently remain at only a small fraction of the allowable exposure limit.

Table 24. Radiation Exposure to Members of the Public Year CEDE (mrem) a Percent of Limit b 2008 3.0E-3 0.01 2009 4.9E-3 0.02 2010 6.SE-3 0.03 2011 1.1E-2 0.04 2012 5.9E-3 0.02 2013 7.9E-3 0.03 2014 4.6E-3 0.02 2015 6.4E-3 0.03 2016 6.6E-3 0.03 2017 3.9E-3 0.02 2018 4.lE-3 0.02 2019 3.0E-3 0.01 2020 6.0E-3 0.02 Notes:

'CEDE: Committed Effective Dose Equivalent in mrem from gaseous effluent in the maximally exposed individual b 40 CFR, Part 190, Subpart B, Limit=25 mrem/yr.

Source:

NFS Biannual Effluent Monitoring Report 2008-2020 Amendment of the SNM-124 license will continue efforts to ensure that public exposure remains ALARA and within NRC's limits.

Public and Occupational Exposure: Potential Impact for Accidents Postulated accidents are described in Section 2.0. While NFS recognizes the potential for these types of accidents, the probability of any of them occurring is low due to engineered safety factors incorporated into the process design. NFS process designs incorporate sufficient safety controls to ensure that any accident sequence (radiological or chemical) resulting in high or intermediate consequences meet the performance requirements specified in 10 CFR Part 70.61.

49

21T-23-0212 Revision 1 As discussed in Section 2.0, in conjunction with the NFS Emergency Plan, a detailed analysis of eight (8) potential accident scenarios has been evaluated. While NFS has classified these scenarios as potential, the probability of any of them occurring is low, due to safety factors incorporated into the design of all radiological material related process equipment and systems.

The level of protection against significant accidents is substantiated by review of past incidents. Section 2.0 lists the most significant environmental accidents during recent NFS Erwin Facility history. A review of Section 2.0 indicates no event that significantly threatened the safety of members of the public.

Based on the review of potential accidents, actual environmental releases, and the comprehensive safety programs in place to prevent and minimize the effect of accidents, the probability and potential consequences of any reasonably foreseen significant site-related accident with off-site consequences are both estimated to be low.

Amendment of the SNM-124 license would not significantly impact public safety.

4.13 WASTE MANAGEMENT Waste management at the NFS Erwin Facility is conducted as stated in Section 2.1.2 Radioactive Waste Management, Liquid Waste Storage, Radioactive Solid Waste Management, Mixed Waste Management, Non-Radioactive Hazardous Waste, and Non-Radioactive/Non-Hazardous Waste. General construction debris will be produced due to the construction of the Proposed Action. It is anticipated that approximately 15,000 cubic feet of soil/asphalt/concrete will be packaged for disposal. This waste will be assessed for the presence of hazardous and/or radioactive materials. Based on the results of this evaluation, it will be processed using existing procedures and dispositioned at a licensed waste disposal facility.

Wastes generated (including general job control waste) as result of the new Uranium Purification and Conversion Services process operations will be handled in accordance with existing NFS waste handling procedures. On average, NFS handles and dispositions approximately 950,000 kg of radiological waste, 7,500 kg of hazardous waste, and 230,000 kg of non-hazardous waste annually. During operation of the Uranium Purification and Conversion Services process, it is anticipated that these waste streams will not be significantly impacted. Based onforecasted production rates, the Uranium Purification and Conversion Services process could produce up to 10,000 kg of radiological waste per year. This translates to a 1%

increase in radiological waste production for the entire Facility. It is expected that hazardous and non-hazardous waste generation for this process may have a similar increase. New waste streams will not be generated from the construction or operation of the Uranium Purification and Conversion Services process and all wastes will be processed and dispositioned using existing procedures and waste vendors.

All waste will be handled in accordance with existing NFS waste handling procedures, managed in accordance with all applicable regulatory requirements (NRC, EPA, and DOT), and transported to an approved licensed waste disposal facility. The amendment of the license would not significantly increase the quantities or types of waste generated at the NFS Erwin Facility. The alternative to license amendment would not decrease the volume of waste generated and would only shift the generation of waste to an alternative facility.

50

21T-23-0212 Revision 1 4.14 CONSTRUCTION OF PROPOSED ACTION Construction materials will be transported via flatbed, WB-62 type truck or other standard delivery type truck on the main roadways and access points to the site (Interstate 26 and main site access roads).

Oversized deliveries are not anticipated, and construction materials will be delivered to the site via existing access points and gates; no new construction access points to the Protected Area will be created. Deliveries will be grouped as much as possible to reduce material transport requirements.

Anticipated construction equipment includes a 60-foot crane, backhoe, grader, front loader, trencher, boom truck, lull, concrete trucks, fork trucks and/or compactor.

