ML23047A411

Comment (5) E-mail Regarding TRISO-X EIS Scoping

ML23047A411
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: ML23047A411 (14)

Text

From: M Mayes <graymel17@yahoo.com>

Sent: Tuesday, February 14, 2023 1:54 PM To: TRISOX-EIS Resource

Subject:

[External_Sender] NRC-2022-0201 Attachments: TRisox Comments for NRC EIS Scoping.docx Greetings -

I am a citizen of Oak Ridge, TN, and a geologist and I am sending my comments to you about the proposed TRISO-X facility.

Please see my comments in the attachment to this email.

Thank you, William G. Dean

Federal Register Notice: 87FR77146 Comment Number: 5 Mail Envelope Properties (280619383.901864.1676400857260)

Subject:

[External_Sender] NRC-2022-0201 Sent Date: 2/14/2023 1:54:17 PM Received Date: 2/14/2023 1:54:28 PM From: M Mayes Created By: graymel17@yahoo.com Recipients:

"TRISOX-EIS Resource" <TRISOX-EIS.Resource@nrc.gov>

Tracking Status: None Post Office: mail.yahoo.com Files Size Date & Time MESSAGE 224 2/14/2023 1:54:28 PM TRisox Comments for NRC EIS Scoping.docx 38788 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

TRISOX EIS SCOPING COMMENTS Dear Jill Caverly -

Thank you so much for the opportunity to provide the NRC comments towards the scope and breadth of the EIS to be prepared for the Triso-X Fuel Fabrication Facility that is planned for the Horizon Center in Oak Ridge, Tennessee.

I am a resident of Oak Ridge and attended your meeting on Jan 25, 2023. I am also a geologist with a PhD. Having conducted both my Masters and Doctorate at University of Tennessee, Knoxville and having lived in Tennessee since coming to graduate school 29 years ago, I can safely attest that I am comfortable and knowledgeable with local geology. Furthermore, I am actively engaged and have personally visited the Horizon Center on numerous occasions, including three specific visits to the site periphery on January 26 and 28, 2023 and February 5, 2023. Thus, I can provide relevant, timely expert and detailed comments towards the project and alert you to technical concerns that may impact matters.

All figures I reference come directly from the TRISO-X application materials (Environmental Report) that was provided by the NRC prior to the 1/25/2023 public meeting and are listed as they appear in those reports. All abbreviations are those used in the same Environmental Report prepared by the client and provided by the NRC

SUMMARY

The applicant selected the HCS site primarily because it was given to them for free. They claim to use siting criteria that includes avoidance of soluble limestone networks that impact and connect surface and ground hydrology and freely transmit fluids (Karst). However, the faulted and dipping sedimentary beds that underlay the HCS are indeed carbonate rocks (Knox and Chickamauga groups) that are regionally and locally known for observed caves, sinkholes, disappearing streams and other karst features. Sinkholes are on USGS maps immediately down-strike and adjoining the HCS. Disappearing streams have been personally observed on property.

Clients own data indicates water from various wells having distinct physical and chemical differences suggesting separate flowpaths or complex flow history between wells. Borehole data Client supplied indicates voids in all wells drilled with some openings as large as 4.1 feet!

Thus, from a purely geologic and hydrologic perspective, the HCS is unsuitable by the criteria the Client put in place, which is to avoid karst geology. Karst geology increases the risk that the plant itself may become impacted from ground collapse or subsidence of de-watered voids/caves. Further, the rapid flow of surface and groundwater on and off-site through a maze of interconnected pathways makes possible early detection of any contaminants very difficult.

Further, the convoluted hydrologic pathways confound remediation efforts. There, the karst geology poses a great risk to the safety of the plant and increases the risks in cases of spills, accidents or attacks. The Clients data supplied to the Environmental Report, indicates the HCS is rife with both surface and subsurface karst features thus making this site UNSUITABLE.

