ML23047A410
| ML23047A410 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 02/14/2023 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 87FR77146 | |
| Download: ML23047A410 (5) | |
Text
From: Long, Larry <Long.Larry@epa.gov>
Sent: Tuesday, February 14, 2023 2:29 PM To: Stacy Schumann; TRISOX-EIS Resource Cc: Kajumba, Ntale; Buskey, Traci P.
Subject:
[External_Sender] EPA comment for TRISCO-X NOI Attachments: TRISO-X 2.14.23 NOI Final.docx Stacy:
I have attached a copy of EPAs comments for the TRISO-X NOI project.
Larry Long Regional Mining Expert Physical Scientist/Sr. Principle Reviewer NEPA Section/Strategic Programs Office Office of the Regional Administrator 61 Forsyth Street, SW Atlanta, GA 30303 404-562-9460 404-562-9598(FAX) long.larry@epa.gov Intelligence does not always define wisdom, but adaptability to change does CONFIDENTIALITY NOTICE: This message is being sent by or on behalf of the Environmental Protection Agency. It is intended exclusively for the individual(s) or entity(s) to whom or to which it is addressed. This communication may contain information that is proprietary, privileged or confidential, or otherwise legally exempted from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy, or disseminate this message, or any part of it. If you have received this message in error, please notify the sender immediately by email and delete all copies of the message.
Federal Register Notice: 87FR77146 Comment Number: 4 Mail Envelope Properties (SA1PR09MB75520994D97A02F7AC394B0F8EA29)
Subject:
[External_Sender] EPA comment for TRISCO-X NOI Sent Date: 2/14/2023 2:28:31 PM Received Date: 2/14/2023 2:28:44 PM From: Long, Larry Created By: Long.Larry@epa.gov Recipients:
"Kajumba, Ntale" <Kajumba.Ntale@epa.gov>
Tracking Status: None "Buskey, Traci P." <Buskey.Traci@epa.gov>
Tracking Status: None "Stacy Schumann" <Stacy.Schumann@nrc.gov>
Tracking Status: None "TRISOX-EIS Resource" <TRISOX-EIS.Resource@nrc.gov>
Tracking Status: None Post Office: SA1PR09MB7552.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1066 2/14/2023 2:28:44 PM TRISO-X 2.14.23 NOI Final.docx 34029 Options Priority: Normal Return Notification: Yes Reply Requested: No Sensitivity: Normal Expiration Date:
U.S. Nuclear Regulatory Commission Stacy Schumann Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management Stacy.Schumann@nrc.gov TRISOX-EIS@nrc.gov RE: EPA Comment on the Notice of Intent to Conduct Scoping Process and Prepare an Environmental Impact Statement; TRISO-X Special Nuclear Material License, Oak Ridge, Roane County, Tennessee. Docket ID NRC-2022-0201
Dear Stacy Schumann:
The U.S. Environmental Protection Agency (EPA) has reviewed the Nuclear Regulatory Commissions (NRC) Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS), in accordance with Section 309 of the Clean Air Act (CAA) and Section 102(2)(C) of the National Environmental Policy Act (NEPA). The CAA Section 309 role is unique to EPA. It requires EPA to review and comment publicly on any proposed federal action subject to NEPAs environmental impact statement requirement. The purpose of the EIS is to address the environmental effects associated with obtaining a special nuclear material license for TRISO-X, a fuel fabrication facility (FFF), and subsidiary of X-energy LLC in Oak Ridge Tennessee.
According to the NOI, an operating license would authorize the applicant TRISO-X to operate and manufacture high-assay low-enriched uranium (HALEU) to support advanced reactors at its FFF located in the Horizon Center Industrial Park on property abutting portions of Renovare Boulevard, within the western limits of the City of Oak Ridge and in the northeastern portion of Roane County, Tennessee. If issued, the TRISO-X would receive a special nuclear material license for a term of 40-years, issued pursuant to part 70 of title 10 of the Code of Federal Regulations (10 CFR).
The EPA recommends that the EIS evaluate the potential for future and historical impacts of the proposed project and describe efforts to address the following potential impacts of the proposed action in the EIS.
(1) Indirect and Cumulative Effects - Potential cumulative and indirect project effects are of particular concern at nuclear facilities. Most notably, Clean Water Act (CWA) issues for surface and groundwater discharges including the potential for releases of radionuclides and hyper-salinity in surface water and groundwater along with groundwater monitoring for radionuclides, underground injection of effluent, spent nuclear fuel storage, contaminant transport and deposition should be address in the EIS.