The construction area supporting the Proposed Action is within an industrial environment (i.e.,

immediate surrounding facilities are industrial in nature). The expected environmental noise generation would be attributed to use of ground moving equipment and crane usage. These types of activities are currently performed at the NFS site on an as-needed basis. The expected use of construction equipment would be intermittent and is expected to last less than six months, aggregate. Construction activities (with exception of equipment and material transport) will occur within the Protected Area, which is surrounded by a 20-foot sand wall that would provide significant noise mitigation to offsite locations. In addition, although the NFS Erwin Facility location is zoned Industrial, in order to accommodate nearby residences, construction activities will typically occur during daylight hours (between 7:00 AM and 6:00 PM} on weekdays, which complies with the Town of Erwin construction time restriction for areas zoned Residential. Following construction, noise levels are anticipated to return to typical site ambient levels (three-year-average of 65 decibels within the Protected Area and 50 decibels in the OCA parking area).

Airborne effluents from construction activities will be typical of industrial settings (e.g., operation of a diesel vehicle). BMPs will be implemented during construction forfugitive dust, which may include, but are not limited to, minimizing ground disturbance, utilizing water and/or street sweepers as necessary, utilizing gravel as backfill until pavement is restored, and maintainingcoverovertrucks transporting backfill materials. With exception of the cut/excavation required for the Utility Building foundation, all work will be conducted on a paved surface; for the foundation and subsurface utility lines, the paved surface will be removed via a wet cut method to reduce fugitive dust. With exception of restoring impacted paved surfaces to allow for trenching and excavation, grinding activities are not anticipated. All building penetrations will be made with a wet cutting device or drill to assist in mitigating fugitive dust.

All excavated soil will be retained and stored on site within a contained area surrounded by erosion and sediment control devices. Representative samples of excavated soil will be obtained to allow for accurate characterization. Contaminated soil is not anticipated. Excavated areas (e.g., foundation) will be backfilled with #57 stone and "crush and run" gravel until foundation work is completed. Crush and run gravel will also be used for a crane pad to allow for stability and drainage. Following construction activities, all surfaces in and around Utility Building 389 and Building 301 will be returned to a paved state and utilize the existing storm water runoff system. Erosion and sediment controls will remain in place until all disturbed areas of the construction site are permanently stabilized.

Minor grading will be required to construct the approximate 3,000 square foot building. Excavation will be to an approximate maximum depth of eight (8) feet below grade. In addition to the foundation work that supports the new Utility Building, subsurface utility lines will be connected to the current plant systems (e.g., city water, city sewer, fire main). Excavations to support the utility lines will be to a depth of approximately three (3) feet. The new stack will also require a foundation; excavation will be to an 51

21T-23-0212 Revision 1 approximate maximum depth of four (4) feet. Subsurface systems, other than utility connections, (e.g.,

supply or retention tanks) will not be installed.

Groundwater is not expected to be impacted by either construction or normal process activities; historically, groundwater has been measured at depths greater than 10 feet below the ground surface.

Groundwater measurements are obtained from groundwater monitoring wells and are documented on monitoring reports that are reviewed during periodic inspections.

Additional on-site fuel storage for construction equipment is not anticipated due to the small scope of the Proposed Action and duration of construction vehicle use; if fuel storage is necessary, secondary containment will be utilized. Furthermore, the site has a Spill Prevention, Control and Countermeasures Plan (SPCC) that will account for activities associated with the construction and operation of the LI-Metal process. Any spills or releases, during construction or operation, will be controlled and mitigated in accordance with site plans and procedures.

SEE CONTROL DOCUMENT OFFICER FOR POSSIBLE ACCESS TO THIS "OFFICIAL USE ONLY" SECTION The chemicals utilized within the Utility Building 389 (e.g., KOH, NaOH, Nitric Acid) are contained within a diked area; applicable deliveries will occur directly to the Utility Building 389 or be hard piped from the site's bulk chemical storage. There are no anticipated accident scenarios in which groundwater would be impacted.

Additional radiological sources are not expected from the Proposed Action during construction and operation. The construction and operation impacts are monitored by a robust and comprehensive routine radiological surveillance program in consultation with TDEC which includes ambient air sampling, dosimeters, and surface water.

4.15 CUMULATIVE ENVIRONMENTAL IMPACT Regional projects large enough to be considered for cumulative impact when combined with the Proposed Action include: the Unicoi County Hospital, constructed in 2018 approximately one and a half (1.5) miles from the NFS Erwin Facility; and a facility purchased by Blue Ridge Paddling in 2022, approximately one (1) mile from the Facility. The combination of the Facility site with these two projects have not created any significant or adverse cumulative impact to the local community or the resource area.