Further, there are concerns on why greenspace needs to be consumed for Heavy Industrial activity, where the Heritage Center, (a former DOE brownfield now an industrial park) a mile or so to the SE, exists for these types of manufacturing activities. The Horizon Center, on the other hand, is bound on three sides by protected lands set aside by the DOE. It is also zoned IND-2, which does not allow for intensive manufacturing nor large quantities of concentrated radioactive material. In order to commence operations TRISO-X will need to seek zoning change. In fact, the prime reason why TRISO-X wants use this property is not based on sound science or environmental concerns, but that, surprisingly, it comes at no cost to them The City and IDB who operate Horizon Center have not shown a strong record of environmental stewardship. There have been wholesale clear-cutting (2013) of the property without permission or input from USFWS; TDEC or other regulatory agencies. The event obscured wetland and plant communities and altered surface hydrology/features, complicating efforts to protect the land, biota and surrounding areas. The City and IDB have not responded to notifications (2021) of derelict sediment fences that have been left in place contrary to established environmental protocols. As of 2023, these derelict sediment fences remain in place.

OVERVIEW and PROJECT NEED TRISO-X and its X-Energy parent company were selected by the DOE to produce by 2027 a new fuel fabrication facility as well as the Xe-100 advanced reactor, which was determined in 2021 to be sited in Washington state. Thus, TRISO-X wishes to build a facility at the Horizon Center, TN to be the sole provider of fuel for a reactor some 2,000 miles away which not only has not been built but also, no finalized site has been identified.

Therefore, it raises serious a priori questions why both sides of the supply chain require vast transportation and security demands. Not only would uranium-235 need to be shipped to the Horizon Center site but both fuel pebbles as well as radiological wastes would need to be shipped west for use and storage.

Thus, the transportation risks for raw materials, finished product and hazardous waste needs to be better constrained and the carbon footprint adequately characterized and understood.

SITE CHOICE TRISO-X states on page 2-36 and 2-37 of their Environmental Report that one prime consideration for locating the facility at HCS is due to the lack of karst formations. However, the fact is that they have chosen a site that is underlain by karst limestone and known sinkholes are located adjoining the property. They in fact disclose karst features in other section of the document by describing borehole voids discovered in most wells,(p 3-26) groundwater turbidity in samples; and karst swales expressed on surface (p 3-47&8). They even acknowledge sinkholes on adjacent properties (p 3-31; 4-26; Figures 3.3.3-1; 3.4.3-2)) and one that was once described on their HCS site itself USGS mapped sinkhole. Furthermore, the presence of disappearing streams, circular vegetated depressions as well as hydrologic data and well log information strongly suggests the presence of karst at the HCS location.

These karst features are a concern towards how operations and development will affect nearby sensitive ecologic natural areas as well as how contaminants may migrate off site. Moreover, the presence of active karst will have pronounced implications for public risk from possible accidents, on-site spills or terrorist attacks. Lastly, the karst geology may have influence to the impacts from construction and operation as well as the decommissioning of the site.

Incredibly, the TRISO-X Environmental Report states karst to be a major criteria for siting nuclear facilities, yet in spite of the wealth of evidence, declares the potential for karst to be SMALL (p4-26). This conclusion seems to be quite contrary to the evidence and needs to be further and more strongly investigated.

GEOLOGY The Environmental Report acknowledges the presence of several carbonate formations underlying the property - notably the Knox and Chickmauga Group. These rock units contact on the site and strike NE-SW across the property. As shown in FIG 3.4. 1-1, these rocks dip (to the SE) and karst features are commonly encountered.

Karst often follows contacts between rocks units, along dipping planes, as occurs here, as well as through fracture sets. Given the SE dipping thrust-faulted carbonate rocks here, along with the facture sets within them provides many discrete pathways for dissolution and formation of karst voids, caverns and other pathways.

