ML23047A413

Comment (6) E-mail Regarding TRISO-X EIS Scoping

ML23047A413
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: ML23047A413 (9)

Text

From:

m mayes <mamayes5@yahoo.com>

Sent:

Tuesday, February 14, 2023 1:51 PM To:

Jill Caverly; TRISOX-EIS Resource; Matt Bartlett

Subject:

[External_Sender] COMMENTS FOR TRISO-X IN OAK RIDGE TN Docket 07007027 Attachments:

Mayes Comments Triso-X environmental review Feb 2023 Oak Ridge TN_final.pdf Hi folks, attached pls find my comments for the Triso-X plant in Oak Ridge TN Docket 07007027.

Thank you Melanie Mayes

Federal Register Notice:

87FR77146 Comment Number:

6 Mail Envelope Properties (1007048489.1330359.1676400633594)

Subject:

[External_Sender] COMMENTS FOR TRISO-X IN OAK RIDGE TN Docket 07007027 Sent Date:

2/14/2023 1:50:33 PM Received Date:

2/14/2023 1:51:51 PM From:

m mayes Created By:

mamayes5@yahoo.com Recipients:

"Jill Caverly" <Jill.Caverly@nrc.gov>

Tracking Status: None "TRISOX-EIS Resource" <TRISOX-EIS.Resource@nrc.gov>

Tracking Status: None "Matt Bartlett" <Matthew.Bartlett@nrc.gov>

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Loca%on: Oak Ridge, TN Licensee: TRISO-X, LLC License Number: TBD License Expires: TBD Docket Number: 07007027 Re: Comments from the Harvey Broome Group of the Sierra Club; prepared by Melanie A Mayes, PhD; regarding the Environmental Report submiNed for NRC applicaPon for the Triso-X corporaPon; Feb 16 2023

Dear Dr. Jill Caverly,

Dr. Mark BartleN, and team at the NRC:

Thank you kindly for accepPng public comments regarding the above docket. I am commenPng on behalf of the Harvey Broome Group of the Sierra Club, located in eastern Tennessee. I would like to establish my quali"caPons - I have BS, MS, and PhD degrees in geology with emphasis on hydrology and contaminant transport including toxic metals and radionuclides - from the University of Tennessee. I have over 20 years of pracPcal experience as a full-Pme research scienPst in the Knoxville-Oak Ridge area and I have lived in eastern TN since 1996 and in Oak Ridge since 2011. In my professional life, I even served as a consultant to the NRC for nuclear power plant safety evaluaPons following the Fukushima incident. I have conducted "eld work on the Oak Ridge ReservaPon and in East Fork Poplar Creek in the immediate vicinity of the HCS. At UT, I parPcipated in numerous "eld trips and "eld classes led by preeminent local geologists and hydrologists including Dr. Bob Hatcher, Dr. Peter Lemiszki, Dr. Phil Jardine, and Dr. Larry McKay. When I was in graduate school, I enrolled in a week-long Karst Hydrology "eld course taught by the preeminent karst hydrologist Dr. Nick Crawford at Western Kentucky University. We conducted dye traces, collected water samples, toured Mammoth Cave, and observed karst features in the Bowling Green KY area. Further, I grew up in the Missouri Ozarks in an area renowned for caves and large springs. BenneN Springs State Park which is near my hometown boasts a "ow of 100 million gallons per day; and nearby Ha Ha Tonka Spring is 48 million gallons per day. My comments are based upon my extensive knowledge and experience of the local Oak Ridge area and on my educaPon and experience with karst systems.

I want to establish upfront that I am deeply concerned about climate change, and that I generally support nuclear energy as a viable pathway for climate miPgaPon.

Hydrogeological Concerns However, I am shocked at the content of the Triso-X applicaPon and I have very serious reservaPons about the appropriateness of the Horizon Center site (HCS) for this purpose. My main concern is that most of the site is underlain by karst hydrology, which is readily demonstrated in the applicants environmental report. Despite this clear fact, it remains shocking that the applicant states that proximity to karst formaPons is a criterium for site selecPon (SecPon 2.2), and yet the applicant concludes (SecPon 2.2.1) that the site oered no major environmental concerns, in terms of groundwater quality, soil plas%city, karst. I will demonstrate below, using material from the applicants report, and photos from the actual site (Jan-Feb 2023), that there is signi"cant karst hydrology underlying the site. But because the applicant states in SecPon 2.2 that karst is not desirable for their facility, it is then self-evident that HCS is inappropriate for their facility. I understand that measures could potenPally be taken to protect groundwater at the site and permit the facilitys applicaPon to proceed, but the applicant did not bother to oer any.