At the NFS site, the BLEU Complex was decontaminated and decommissioned in 2015 to support additional expansion projects. The site was seeded with grass and remains an area available for future project development. A proposed project for a portion of this space is the addition of a warehouse and/or laydown area. If a laydown area were to be constructed, it would involve either asphalt/concrete or "crush and run" gravel.

According to the Tennessee Department of Transportation (TDOT) website, under active and proposed projects, there is only one project scheduled for Unicoi County-the 1-26/Pinnacle Road bridge repair, located approximately seven (7) miles north of the Proposed Action. Lane closures will be in place for the entire duration of the bridge repair. It is anticipated that this project will be completed before the Proposed Action begins; therefore, no additional congestion on 1-26 due to construction of the Proposed Action is anticipated.

52

21T-23-0212 Revision 1 No cumulative impact to the environment from the construction and operation of the Proposed Action in combination with the above identified projects is anticipated. There are no other known projects in progress or forecasted in the resource area.

53

21T-23-0212 Revision 1 5.0 Mitigation Measures Mitigation measures are designed into all process operations and evaluated prior to implementation. NFS strives to control all emissions at the source and to the degree possible to mitigate uncontrolled releases.

NFS' goal is to maintain occupational and public exposure to radioactive material to "As Low As is Reasonably Achievable" {ALARA). The ALARA goal is detailed in Section 4.12 {Public and Occupational Health Impacts).

NFS recognizes the potential for accidents such as those postulated in Section 2.0 {Alternatives). The probability of the accident scenarios described in Section 2.0 occurring is low due to engineered safety factors incorporated into the process designs.

Furthermore, the operational mitigation to reduce the impact to the public incorporates safety factors into the design of radiological material related process equipment. NFS' emissions are reduced by the use of effluent control equipment, which minimizes the amount of air contaminants that reach the environment.

No disproportionate impacts are expected to occur; therefore, no additional mitigative measures are anticipated other than those NFS currently has proposed associated with the Proposed Action as described in Section 1.

54

21T-23-0212 Revision 1 6.0 Environmental Measurements and Monitoring Programs The NFS environmental monitoring program is a comprehensive program that encompasses on-site and off-site environmental surveillance (see Section 4.0). Environmental media monitoring includes air, surface water, sediment, soil, vegetation, and groundwater. Figure 7 (Environmental Air Sample Locations) and Figure 8 (Surface Water Sample Locations) shows the locations where samples of these media type are taken.

6.1 RADIOLOGICAL MONITORING The radiological monitoring program is described in Section 4.0. Chapter 9 of the US NRC License sets forth the requirements of the radiological effluent control and the environmental surveillance and monitoring program at NFS. This includes specific actions to be flowed into operating and sampling procedures; including performing routine measurements and calculations, comparing results to action levels, and reporting the results to plant management and the NRC, as appropriate. The license requires continuous sampling of all process ventilation stacks, collected and analyzed daily for the presence of radioactive material. In addition to point source sampling, NFS is also required to collect ambient air, soil, silt/sediment, vegetation, and groundwater samples from off-site locations. These are collected in areas surrounding the plant-site and based upon prevailing weather patterns.

From a liquid effluent or ambient air standpoint, additional sampling will not be required. The new stack, STACKX-9201, and control system will replace the existing Building 301 stack (Stack 774) and the sample data will be included in the NRC biannual effluent monitoring report. The radiological monitoring program will not be revised as the chemical/radiological attributes are not changing and the method used to perform the monitoring will not change. NFS' routine radiological surveillance program includes sampling of different media that could potentially be affected by NFS Erwin Facility operations.

Based up on this continuous monitoring, a biannual dose assessment for the maximally exposed off-site receptor is completed and submitted to the NRC. The new stack will be located in the same vicinity and will replace the current Building 301 Stack 774. Since the new process will be located within the protected area of the plant and the new stack will be located in the same vicinity as the previous emission point, the Radiological Surveillance program will not require any changes to support the new Uranium Purification and Conversion Services process.

6.2 PHYSIOCHEMICAL MONITORING 6.2.1 Air Ambient concentrations of atmospheric chemical pollutants near the NFS Erwin Facility are not routinely measured. The primary NFS emission source of criteria pollutants is the industrial boiler. The secondary emission source is chemical processing. Table 22 (Permitted and Actual Emissions of Criteria and Hazardous Air Pollutants) presents the currently permitted maximum (allowable) and average actual emissions of chemical pollutants based on permit application information.