In fact, borehole data brings to light numerous voids and clay filled voids in all 7 borings that penetrated rock. These voids ranged in size (0.1 M) to (1.2 M) in vertical size (p. 3-31 & p 3-35).

An additional 6 wells were drilled under the proposed building footprint and 4 of 6 of these also contained large voids ranging from 0.1 M to 1.1M in vertical size. These voids are not only large but indeed consistent with the soluble limestone and are indicative of karst. They also seem to have an active influence on present hydrology (described in section below). Thus karst seems present across the entire site and has the potential to affect building integrity, facility operation, and increased environmental risk.

The weathered bedrock is capped by clay and clay soils ranging in depths of 1.1 M to 9.6 M (P 3-34). These clay soils have a potential to in-fill karst voids during wet conditions when they expand and in fact, clay-filled voids were often encountered in the well logs.

On the surface, the geomorphology depicts a rolling terrain that shows a series of drainages and low-lying areas. Weathered clay underlies the surface. This clay has the potential to infill voids and plug water flow when wet. However, alterations of the hydrologic regimes that lower water table and de-water these voids can allow the clay to dry, shrink thus opening up rapid pathways for water flow. Further, dewatering of subsurface voids can lead to compaction and collapse of the voids causing surface subsidence. Such an event could be highly detrimental with regards to a nuclear fuel fabrication facility.

HYDROLOGY Surface Surface drainage (Fig 3.4.2-2) depicts several streams flowing across the property. The largest drainage being SD-1, which was confirmed to be conveying water on 1/26; 1/28 and 2/5/23.

There are numerous circular, vegetated depressions, and large ovate depression.

Fig. 1.3-3 Site Plan shows a drastic manipulation of surface water. Notably, storm water/effluent from production facility is collected by an encircling drainage ditch that subsequently directs water to a low-lying depression on the SW corner of the property that will serve as a detention basin. It should be known from personal observation that this feature appears to be a sinkhole! Further, the plan calls for directing excess storm water flow from the detention basin to an offsite location immediately to the SW. It is listed as a DOE natural area in Fig 1.3-3.

Please consider the negative impact to this protected natural area as pulses of storm water are redirected. However, lets look at the submitted Fig 2.1-1 of the site plan. In this case, the detention pond is shown draining into the DOE natural area that is delineated as a sinkhole!

My personal visits to the area (1/26; 1/28; 2/5) confirm that this feature is indeed a large sinkhole, which is along geologic strike of the detention pond, which also appears to be an up-strike continuation of the sinkhole. Thus the plans suggest TRISO-X will dispose of surface water into a sinkhole!

Further upslope, the clients show on Fig 2.1-1 a stream flowing into the HCS site. The consultant (Wood) called this an intermittent stream, but on my visits 1/26; 1/27 & 2/5 I observed flowing water on the TRISO-X property where that stream enters, and instead of being intermittent it simply disappears which is a classic example of Karst topography.

Incredibly, the Environmental Report even describes it as a sinking stream (p 3-31), yet incredulously somehow they list the effects of karst here as SMALL (P 4-26)

Most importantly to siting a nuclear production facility here is that there seems to be an active karst system underlying the property and data further underscores that groundwater and surface water here seem to be highly connected. Thus, the risk for contamination to spread from leaks, accidents or attacks may be quite high. Given the property lies at the base of a large ridge (Blackoak Ridge) and that site preparation will remove significant quantities of soil, there will a continuous source and more rapid flow of water to the site with less capacity for natural storage. This has huge implications as the subsurface karst subsequently adapts to the new hydrologic regime.

Wetlands My on-ground observations indicate numerous small but vegetated depressions that all suggest karst control. Also noted was stream flow and disappearing stream. These observations suggest a vast network of connected wetlands prior to the clearing in 2013. Further, previous activities

across the property have resulted in relict sediment fences also surrounding some of these and other areas indicating a past concerns about wetlands, probably before the site was cleared without permission or permitting (See Mr Andrews letter from USFWS). In fact, Figure 3.4.4-1 is a National Wetland Inventory map depicts a stream (SD-1) flowing across the property and the photographic shows small vegetated circular depressions. Also, depicted in the figure 3.4.4-1 is a large ovate depression between the stream channel and Philotechnics building. This feature has sediment fence installed along its periphery.