The applicant repeatedly states or implies that there is no karst on their property (p. 4-26): Sinkhole FormaPon. As summarized in SecPon 3.3.2, no karst features were reported to occur directly on the HCS. Therefore, because there is no reported incidence of sinkholes on the site, and because miPgaPve measures are employed in conjuncPon with the results of a geophysical invesPgaPon as needed, potenPal hazards associated with sinkhole formaPon are SMALL. They also dont acknowledge an actual disappearing stream onsite in their property, even though it is on the naPonal wetlands inventory (NWI) in Fig. 3.4.4-1. This parPcular stream (SD#1 on Fig. 3.4.2-2) drains 138 ac. However, SD#1 is completely missing from Fig. 3.4.4-2 which is their Wetland and Stream DelineaPon of the HCS. On p 3-52 the applicant claims This mapped stream feature was reviewed in the "eld and was determined to be a vegetated swale lacking wetland, stream, or WWC characterisPcs (Figure 3.4.4-2). They claim, in secPon 4.4.2.2.1.1, that because they cannot "nd SD#1 or any surface water "owing, that construcPon acPviPes will have no eect on any surface water. I have visited the greenway behind the site twice since their report was released, and observed a signi"cant amount of "ow underneath a culvert on the greenway, "owing into the site, and "nally disappearing in the soil about halfway across the open "eld of the HCS (see photos below). This is a disappearing stream, a clear indicaPon of a karst feature. When I visited the site in early February, I observed a second disappearing stream about 5 minutes away (by foot) along the greenway road. It appeared to drain into the subsurface beneath the giant sinkhole shown in Figure 2.1-1, which I will discuss shortly. I am also aware of a prominent spring just to the east of the site along the greenway road.

There are two valleys in the HCS property, each trending SW-NE to align with the geology and topography of the Valley and Ridge province. The westernmost valley is underlain by the Mascot Dolomite which is part of the Knox Group, which is known to be heavily karsP"ed (paleokarst). Photos H and I in Fig. 3.9.3-2 show this valley. There are notable karst features visible in these "gures and in my photos above - the circular depressions with trees remaining. The disappearing stream and the lack of surface drainage are both clear indicators of karst hydrology at the site. Of lesser concern is the easternmost valley which is part of the Chickamauga Group which does have some karst features but

contains more clasPc lithology compared to the Knox. The applicant intends to build a detenPon basin in the westernmost valley - on top of the Knox - to capture stormwater drainage from the site. There is a sedimentaPon forebasin and an over"ow backbasin, and at least one of these is unlined. It will sit directly atop the karsP"ed Mascot Dolomite which is a unit within the Knox Group.

They state speci"cally on p 4-30 that stormwater is released from the site detenPon basin at the outlet structure near the western side of the HCS idenP"ed in Figure 2.1-1, to the ground surface at the southwestern porPon of the HCS. Drainage from this locaPon is noted to be conveyed by an exisPng drainage swale to an observed sinkhole feature in the adjacent parcel. The sinkhole is a signi"cant geological feature just to the southwest of the HSC, and is visible on Fig. 2.2-1 (see encircled area below containing both the detenPon basis and the recipient sinkhole). The applicant even states that the intermiNent stream SD#1 terminates at an o-site depression, suggesPng karst topography with apparent surface drainage to groundwater (p 3-48).

THE APPLICANT PROPOSES TO DUMP THEIR STORMWATER INTO A SINKHOLE!!!!!!

THE APPLICANT PROPOSES TO DUMP THEIR STORMWATER INTO A SINKHOLE!!!!!!

THE APPLICANT PROPOSES TO DUMP THEIR STORMWATER INTO A SINKHOLE!!!!!!

I cant imagine any scenarios where this would be appropriate, from a residenPal development to a municipal land"ll - so why in the world would this be appropriate for a nuclear facility?

The sinkhole, in fact, consPtutes the parcel known as ED-1, which the DOE has determined to be a natural area that is to be excluded from development (Fig. 2.3-1). When the Horizon Center was

turned over to CROET and the Oak Ridge Industrial Development Board, a number of areas in between the speci"c development parcels (here, parcel 6b) were set aside to be preserved as natural areas speci"cally because of their important environmental value. They are the light green shading in Fig. 2.3-

1. As described on p3-102, the development areas on the HCS are separated by dedicated green belts which are zoned as Greenbelt Districts by the City of Oak Ridge. The green belts were established by the DOE in 1996 as a miPgaPve measure to reduce impacts of development of the Horizon Center.