The proposed Uranium Purification and Conversion Services process gaseous effluents are listed in Table 25 below. The proposed Uranium Purification and Conversion Services emission source will include BPF 55

_J

21T-23-0212 Revision 1 and APL (as shown in Table 25). With approval from the TDEC, these processes will share new Emission Point, STACKX-9201, and will be governed by requirements issued by the TDEC Division of Air Pollution Control. The gaseous effluents from the proposed Uranium Purification and Conversion Services process are similar in attribute and quantity to those emitted from current operations at the NFS Erwin Facility.

Table 25. Gaseous Effluents from the Proposed Action Uranium Metal Purification and Conversion Process Chemical Name Chemical Formula Nitrogen Dioxide N02 Nitric Acid HN03 Acetic Acid CH3COOH Hydrogen Peroxide H202 Inert Gases (02, N2, Ar) 02, N2, Ar Hydrogen H2 Hydrogen Fluoride AHF Hydrofluoric Acid HF Ammonia NH3 Iodine 12 Nitrous Oxide N20 Carbon Dioxide CO2 Carbon Monoxide co Water H20 Fluoroboric Acid HBF4 Radionuclides U-234, U-235, U-238 Particulate Matter -

BLEU Processing Facility (BPF)

Nitric Acid Vapor HN03 Nitrogen Dioxide Vapor N02 NORPAR 12 -

Tri-butyl Phosphate (C4H9)3P04 Radionuclides U-234, U-235, U-238 Particulate Matter -

Advanced Pilot Line (APL)

Nitric Acid Vapor HN03 Hydrogen Peroxide Vapor H202 Nitrogen Dioxide N02 Ammonia Vapor NH3 Radionuclides U-234, U-235, U-238 Particulate Matter -

6.2.2 Surface Water The NFS WWTF discharges water to the Nolichucky River from Outfall 001. Table 26 (NPDES Outfall Monitoring Data) provides effluent quality data for the NFS WWTF outfall for the period 2009 through 2020. This data indicates discharges from the WWTF consistently comply with the limitations imposed by the NFS NPDES permit.

56

21T-23-0212 Revision 1 Table 26. NPDES Outfall Monitoring Data Mg/I (except as noted)

Effluent Characteristic Average* Maximum COD 181.3 370 TSS 10.01 38 Ammonia (N) 11.38 29 Nitrate/Nit rite 39.38 213.4 Fluoride, Total 2.39 20 Cadmium, Total 0.0008 0.005 Copper, Total 0.007 0.06 Lead, Total 0.0046 0.066 Mercury, Total 0.0002 0.0079 Silver, Total 0.002 0.023 pH 7.8 9 Notes:

' For some constituents, the calculated average is an estimated quantity, which consists of detected values and reported non-detected samples. The average was determined by using the quantitation limit when non-detects occurred; thus, the actual concentrations were probably lower.

Source:

2009-2020 NFS Discharge Monitoring Reports. Where less than values occurred, the absolute value was reported.

NFS NPDES Industrial Storm Water Permit monitors storm water runoff. Compliance storm water sampling is conducted annually, as shown in Table 27 (NFS 2009 - 2020 Storm Water Data). The annual monitoring data identifies nitrate as nitrogen and magnesium in storm water at concentrations above the monitoring State Benchmark concentrations. These two attributes have exceeded the cut-off concentration limit since February 1998. An investigation into the elevated nitrate as nitrogen and magnesium attributes identified that they are natural occurring in surface water and ground water at levels above the NPDES State Benchmark concentration limits. The aluminum and copper contributors are unidentified.

57

2 lT-23-0212 Revision 1 Table 27. NFS 2009-2020 Storm Water Data Outfall A Outfall B Parameter Average Average (mg/I) (mg/I)

Chemical Oxygen Demand 53.84 58.89 pH 7.7 7.4 Total Suspended Solids 37.94 43.2 Nitrate+ Nitrite, Nitrogen 11.38 0.73 Ammonia 0.287 0.455 Magnesium, Total Recoverable 2.29 1.84 Aluminum, Total Recoverable 0.381 0.548 Iron, Total Recoverable 0.438 0.764 Cadmium, Total Recoverable 0.001 0.001 Cyanide, Total 0.0018 0.0018 Lead, Total Recoverable 0.0029 0.0047 Mercury, Total Recoverable 0.0001 0.0001 Selenium, Total Recoverable 0.0075 0.005 Silver, Total Recoverable 0.0008 0.0008 Copper, Total Recoverable 0.0136 0.0216 Gross Alpha (pCi/1) 16.21 25.15 Gross Beta (pCi/1) 9.95 10.39 Isotopic U-234 (pCi/1) 9.28 18.79 Isotopic U-235 (pCi/1) 0.479 0.77 Isotopic U-238 (pCi/1) 1.2 0.437 Temperature (°F) 59.7 60 Notes:

Source: NFS Annual Storm Water Monitoring Reports 2009-2020. Where less than values occurred, the absolute value was reported.