I would suggest an actual accounting of standing water observations as well as investigations into reduced soil conditions such as gleying, translocation of minerals/clay and other field features to determine the actual extent of wetlands and water conveyances on the surface.

(https://www.nrcs.usda.gov/sites/default/files/2022-09/Field_Indicators_of_Hydric_Soils.pdf)

Surface water needs to be coupled with karst data to attempt to understand the connection between surface and groundwater at this site. The use of dye tracers and environmental tracers may provide some improvement towards understanding hydrologic relationships here,.

Groundwater The groundwater wells suggest a general soil water flow to the SE, however and importantly, no assessment of the karst groundwater flow was determined. Groundwater at the HCS as determined from the clients own data also indicates the potential for Karst as well as discrete flow patterns across the property.

As per Table 3.4.1-2, ground water elevations on Sept 16, 2021 indicate GW-1 at 748.87 feet however, GW-2 was 764.37 feet on 9/15/21; GW-3 was 764.96 feet on 9/14/21; GW-4 756.46 feet on 9/16/21 and GW-5 759.28 feet on 9/17/21.

These data then suggest flow CONTRARY to the depicted flow lines in Fig 3.4.1-5 that lists the groundwater elevation in GW-1 as 784.87 feet. Thus, an error in data reporting exists between either the Table 3.4.1-2 or Figure3.4.1-5 and this needs to be verified.

Moreover, the data in Table 3.4.1-2 show that there is much fluctuation in groundwater elevation. There is at least 20 feet of variability of water table in GW-1, if we accept the 9/16/21 data as 784.87 feet. However, GW-1R shows some 41 feet of water table elevation change between Feb 2022 and June 2022. This is a drastic comparison to the other wells, such as GW-2 that only shows some 2 feet of water table elevation change from 9/15/21 to 8/8/22. GW-3 indicated about 25 feet of water table change between 9/14/21 and 2/28/22, but was near the same initial elevation by 8/8/22. GW-4 was within 1 foot elevation change between 9/16/21 and 8/8/22 reaching an acme of 4 feet increase on 2/28/22. Thus, given GW-1 and GW-1R data, the groundwater in the upper NW quadrant of the property seems to endure major elevation changes that are distinct and do not seem connected to the well responses on the rest of the property. This may be due to numerous reasons and one such consideration is the perching of water table in the clays in the higher elevation areas (GW-1; 1R & 3).

Groundwater quality from Tables 3.4.1-4 and 3.4.1-5 also indicates the potential for distinct water sources and flow paths between the upper wells (GW-1; GW-1R; GW-3) and the lower wells (GW-2; GW-4). Specifically, we see lower alkalinity at GW-2 and GW-3 than GW-4; GW-5.

Dissolved O2 is also higher (~5 times) at GW-1; GW-2 and GW-3 than the lower wells.

Temperature at GW-1; GW-2 and GW-3 is also some 10 degrees C warmer (~24 C) than GW-4; GW-5 etc. Lastly, the groundwater samples at GW-1; GW-2; depict much more turbidity than GW-3; GW-4 and GW-5.

Taken together, these water quality data also suggest distinct water sources and/or travel paths between the wells on the property. It seems the GW-1 and GW-1R; GW-3 are warmer, endure much greater water table fluctuations than GW-4. The alkalinity and dissolved oxygen (and BOD) all suggest that meteoric/surface water may be mixing in the upper gradient wells (GW-1; GW-1R; GW-3) whereas the lower Temperatures, lower dissolved oxygen and BOD as well as increase Total Dissolved Solids that increase in the lower wells (GW-4 and GW-5) indicate much longer residence times and perhaps discrete water sources for the groundwater beneath the HCS. The high turbidity (and temperature) of the groundwater in GW-1; GW-1R and GW-3 suggest rapid flow quite likely through karst features that the client has documents (borehole voids as large as 4.2 feet!)