Development of the green belt areas has eecPvely protected wildlife habitat, plant communiPes, threatened, or endangered species threatened and endangered species and maintained habitat connecPons to reduce the ecological eects of fragmentaPon. I dont think that diverPng all of the stormwater from the HCS development into a natural area that was designated for the speci"c purpose of miPgaPon of development within the Horizon Center is consistent with the spirit or intent that DOE had when they set aside the natural areas for preservaPon. The applicant concludes that the indirect impacts to o-site wetland resources due to site construcPon phase runo and sedimentaPon are SMALL (SecPon 4.4.4.2.1).

Recently, the City and its Industrial Development Board "oated the idea of a racetrack on the enPre Horizon Center property. Rumor suggests that a major reason that the racetrack did not proceed was speci"cally because it required development of the ED-1 parcel and other similar parcels. Therefore, this inappropriate use of the natural areas is something that should be reevaluated by DOE if the Triso-X project proceeds. Using the ED-1 parcel in a way that was not intended could indeed require revisiPng of the original EIS that allowed the original development of the Horizon Center property.

An important consequence of the plan to discharge stormwater into the sinkhole, of course, is that any uncontrolled outdoor liquid releases at the Triso-X plant would be dicult to capture. This plan risks an unintended release to the groundwater. I understand the applicant idenP"ed the nearest drinking water well as required by the NRC site evaluaPon process, and that there are not many drinking water wells in the vicinity of HCS. However, this logic isnt necessarily valid for karst, where subsurface conduits can rapidly deliver water over long distances in the subsurface. And although I am sPll doubqul that a release into the karst would reach a groundwater well, subsurface karst pathways are likely to provide a rapid connecPon into beleaguered East Fork Poplar Creek, which drains into Poplar Creek and then into WaNs Bar Lake. Perhaps one may think this is unimportant for stormwater, despite my objecPons above regarding the natural area or the inconsistency of such an approach with current regulatory expectaPons. But this situa%on would make impossible the capture of any unintended outdoor releases of liquid nuclear or chemical wastes from the site. The applicant even notes the diculty of making predicPons of "owpaths in karsP"ed landscapes (p 3-43).

The applicant claims that the stormwater drainage into the sinkhole will keep the euent "ow rate at or below the pre-developed site condiPons (p 2-11). They also claim that the detenPon ponds are only capable of holding rainfall from a 1-inch event (p 4-38). Rain events of several inches at a Pme are common in Oak Ridge. If you review the rainfall records from the Oak Ridge area, you will "nd that events of 2-3 inches are very common, and that events of 4-5 are extremely common in both February and July. So the capacity to hold a 1-inch event is enPrely inadequate. Therefore they plan for an emergency spillway to handle 100-year events (p 2-11). Presumably, such a spillway would merely bypass their retenPon pond and go straight into the sinkhole.

Finally, I want to point out the major SAFETY concern that the underlying geology poses to the site. The applicant drilled a total of 13 boreholes, 11 of which had substanPal VOIDS at depths < 40 u. These voids

- of which there were 21 - ranged from 0.2 feet to as much as 4.1 feet (p 3-35). Here is a good place to

pause and let this sink in - there are voids as large as 4 FEET underneath this site. This is consistent with the underlying karst geology concept diagram (Fig. 3.4.1-1). Fig. 3.3.3-4 shows the voids but is depicted with "at-lying rocks, so this "gure is inaccurate (compare with Fig. 3.3.3-5 which shows a more accurate depicPon of the posiPons of the subsurface layering). The applicant notes that the voids are either open or are clay-"lled. The HCS is in a unique locaPon - at the foot of a large forested hillslope - resulPng in several hundred feet elevaPon change from the ridgetop to the valley in which the HCS resides. This amounts to a high hydraulic head at the site, so there is a lot of force behind that subsurface "ow. They propose to capture all the surface drainage and intercepted subsurface drainage, which presumably includes the disappearing stream that I menPon earlier - and divert it to the detenPon basins using a series of engineered channels (Fig. 4.9.2-1). This approach has the potenPal to dewater the soil and shallow groundwater underlying the site. But a unique feature of karst landscapes is that the voids in the rocks are held open by the force of the water in the pores and voids. So, if there is dewatering, then the open voids will be truly open - which greatly increases the chance for a karst collapse. They note that many voids are "lled with clay - this is also a common factor in karst landscapes - but loose clays are also likely to fail if the rocks become desaturated. Such a collapse could endanger the integrity of the plant.