Radiological analysis is not a storm water permit requirement.

Chemical attribute sampling was reduced in 2016 to only include: pH, NO3/NO2, NH3, Mg, Al, Fe, & Cu.

The monitoring program for liquid effluents will not require any changes for the proposed Uranium Purification and Conversion Services process because new radiological and chemical attributes will not be introduced. The NFS Storm Water Pollution Prevention Plan (NFS-GH-906) will be revised to include the new Utility Building.

6.23 Soil and Vegetation No routine monitoring of soil and vegetation is conducted for chemical parameters.

6.2.4 Groundwater NFS has been conducting extensive groundwater investigations since 1990 in conjunction with its HSWA Permit and as part of its ongoing efforts to decommission inactive parts of the NFS Erwin Facility. There are 13 wells routinely sampled and analyzed for various parameters on either quarterly or monthly basis. Additional wells (the number varies from ~2s-12s in any given year) are monitored annually by the 58

21T-23-0212 Revision 1 groundwater remediation contractor to determine the effectiveness of groundwater remedial actions across the Facility. The results of this monitoring are shared and discussed with both the TDEC and NRC.

This monitoring is being done pursuant to requirements of the RCRA Part B HSWA permit. The analytical results are routinely reviewed by the agencies.

The monitoring program for groundwater will not require any changes for the proposed Uranium Purification and Conversion Services process because new radiological and chemical attributes will not be introduced. Groundwater monitoring wells are sampled at a set frequency (i.e., monthly/quarterly) for the presence of radionuclides.

6.3 ECOLOGICAL MONITORING The ecology within the vicinity of the NFS Erwin Facility is described in Section 3.0. The radiological monitoring of air, water, vegetation, sediment, and soil as discussed in Section 4.0 and Section 6.1; and the chemical monitoring of process water discharges and storm water runoff are the key to preserving the ecological health within the vicinity of the Facility. The monitoring programs have not indicated adverse effects to the ecological system.

59

21T-23-0212 Revision 1 Figure 7. Environmental Air Sample locations UNICOI CO.SHERIFF'S DEPT.

ERWIN HEALTH CAQE CENTER U!Gl!ND

  • - Aa llllJU!ll:s Ill PIIIM!l'l!l 11 IU fl!ltllllffl!Ji I lllJ IIIIJIIIIII UL IIOAll,11 ll.\llllliU Im IDWC!ill.lll.LIIO,U),IWli~

a IWMlll Bl. llllAII.AT ll'Ai.1$1J LU:!

1111 Pallll!Q S I mMa Ill JIIIIAL S ~ Ill W PMillffl!I ll 1M 'nrl' o, IJll'IMII N.a:mo wr aomt Ill' LQCl,m, .ll.lml 11m ~ ll:IUlClh\lT Al.o:,"U UI.Uill TIWV 161 PQDIIIQ II

.324 Vf lff 1ft lt'll!U. IIIWlm I BOOAI. CllllJlCII II I ltW,tL ffllllllill N PAST MOUNTAIN INN Ill !llft.OTII l'AUl!la l.01' l!001'lt AND SUITE

  • "llfl'lll'll"AII WH!.l.llll 11111 urn.g JQJIJNTAIN llf Mlll\'UI IIOlll'"Y
  • ff.lLllliB l.l!l'II
  • I!

Mm'iffll!IT 1111 PAI JWJ. IIO,\I Ill 111t11.'fflt\L PIIU AT IIIAlllll Ill Im! ,W!QNO C9IITIII AOMIN!STRATIVE Rl!VIEW

" ' - - - 1 DtwlUIPI Dllltt-'Dtlll.l - - - 1 w

ASTICS --*

NUCLEAR FUEL SERVICES, INC.

ME ~l!._'<!SS:!.f ENVIRONMENTAL Jit{tl ,... 1tR AIR SAMPLE LOCATIONS 60

21T-23-0212 Revision 1 Surface Water Sample Location s ERWIN RHSIN SOLUTIONS il/2121

---10°"'1'-CllOl 0Dfi:w-aP*t _ _ _ ,

LIIDIND M O U N T A I N S w a~...

  • IIWAPI l l ' ~ ~
l?Ull lifflUlll A.'Y ~ A.I'll. NUCLEAR FUEL SERVICES, INC.

t'llm~**--lllfl OllG'<.1°"6S!li I KA&me lllllll-l~UVll- - f i L I I .

-NI,

,~a...-

1 fflVWlr.W.

t ~ OIi ll.lffllCS lUD -

OOO-COUl*B 61

21T-23-0212 Revision 1 7 .O Summary of Environmental Consequences 7.1 ADVERSE IMPACTS Section 4.0 of this report comprehensively describes the direct and indirect environmental impacts of the NFS Erwin Facility's operation, and the environmental justice related impacts. The data indicate that NFS' conduct of licensed activities has, and is expected to continue to have, no significant adverse impact on the people, air, land, water, flora, and fauna surrounding the NFS Erwin Facility.