Therefore, based on groundwater data, I suspect there may be active karst pathways influencing groundwater flow.

Thus, I question the validity of the 2 dimensional flow depicted in Fig 3.4.1-5 and 3.4.1-6 because the dipping fractured rocks combined with numerous dissolution voids suggests there may be distinct flowpaths associated with karst.

I recommend that the client ascertain the flow and pathway as controlled by the karst limestone whereby component of groundwater flow may be following surface gradient but also controlled by flowing down dip, down strike and through numerous karst channels (voids) in the rock.

Specifically, the client should conduct dye tracers to determine flow paths and direction as well as the relative volumes of water. This is direly important considering the client wishes to discharge storm water, potentially with contaminants, directly into a sinkhole immediately to the southwest of their property.

Further, client should attempt to understand the potential risk from accidents or other events that could release liquid contaminants, including radiological components, into the karst systems. Client could employ Ground Penetrating Radar, environmental tracers and other techniques to map dissolution features/hydrologic connections.

Also as the client noted, numerous voids were encountered in the limestone borings and these were often clay-filled. When surface water supply is removed, these clays wills shrink, opening

new pathways. Thus, while the area presently seems to show much open connection between surface and ground water major concerns may be the opening of new conduits and pathways for water flow and even, the lowering of surface elevation as dewatered subsurface features collapse. Any of these scenarios is unsuitable for nuclear fuel manufacturing.

Lastly, and critically, client needs to state how the groundwater will change in relation to changes to surface water budget through both interception and re-direction of surface flow along with the vast impervious surfaces planned for the site. It is entirely plausible that some subsurface karst features may be currently filled with water. However, the manipulation of surface water and the impervious surfaces may result in the dewatering of the subsurface karst which may have dire impact for the potential for collapse.

ECOLOGY While Table 1.4-2 submitted by the client claims there are no endangered birds or animals on site, it is imperative to note that Steven Alexander, of the US Fish and Wildlife Service responded to the consultants (Wood) hired by the client to address endangered species concerns. Mr. Alexander clearly indicated that several bat species occupied this area.

Furthermore, the USFWS noted significant karst features in the project area which are notable bat roosting features. Moreover, Mr. Alexander specifically stated that the Horizon Center site in question was cleared by the Oak Ridge Industrial Development Board without appropriate environmental review or permitting by the state of Tennessee. They further state there have been numerous protected species at this site and that the parcel has important deed restrictions pursuant to NEPA. Thus, the area is indeed sensitive with respect to endangered species in spite of attempts to obscure them by unpermitted clear-cutting and land manipulation.

Furthermore, the Horizon Center is bordered on three sides by protected natural areas that include wetlands and sinkholes directly impacted by TRISO-X construction and activities. These protected areas include Black Oak Ridge Conservation Easement as well as Natural Areas within the Horizon Center and they host endangered biota and the impact to these areas needs to be fully considered.

Lastly, it has been shown that BORCE and the Horizon Center are used by various animals as regional migration corridors between the DOE Oak Ridge Reservation; Great Smoky Mountain National Park; Big South Fork and Obed Wild and Scenic River area.

ZONING TRISO-X states on p 5-5 that the proposed land use is consistent with City of Oak Ridge land use plans and zoning, but this is incorrect. On P 3-20, it is clearly stated that the Horizon Center is zoning IND-2, where the property is medium Industrial. The fact that the project design includes numerous effluent stacks, concentrated sources of uranium, radiological waste, noise etc for the project requires TRISO-X to seek a zoning change to IND-3. However, this zoning change was not the agreed-upon designation when the Horizon Center was transferred from the DOE.