The results of the wells drilled at the site also support a signi"cant karst hydrology underlaying the site.

Wells GW-1, GW-1R, and GW-3 likely permeate the Knox Group, while GW-2 and GW-4 likely permeate the Chickamauga Group. You can see in the groundwater potenPometric elevaPons (Fig. 3.4.1-4, Table 3.4.1-2) that the three former wells have much higher water levels and much more variaPon than the others. The dierence between the two groups of wells suggests they are not hydraulically connected.

Groundwater quality also shows that GW-1, GW-1R, and GW-3 have higher dissolved oxygen and posiPve oxidaPon-reducPon potenPal, both of which are indicaPve of close interacPon with meteoric waters (ie recent recharge), while GW-2 and GW-4 have lower oxygen and negaPve oxidaPon-reducPon potenPal, likely indicaPve of more stagnant waters. The applicant has not even begun to understand the meaning of their well data, as is apparent from the aNempt to draw groundwater contours that combine these two dierent hydrologic units (Figs. 3.4.1-5 and 3.4.1-6). These two hydrogeologic units may or may not be connected to each other, or their connecPons may be so slow as to be negligible. Otherwise, the wells would probably show a lot more geochemical similarity to each other.

If the applicant wishes to use the HCS for the Triso-X plant, a thorough hydrogeological inves%ga%on is required, from a "rm that is quali"ed to perform dye tracing and geophysical methods to determine the subsurface karst and groundwater "ow condi%ons, both on parcel 6a AND on the surrounding BORCE and natural area proper%es, in order to produce a safe and viable plan for site development.

Permi2ng Concerns I am deeply concerned that the City of Oak Ridge will be responsible for permivng at this site. The parcel in quesPon was cleared in 2013 by the Citys Industrial Development Board, without any permits whatsoever, as established in a leNer from Mr Andrews from USFWS (US Fish and Wildlife). The regulaPon requires permivng for any land disturbing acPvity involving over 1 ac of land. Here, the City itself cleared over 600 ac without any permit at all. Consequently, there are no rare or endangered plant communiPes on the HCS parcel, because since 2013 it has been seeded as a lawn and mowed regularly.

This is then used by applicant as a reason for the site to be developed. Therefore, because of its history of blatant disregard for environmental regulaPons, I do not trust the City to correctly oversee the necessary permivng for this site. According to Table 1.4-1, the City will provide permits for land disturbance, building permits, and the NPDES permit for stormwater discharge. The criteria to retain only one inch of rainfall from each event is apparently consistent with the City Stormwater Management

Ordinance (p 4-35). On p 4-31, the applicant claims that the City is capable of sevng criteria for stormwater permivng in karst regions. It is highly unlikely the City has any special knowledge, capabiliPes or meaningful regulaPons regarding karst.

I am also deeply concerned that the Horizon Center is zoned for Industrial-2 (IND-2), and that Industrial-3 (IND-3) will be required for the proposed Triso-X development. Industrial 3 accounts for manufacturing faciliPes that have a greater impact on the surrounding area than industries found in the IND-2 District. Manufacturing or other enterprises with signi"cant external eects, or which pose signi"cant risks due to the involvement of explosives, radioac%ve materials, poisons, pes%cides, herbicides, or other hazardous materials in the manufacturing or other process. It is the intent of this district to provide an environment for industries that are unencumbered by nearby residenPal, insPtuPonal or commercial development. The Horizon Center is not zoned IND-3 because that was not its designated use. The DOE gave the land to the City to promote the Citys economic development, but they did not do so without constraints. One of the constraints is the natural areas, which I addressed above. The other is the zoning that supports the publicly-stated uses of the land. It is a bait-and-switch tacPc to promote the Horizon Center as a place for light industry and manufacturing, for over a decade, and then actually allow virtually any use possible - e.g., a nuclear producPon facility, or a racetrack. I believe that this type of development, and the zoning changes that it requires, should result in the DOE revisiPng the original EIS that allowed for the establishment of the Horizon Center industrial park. I do not have any reason to believe that the City of Oak Ridge would deny the rezoning from IND-2 to IND-3.

I do not believe that their decision would involve any scienP"c raPonale, or to provide any substanPal oversight. Our city does not have the technical capabiliPes or the environmental concerns to oversee permivng on such an important project.

I do know the City is giving the land away for free, which is quite odd, considering the racetrack proposal was supposed to net almost $5M in sales fees.