The potential for significant adverse impacts is considered only for the "No License Amendment" action,

~ecause not amending the license would likely require land use impacts at another site resulting from construction and start-up activities, since the work would have to be conducted elsewhere and currently available licensable facilities are limited. The potential significant adverse impacts from this scenario are:

1. Land Use - The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to land use. Not amending the license would likely require land use impacts at another site resulting from construction and start-up activities.
2. Transportation - The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to transportation routes. The alternative to amending the license would result in the transportation of authorized special nuclear materials to an alternative site which could potentially result in new impacts to transportation routes.
3. Geology and Soils -The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to geology and soils. Conducting the Uranium Purification and Conversion Services elsewhere could result in potential impacts to geology and soils from new construction, since other currently available licensable facilities are limited.
4. Water Resources - The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to water resources. The construction and operation of a new licensable facility could potentially result in new impacts to water resources.
5. Ecological Resources - The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to ecological resources.

Conducting the Uranium Purification and Conversion Services elsewhere could result in potential impacts to ecological resources from new construction.

6. Air Quality - The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to air quality.
7. Noise - The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to noise. The alternative to license amendment is likely to increase noise levels at an alternative site as a result of construction and operation of a new facility.

62

21T-23-0212 Revision 1

8. Historic and Cultural Resources - The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to historic and cultural resources. Under the alternative to license amendment, a new facility would likely have to be constructed at an alternative location, since other currently available licensable facilities are limited. The presence of historic and cultural resources at an alternative site would have to be evaluated and, if present, could be potentially impacted.
9. Visual/Scenic Resources - The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to visual and scenic resources. The alternative of no license amendment could potentially impact visual and scenic resources at an alternative site depending on the specific site characteristics. Since the development of the 2009 ER, the main discharge stack was relocated within the protected area in 2014. However, the new stack is the same size and height as the previous stack. Otherwise, no other changes that have occurred since 2009 have presented any significant or adverse change to the visual character of the surrounding community.
10. Socioeconomic - Under the "No Amendment Alternative," the potential exists for a portion of the current 935 NFS employees to lose their jobs, as the only confirmed operational activity would be naval fuel production. This would further increase the unemployment rate as well as negatively impacting the tax revenues in the ROI. The Counties within the ROI would experience negative socioeconomic impacts due to NFS downsizing.
11. Environmental Justice - The socioeconomic data and land use information provided in this report demonstrate that no disproportionate adverse economic impact to the minorities or low-income population in the ROI will occur from this license amendment. If the construction and operation of a new facility is relocated to a new site, then there is a potential for environmental justice impacts associated with a new site.
12. Public and Occupational Health Impacts- The proposed license amendment and the activities that have occurred since 2009 have not and will not result in significant adverse impacts to public and occupational health. NFS conducts a robust and comprehensive monitoring program in consultation with the TDEC as outlined in Section 6.0 of this report. All results of the monitoring program comply with or are below acceptable standards.
13. Waste Management - The amendment of the license would not significantly increase the quantities or types of waste generated at the NFS Erwin Facility. The alternative to license amendment would not decrease the volume of waste generated and would only shift the generation of waste to an alternative facility.

In addition, further negative impacts resulting from the non-approval of the license amendment are the counter-productivity of the nuclear material processing objectives of the U.S. Government and the negative effects to the U.S. Department of Energy Naval Reactors Program.

63

21T-23-0212 Revision 1 7.2 BENEFICIAL IMPACTS The beneficial impacts of NFS' licensed activities are:

1. The average per capita income in Tennessee in 2019 was $29,859. The average NFS 2021 salary is $96,100 (with benefits) or $73,350 (without benefits), which greatly exceeds the ROI per capita income. This demonstrates NFS' positive influence on the socioeconomics of the ROI.
2. Furthermore, NFS provides approximately 0.19% of the regional employment within the ROI. The highest percent of individuals living below the poverty level for each County is Carter County (19.3%), Unicoi County (15.8%), and Washington County (15.8%). Washington County population is the most positively influenced by the NFS employment trends.
3. The decommissioning and remediation of the BLEU Complex and the northern burial ground area including the surface water impoundments in 2018 has improved the environmental characterization of the NFS Erwin Facility.
4. Nuclear fuel production for the U.S. Department of Energy Naval Reactors Program; and,
5. Supporting the nuclear material processing objectives of the U.S. Government.