Further, changing this requirement then alters the susceptibility of the Greenspace protected natural areas and BORCE. In fact, altering this zoning after the fact then changes the nature of

this land transfer from the DOE to the City, and may in fact require a new EIS to consider the impacts of the federal action of the DOE transferring this property to the City, since this was not supposed to be a heavy industrial site (IND-3) when the DOE transferred it. Certainly, the Horizon Center was designed and intended as a light industrial area to compliment and support the BORCE/Natural areas properties. Changing the zoning to heavy industry at this point contradicts the desire for permanently protected areas and compromises those efforts.

ENVIRONMENTAL IMPACTS (Chapter 4)

The anticipated environmental impacts described by the client do not seem to be associated with reality. Specifically, p 4-26 the client states the risk from sinkhole formation is SMALL.

However, numerous lines evidence presented in their own document (water table data; water quality data; borehole geology), coupled with the visible occurrences of disappearing streams, circular depressions on surface along with a large ovate depression, numerous voids in all boreholes, plus known sinkholes immediately adjoining and draining the HCS property along with the known characteristics of the underlying geology all belie their assumption.

This very real presence of karst affects every aspect of this project from Construction, Operation and Decommissioning.

The client also claims that the operation of the facility will have no impact on groundwater.

However, this is also most likely false as the design calls for removal of soil (which stores water) and the development of drainage ditches and retention pond which effectively separates groundwater from recharge sources. This in turn may lower groundwater levels, dry out clays and potentially lead to dewatering of voids and ultimately, collapse, which is not an acceptable outcome for a nuclear facility.

Furthermore, there is evidence of a perched water table given the large water table fluctuations at GW-1 and GW-1R. Undoubtedly, construction of impervious surfaces along with surface interception plans of lined and unlined drainage ditches will impact groundwater (p 4-30), as already mentioned by the applicant.

TRISO-X also states on P 4-29 that there may be large-scale releases of contaminants from materials stored outside. They seem to minimize this risk by stating there are no downgradient public or private wells. However, this does not take into account the effects upon the protected natural areas that compose Horizon Center as well as border it. This plan of operation, outside storage of hazardous materials and a lack of concern towards the natural and protected areas is completely unaccepted, particularly given that this facility is planned for a Greenfield that is surround on three sides by protected natural areas. They claim groundwater sampling as a tool to detect these materials, but their own water quality data show the various wells have differing chemistry, different hydrologic response and are likely not completely connected, at the very least. Thus, their plans for handling hazardous material and their schemes to detect it are not valid for the karst geology that dominates this site. In fact, their entire scheme is simply to intercept water, collect it in ditches and retention pond and convey it by an existing drainage swale* to an observed sinkhole feature in the adjacent parcel p 4-30. That they even

admit this is a sinkhole is amazing, however, it is completely unacceptable for TRISO-X to be using the karst features here as a means to dispose of contamination or storm water.

• (i.e. surface feature caused by karst collapse).

Their data indicate the property is rife with karst features and this adds to the complexity and uncertainty between runoff and surface water conditions P 4-34. Without a doubt, this uncertainly then is manifested as it pertains to groundwater.

TRISO-X also claims there is no surface water on site to be impacted P 4-40. However, as stated be them, the karst swale and intermittent stream drain most of the property and NWI maps a stream through the area. That they could not make this determination is predicated by the fact that the property was cleared ~2013 by IDB and the City if Oak Ridge with permit or approval.

Thus, obvious vegetative evidence was removed. However, as stated previously, I have observed standing and flowing water on site on 1/26/23; 1/28/23; 2/5/23 and there are simple ways to determine if the soils are related to wetlands.

TRISO-X also acknowledges that noise from their operations will exceed EPA recommendations, P 4-64. However, they avoid this responsibility by stating that the EPAs recommendations are not regulatory standards. Unfortunately, this is an unsatisfactory response and attitude for a corporation seeking to develop a greenfield property surrounded by protected greenspace set aside for ecological and recreational value.