Surface Water Concerns It is likely that all drainage from the HCS will end up in East Fork Poplar Creek, regardless of the actual "owpath taken. East Fork Poplar Creek is already extensively contaminated, due to decades of releases of mercury from the Y-12 plant (now the NaPonal Nuclear Security AdministraPon facility) beginning in the 1950s and conPnuing unPl now (hNps://www.sciencedirect.com/science/arPcle/abs/pii/S0269749110004112?via%3Dihub). My own scienP"c research demonstrated that of nearly 800 of creekbank samples beginning just downstream of the Y-12 plant and extending nearly to the mouth of East Fork Poplar Creek, only 1 sample did not contain detectable mercury. ConcentraPons in the creekbank soils varied over 4 orders of magnitude, the highest being ~4500 mg of mercury per kg dry weight of soil (mg/kg). ConcentraPons in streambank soils in the vicinity of HCS were approximately 13 mg/kg, and in stream sediments were approximately 16 mg/kg (hNps://link.springer.com/arPcle/10.1007/s11368-018-2183-0). Streambank erosion is a major contributor of mercury to the creek, where it is readily transformed by the microbial community into toxic methylmercury (hNps://setac.onlinelibrary.wiley.com/doi/10.1002/etc.3310). Methylmercury poses a risk to the enPre ecosystem because it is toxic and because it becomes biomagni"ed through the food chain. Consequently, increases in storm "ow to East Fork Poplar Creek as a consequence of collecPon of site runo at the HCS has the potenPal to alter erosion and therefore the delivery of mercury into East Fork Poplar Creek and Poplar Creek and WaNs Bar Lake; and such mercury mobility also increases the probability of transformaPon into toxic methylmercury which bioaccumulates in invertebrates, birds, "sh and throughout the environment. Finally, many parts of East Fork Poplar Creek are over regulatory limits for phosphorus, nitrate, nitrate, PCB, sediments, fecal coliform, E coli, and of

course mercury (p 3-50). It seems that East Fork Poplar Creek already bears a strong legacy of contaminaPon from DOE and from the city wastewater treatment system. It is hard to imagine that the proposed plan for land and stormwater modi"caPon at Triso-X would be helpful to East Fork or its downstream environs, which are used extensively for recreaPon and "shing. I do not agree with the "nding (p 4-39) that the impacts to the quality of receiving waters from the operaPon of the TRISO-X FFF are SMALL.

Other Concerns I did not "nd any substanPal informaPon in this applicaPon regarding the potenPal for a criPcality incident or any other unintended release of radionuclide materials or causPc materials such as nitric or other acids, bases, or solvents. I expected that the potenPal for unintended releases would consPtute an important part of an environmental and safety review. The applicant simply claims all materials would be disposed of via process drains to the Oak Ridge sanitary sewer system. I dont believe this is adequate for such a risky endeavor as we are dealing with here - involving nuclear materials, and using a new process that has not been tested at scale.

The Black Oak Ridge ConservaPon Easement (BORCE) was established to help miPgate the history of negaPve impacts of the Oak Ridge ReservaPon on the areas wildlife and people. The BORCE is immediately adjacent to the HCS parcel, and it surrounds the enPre Horizon Center area. The applicant notes the purpose and value of BORCE on p 3-109, staPng that it provides valuable rare forest interior that serves as habitat for uncommon wildlife and nesPng and migratory birds. Yet the applicant de"nes the scope of impact of their acPviPes as only reaching to the edges of the HCS parcel 6a. They admit there will be noise polluPon, but do not evaluate its eect upon the BORCE - or upon the community greenway trail that forms the boundary between their parcel and the BORCE. They do not acknowledge or address what will undoubtedly be a tremendous amount of light polluPon. Such light polluPon will break up the darkness that is right now the coupled Horizon Center site and BORCE. This has the potenPal for interfering with migratory birds and other wildlife. There is a leNer from the USFWS (US Fish and Wildlife) that states that there is a potenPal for bat habitat on the HCS parcel. But the applicant does not address how or if they will maintain the bat habitat, or whether bats would be impacted by their light or noise polluPon. This kind of development will undoubtedly have a tremendous impact on the quality of wildlife habitat of BORCE, yet it remains enPrely unexamined by the applicant. They act as if the only relevant issue is what happens within the con"nes of parcel 6a.

Thank you for the opportunity to comment, and I hope these comments are helpful in guiding your review. Please look out for our town.

Sincerely, Melanie Mayes, on behalf of the Harvey Broome Group of the Sierra Club