64

~--------------------------------------"-------

21T-23-0212 Revision 1 8.0 List of References ARCADIS 2017 Arcadis U.S., Inc., Railroad Well Hydraulic Capture Analysis, August 4, 2017.

ARCADIS 2021 Arcadis U.S., Inc., Martin Creek Flood Study Summary, May 13, 2021.

BLS 2021 U.S. Department of Labor, Bureau of Labor Statistics, Johnson City MSA Economy at a Glance, May 2021, https://www.bis.gov/regions/southeast/tn _johnsoncity _msa .htm (July 2021}.

DOE 1996 U.S. Department of Energy, Disposition of Surplus Highly Enriched Uranium Final Environmental Impact Statement, DOE/EIS-0240, Volume I, (Washington, DC), June 1996.

DOWR 2021 Tennessee Department of Environment and Conservation, Department of Water Resources, Wellhead/ Source Water Protection Request (Email Communication),

July 20, 2021.

EPA 2021 Environmental Protection Agency, Tennessee Nonattainment/Maintenance Status for Each County by Year for All Criteria Pollutants, June 30, 2021, https://www3.epa.gov/airquality/greenbook/anayo_tn.h tml (July 2021}.

Erwin 1995 City of Erwin, City of Erwin Zoning Map, September 26, 1995.

EXO 1994 Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations.

FEMA 2008 Federal Emergency Management Agency, Flood Insurance Rate Map {Map Number 47171C0068C), September 3, 2008.

GMI 1996 Geraghty & Miller, Inc., Final Project Report- Groundwater Flow and Constituent Transport Modeling at the Nuclear Fuel Services, Inc. Facility, Erwin, Tennessee, April 25, 1996.

Google 2019 Google Earth Pro v7.3.3.7786 (32-bit}, NFS Site, Erwin, TN, October 17, 2019.

ISA 2007 Nuclear Fuel Services, Inc, Integrated Safety Analysis, 2007.

NFS 1984 Nuclear Fuel Services, Inc., Environmental Report for the Erwin Plant located in Erwin, Tennessee, July, 1984.

NFS 1995a Nuclear Fuel Services, Inc., RCRA Facility Investigation Report for SWMU3 at Nuclear Fuel Services, Inc., Erwin, Tennessee, December 1995.

NFS 1995b Nuclear Fuel Services, Inc., RCRA Facility Investigation Report for SWMUs 13 and 14 at Nuclear Fuel Services, Inc., December 1995.

NFS 1996 Nuclear Fuel Services, Inc, Applicant's Environmental Report for Renewal of Special Nuclear Material License No. SNM-124, December 1996.

NFS 1996b Grimaud, G., NFS Engineering Section Manager, "Seismic Loading from the Southern Building Code," request for information to support DOE EIS, Erwin, TN, February 16, 1996.

65

21T-23-0212 Revision 1 NFS 2001d Nuclear Fuel Services, Inc., Technical Basis - Dose Factors and Action Levels for WWTF Radioactive Liquid Effluents, Rev 0, Document #21T-01-0728, July 11, 2001.

NFS 2009 Nuclear Fuel Services, Inc., Environmental Report for Renewal of Special Nuclear Material License No. SNM-124, Docket No.70-143; SNM License 124, May 2009.

NFS 2020 Nuclear Fuel Services, Inc., 2009-2020 Storm Water Discharge Data, 2020.

NFS 2021a Nuclear Fuel Services, Inc., Environmental Database Management System (EDMS),

2021 NFS 2021b Nuclear Fuel Services, Inc., Emergency Plan, Revision 27, November 2021.

NOAA 2019 National Oceanic and Atmospheric Administration, Comparative Climatic Data, https://www.ncdc.noaa.gov/ghcn/comparative-climatic-data (July 2021).

NOAA 2021a National Oceanic and Atmospheric Administration, Climate Normals, https://www.ncei.noaa.gov/access/us-climate-normals/ (July 2021).

NOAA 2021b National Oceanic and Atmospheric Administration, National Centers for Environmental Information, Storm Events Database, https://www.ncdc.noaa.gov/stormevents/ (July 2021).

NPS 2020 National Park Service, National Register of Historic Places {last update September 2020), https://www.nps.gov/maps/full.html?mapld=7ad17cc9-b808-4ff8-a2f9-a99909164466 (July 2020).

NRC 1991 United States Nuclear Regulatory Commission, Environmental Assessment for Renewal of Special Nuclear Materials License No. SNM-124, Docket No.70-143, NRC, August, 1991.

NRC 1991a United States Nuclear Regulatory Commission 1991, referencing Climates of the States. Dale Research Company for the National Oceanic and Atmospheric Administration. 1978, Vol. 1, Detroit, Michigan.