Not discussed are the effects of light pollution into the surrounding BORCE and greenspace.

Light pollution from the operations as well as security perimeters needs to be addressed and properly contained. As noted in the document and supplementary letters, the karst features here along with the bordering protected natural areas serve as critical habitat for several bat species. There are also other extant nocturnal biota such as bobwhite quail, bobcat, fox, fireflies, etc. that are highly susceptible to light pollution.

Further, TRISO-X claims the project is within Oak Ridge land use criteria, p5-5, but this is incorrect, as the applicant must secure a zoning change from IND-2 to IND-3.

CITY ENVIRONMENTAL AND ECONOMIC COMMITMENT The applicant assures the NRC that the proposed facility and operations would be consistent with the City of Oak Ridge policies, guidelines and landuse. However, please understand the applicant must request a zoning change for this to occur. Further, there is no discussion of light restrictions and noise will exceed EPA recommendations. The City itself has a track record of ignoring environmental issues pertaining to the Horizon Center.

First, the IDB under auspices of the City clear cut the property without permission, a permit or a survey to identify rare species, critical habitat, wetlands, etc. This was discussed in the supplement Letter provided by Mr. Andrews of the USFWS and suggests that the City and its

quasi-governmental IDB have little regard for the protection and preservation of sensitive biota and natural areas.

In fact, in 2020, a motorsports park was proposed for the entirety of the Horizon Center, which would have impacted the wetlands and protected natural areas which they planned to develop.

The City and IDB would have agreed to the motorsports park for $4,800,000 sale price.

https://oakridgetoday.com/2020/02/06/motorsports-park-proposed-at-horizon-center/

However, in spite of major environmental concerns about impacts to wetlands and protected areas, as well as residential concerns about noise, the project was abandoned when it became clear the DOE would not agree to zoning changes that allow impacts to the natural Exclusion Areas of the Horizon Center https://www.wvlt.tv/2021/04/05/motorports-park-driving-oak-ridge-debate/

During this time, I served on the Environmental Quality Advisory Board (EQAB) for the City of Oak Ridge. As I was conducting due diligence on-ground investigations of the Horizon Center for the proposed racetrack, I became aware of an extensive network of old, derelict sediment fences on the Horizon Center property, including the TRISO-X parcel. These were apparently installed at least as far back as 2013.

According to TDEC, silt fences have specific guidelines (p 250-7), below:

https://tnepsc.org/TDEC_EandS_Handbook_2012_Edition4/TDEC%20EandS%20Handbook%204 th%20Edition.pdf.

TDEC stipulate among other things that silt fences are temporary, with 6 to 12 month life and that they be no more than 24 inches high. The silt fences are also expected to be maintained and repaired.

I notified EQAB in early 2021, which includes the Assistant to the City Manager about the issues with the abandoned silt fences that traverse the entire Horizon Center, included the TRISO-X parcel. We generated as sent a letter to the City notifying them of these issues. The City deferred responsibility and requested we transmit a letter to IDB, which we did. However, neither IDB nor the City took action. Instead of taking action or investigating, IDB, pressed EQAB to provide exact locations of fences, effectively doing nothing to address the matter:

http://www.oakridgetn.gov/images/uploads/Documents/Boards&Commissions/IDB/Minutes/2 021%20Minutes/ORIDB%20Minutes-%20November%201,%202021-Approved.pdf In fact, the silt fences, many over topped or collapsed from fallen limbs, some blocking flowing water, all remain in place as of 2023 with no effort by City or IDB to remediate the situation. It should be emphasized that silt fences are borne of the Clean Water Act and government entities are mandated to ensure the health and function of our surface water.

Furthermore, the City initially desired to increase electrical power to the Horizon Center by running new power lines through the sensitive Ecologic Exclusion Areas that were set aside by the DOE. This plan was only overcome after stringent opposition by citizens and environmental groups, not by the City seeking a means avoid deleterious impacts.