(2) National Pollution Discharge Elimination System (NPDES) -The EIS should include a water balance analysis and provide additional information from past studies, if any. In addition to the water balance calculation of the facility, the EPA also recommends the NRC
address the structural integrity of any discharge structures. While the current NPDES permit requires monitoring to ensure that there are no point source discharges from the cooling structures to any adjacent surface waters, it is important for the facility to use relevant techniques to verify that all discharge structures are intact and able to retain nutrient-rich wastewater. The EPA recommends NRC consider this issue as part of the Aging Management Program or other relevant mechanism and include the potential discharges of increased peak storm events such as tropical storms and hurricanes.
(3) Wetlands and Streams - To support wetland and stream mitigation decisions and Tennesse Department of Environment and Conservations (TDEC) evaluation of potential stream impact requirements for the CWA Section 401 Water Quality Certification, information regarding CWA Section 404(b)(1) should be included in the EIS. Providing adequate wetland and stream information within the NEPA process can help to streamline the environmental review and permitting processes for these resources.
(4) Waste Disposal - The EIS should indicate if there will be any changes in the generation of waste including low-level radioactive waste, mixed low-level radioactive waste, transuranic waste, and hazardous and Toxic Substance Control Act wastes over the life of the program.
The EIS should indicate where TRISO-X will send the spent nuclear material, nuclear fuel and spent fuel debris for storage pending long-term disposal options outside of the facility.
Climate - Climate change may impact the proposed project, posing risks to aging infrastructure, worker health and safety and the environment. We recommend that the EIS include an evaluation of potential climate-related impacts including a discussion of frequency and severity of major storm events, wildfires, or drought that could lead to power disruptions or increased cooling demands in summer months. The EIS should also provide an analysis of severe events and their cumulative impacts on communities with Environmental Justice concerns. The EIS should clearly define the potential direct, indirect and cumulative impacts on the operations of the FFF from tornados and hurricanes, along with increased storm intensity due to climate change, The EIS should also address potential impacts associated with indirect, and cumulative impacts associated with future severe storm events including, but not limited to, tornados and hurricanes, along with increased storm intensity due to climate change, and analysis of these severe events on communities with Environmental Justice concerns.
(5) Hurricane and Storm Impacts- The EIS should explain the differences that result from using different storm prediction models as well as the validations of these models. Sea level rise should be incorporated into a discussion with a Sea, Lakes, Overland and Surge from Hurricane (SLOSH) model, which is also used by the National Weather Service and federal agencies when determining storm surge predictions. The EPA recommends that the EIS provide a detailed description of any other model used for determining storm surge and flooding, and the rationale for using another model over the SLOSH model.
(6) Environmental Justice - Executive Order (E.O.) 12898 directs federal agencies to identify and address any disproportionately high and adverse human health or environmental effects of its programs, policies and activities on minority, low-income, tribal, and indigenous
populations. The EIS should include an analysis that is consistent with E.O. 12898. The analysis should indicate whether people of color, low income, tribal, and indigenous populations reside within the vicinity of the proposed project area. It would also be helpful to include a current map depicting the population demographics near the facility.
Assessing data using EJScreen (https://www.epa.gov/ejscreen), the EPAs nationally consistent environmental justice (EJ) screening and mapping tool, is a useful first step in understanding or highlighting geographic locations that may need further review or outreach.
The tool provides information on environmental and socioeconomic indicators as well as pollution sources, health disparities, critical service gaps, and climate change data. The tool can help identify potential community vulnerabilities by calculating EJ Indexes and displaying other environmental and socioeconomic information in color-coded maps and standard data reports.
If communities with EJ concerns are located within the vicinity of the proposed project area or potentially affected by the proposed project, the EPA recommends the NRC meaningfully involve with direct communications with these communities throughout the decision-making process to help identify potential benefits and burdens associated with relicensing and permitting decisions. Adaptive and innovative approaches to both public outreach and community involvement regarding project issues should take place during the project planning. The EIS should clearly define the efforts that TRISO-X is taking to address and adapt to potential climate in association with the Environmental Justice section.
The EPA appreciates the opportunity to provide comments on the proposed project. If you have any questions regarding our comments, please contact Mr. Larry Long, of the NEPA Section, at (404) 562-9460, or by e-mail at long.larry@epa.gov.