NRC 1991b United States Nuclear Regulatory Commission 1991b, referencing U.S. Nuclear Regulatory Commission, Office of Nuclear Materials Safety and Safeguards, Div. of Fuel Cycle and Material Safety, Environmental Impact Appraisal of the Nuclear Fuel Services, Inc., Erwin, Tennessee, (Washington, D.C.) January 1978.

NRC 1991d United States Nuclear Regulatory Commission 1991, referencing "Groundwater Resources of East Tennessee." Tennessee Division of Geology, Bulletin 58, Nashville, Tennessee. DeBuchananne, D.G. and R.M. Richardson, 1956 and "Geology &

Manganese Deposits of Northeast Tennessee," Tennessee Division of Geology, Bulletin 52, Nashville, TN. King, P.B. H.W. Ferguson, L.C. Craig and J. Rodger, 1944.

NRC 1991e United States Nuclear Regulatory Commission 1991, referencing Eyre, F.J. (ed.).

Forest Cover Types of the United States and Canada. 1980 Society of American Foresters, (Washington, D.C), 148.

NRC 1991f United States Nuclear Regulatory Commission 1991, referencing Braum, E.L. (1950)

Deciduous Forests of Eastern North America. Free Press, (New York), 556.

66

21T-23-0212 Revision 1 NRC 1991g United States Nuclear Regulatory Commission 1991, referencing Simpson, G.G.

1964. Species Density of North America Recent Mammals, Systematic Zoology 12:57-73, 1964.

NRC 1991h United States Nuclear Regulatory Commission 1991, referencing Cook, R.E. 1969.

Variation in Species Density of North American Birds, in Systematic Zoology, 18:63-84, 1969.

NRC 1995 United States Nuclear Regulatory Commission, Environmental Justice Strategy, March 1995.

NCRP 93 National Council on Radiation Protection and Measurements, Ionizing Radiation Exposure of the Population of the U.S., Pergamon Press, Elmsford, NY, 1993.

TNC 2019 Tennessee Comptroller Digital Parcel and CAMA Data for Unicoi County, February 4, 2019.

TNNHP 2021 Tennessee Department of Environment and Conservation, Division of Natural Areas, Natural Heritage Program, Rare Species Database Review, August 20, 2021.

TDEC 2019 Tennessee Department of Environment and Conservation, Chapter 0400-40 Use Classifications For Surface Waters, 2019.

https:ljpublications.tnsosfiles.com/rules/0400/0400-40/0400-40-04.20190911.pdf (July 2021).

TDEC 2021 Tennessee Department of Environment and Conservation, TN Water Well Desktop Application [3.0-PUBLIC}, https://tdeconline.tn.gov/tdecwaterwells/ (July 16, 2021).

TNDOL 2021 Tennessee Department of Labor and Workforce Development, Unemployment Rates, April 2021; https://www.tn.gov/workforce/tennessee-economic-data-/labor-force-statistics/unemployment-rates.html (July 2021).

TWRA2016 Tennessee Wildlife Resources Agency, Rules and Regulation for In Need of Management, Threatened, and Endangered Species, June 2016, https://www.tn.gov/content/dam/tn/twra/documents/wildlife/1660-01 threatened-endangered-species-rule.pdf (July 2021).

USCB 2019 U.S. Census Bureau, QuickFacts https://www.census.gov/quickfacts/fact/table/US/PST045219 (July 2021).

USDA 1985 U.S. Department of Agriculture, Soil Conservation Service, Soil Survey of Unicoi County, Tennessee, 1985.

USDA2017 U.S. Department of Agriculture, National Agricultural Statistics Service, 2017 Quick Stats - Unicoi County, https:ljquickstats.nass.usda.gov/?source desc=CENSUS#22587508-FB7C-329B-A950-CD5F337174DF (July 16, 2021).

USFWS 2021 U.S. Fish and Wildlife Service, List of Threatened and Endangered Species, Consultation Code: 04ET1000-2021-SL/-1007, July 15, 2021.

67

21T-23-0212 Revision 1 USGS 2018 U.S. Geological Survey, 2018 Long-term National Seismic Hazard Map, 2018.

https:ljwww.usgs.gov/med ia/i mages/2018-lo ng-te rm-natio na I-se ism ic-haza rd-map (July 2021).

USGS 2021 U.S. Geological Survey, National Water Information System: USGS 03465500 No/ichucky River at Embreevi/le, https:1/waterdata.usqs.qov/nwis/inventory/?site no=03465500&aqency cd=USGS (July 2021).

UT 2018 University of Tennessee Extension, Contribution of Agriculture to the Unicoi County Economy, https://extension.tennessee.edu/publications/Documents/W634.pdf (July 2021).

68

Retrieved from "https://kanterella.com/w/index.php?title=ML23041A236&oldid=3595487"