Therefore, given the City and IDBs 1) lack of regard for clear cutting parcels without permits; and thus; 2) avoidance to protect wetlands, threatened plants and animals; 3) willingness to impact/destroy Ecologic Exclusion Areas through development or racetracks or powerlines; 4) refusal to follow standard protocols for containing sediment and properly managing those sediment trapping structures, in spite of being 5) repeatedly notified through proper channels (EQAB), it is apparent the City is unable and incompetent in providing adequate environmental and safety oversight. This lack of effective local oversight is unacceptable for a nuclear facility and given the need for the City to provide specific permits (Table 1.4.-1) for matters such as stormwater drainage and site construction, then I have grave concerns on how these permits will be determined.

Conflicts of Interest Possibly, part of the reason the City cannot be relied upon to operate in the best public interest of Horizon Center lies with potential conflicts of interest. It is a matter of fact that a long serving (~20 years) IDB member; a multi-term City Council member are direct relatives with interest in a private realty firm that actually owns some Horizon Center property and would stand to benefit.

https://sports.yahoo.com/board-looks-sell-transfer-remaining-010013071.html https://livability.com/tn/oak-ridge/education-careers-opportunity/what-new-developments-are-coming-to-oak-ridge-tn/

Given the fact the 110 acre TRISO-X property was simply given away for free, and that there is a 20 year exemption on taxes, it is difficult to reconcile that land deal was somehow to the betterment of our City or citizens. It seems more likely this project is designed for the betterment of a select few of our community at the expense of everyone else. This becomes very clear when we see the track record of ignoring the protection of the sensitive ecological areas (clear cutting 2013; powerlines 2020); not abiding by environmental protocols when notified (Silt fences 2021); providing economic windfall to public (HCS property simply given away 2022). And now, some wish to renege on DOE-agreed upon terms and re-zone Horizon Center from IND-2 to a much more intensive, IND-3 which was clearly not the intent of the Horizon Center Development. It seems clear from Clients own document that a prime reason to select the Horizon Center Site was the financial incentive of the 110 acres being transferred at no cost, along with putting a multi-decade tax deferral scheme in place. This is hardly the result of sound science, environmental stewardship or benefits to the community.

QUESTIONS/CONCERNS FOR EIS SCOPING:

1. What is the extent of karst features on HCS site?

2. How interconnected are voids observed in boreholes?

3. How connected are the flow paths?

4. Why is water chemistry and physical properties vastly different in GW-1; GW-1R GW-3 from the other wells

5. What do Dye Tracer tests and/or environmental tracers conducted from surface along with injection into wells indicate about the flow paths?

6. Map and explain the Disappearing stream (SD-1) which has also been mapped by the NWI.

7. Determine wetlands on property. Vegetation has been cleared, but low-lying, often wet areas persist. Use soil mapping, soil investigation along with monitoring to determine actual wetlands

8. Assess impacts to natural Exclusion Areas, including surface and sub-surface hydrological changes.

9. Determine and manage impacts of light pollution into BORCE; exclusion areas and provide mechanisms to contain light

10. Assess the cumulative risks of increased truck transport of radiological material and wastes in context of on-going activities at DOE, TVA, sites and activities of contractors. At what point do we consider the totality of combined risks from all these sources in a comprehensive EIS?

11. Examine the property transaction and those who personally benefit in context of those who are making decisions to bring these operations to HCS.

12. Determine the suitability and legal responsibilities to alter zoning from IND-2 to IND-3 to accommodate heavy industry in a light industrial park as delivered and agreed upon by the DOE. Will DOE need to conduct an EIS to determine how such zoning changes affect BORCE or the Natural Exclusion Areas?

Thank you for your time and consideration.

Respectfully submitted, William G. Dean, PhD Oak Ridge citizen