ML23214A388
| ML23214A388 | |
| Person / Time | |
|---|---|
| Issue date: | 08/10/2023 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| Download: ML23214A388 (8) | |
Text
1 U.S. Nuclear Regulatory Commission Pre-Application Site Visit Trip Report Carbon Free Power Project May 15-19, 2023 Overview On May 15-19, 2023, staff from the U.S. Nuclear Regulatory Commission (NRC) and Pacific Northwest National Laboratory (PNNL) traveled to Idaho Falls, ID and the Idaho National Laboratory (INL) site to participate in a site visit and readiness assessment with the potential applicant for the proposed Carbon Free Power Project (CFPP). This visit was part of meetings held by a larger NRC group, including staff from the Office of Nuclear Reactor Regulation and Regions. During the visit, the NRC environmental staff1 also met with staff from the Department of Energy Office of Nuclear Energy (DOE-NE) and Idaho National Lab (DOE-ID) to discuss the potential for coordination on environmental reviews associated with the planned applications. The NRC staff met separately with cultural resource program staff of the Shoshone-Bannock Tribes to discuss the proposed project and the NRC review process, including the National Historic Preservation Act (NHPA) Section 106 review and consultations.
Purposes
Familiarize the NRCs expanded environmental review team (including PMs and SMEs from PNNL) with the applicant and the proposed site for the CFPP at INL.
Perform Phase 3 of the readiness assessment to review, discuss and provide general feedback to the applicant on select sections of the limited work authorization (LWA), expected to be submitted July 31, 2023.
Continue discussions with the applicant on the proposed licensing approach, impacts on the subsequent National Environmental Protection Agency (NEPA) project schedules and information expected in the environmental report of each submittal based on applicable regulations and guidance.
Meet with key staff from the Department of Energy (DOE) to discuss the potential for cooperation and/or coordination on the NEPA review and the NHPA Section 106 review and consultations.
Meet with and further develop a relationship of trust with the Shoshone-Bannock Tribes cultural resource management staff and the Fort Hall Business Council on the Fort Hall Reservation.
NRC/PNNL Team The following staff supported the activities associated with the site visit and readiness assessment. Details related to their affiliation and project role and located in the table.
Some staff who were not in person supported various meetings virtually (denoted by the asterisk).
1 References to NRC staff in this report includes PNNL contract staff, unless otherwise noted.
2 Name Project Role US NRC Dan Barnhurst Project Manager, Proposed Action, Purpose and Need, Plant Description, Water Resources Gerry Stirewalt Project Manager, Proposed Action, Purpose and Need, Cultural and Historic Resources, Water Resources Brian Glowacki Air Resources, Alternatives Don Palmrose Radiological and Non-radiological Health, Waste Management, Fuel Cycle, Accidents, Transportation, Decommissioning Mary Casto (NRAN)
Ecological Resources, Land Use Shelley Pitter PM (rotation)
Chris Regan NMSS/REFS Division Director Lucieann Vechioli MSST Tribal Liaison Peyton Doub*
Ecological Resources, Land Use Zachary Gran*
Radiological and Non-radiological Health Ed Stutzcage*
Radiological and Non-radiological Health PNNL Ann Miracle Project Manager, Ecological Resources Stephanie Johansen PM Dave Goodman Alternatives Dave Anderson Socioeconomics/Environmental Justice, Cost-Benefit Phil Meyer Water Resources Lindsey Renaud Cultural and Historic Resources Tara ONeil Cultural and Historic Resources Quanah Spencer Tribal Engagement Kim Leigh Non-radiological Health Bo Saulsbury Land Use, Cumulative Impacts Katie Wagner Program Management Becka Bence*
Water Resources Rajiv Prasad*
Water Resources Kazi Tamaddun*
Water Resources Tracy Fuentes*
Ecological Resources, Land Use Jon Napier*
Accidents, Decommissioning, Fuel Cycle, Transportation Harish Gadey*
Waste Management, Radiological health Lin Zeng*
Socioeconomics/Environmental Justice Kendall Parker*
Socioeconomics/Environmental Justice Julia Flaherty*
Air Resources Lexie Goldberger*
Air Resources
- Virtual attendee
3 Schedule of Activities A schedule of activities, topics of discussions and attendees is provided in the following table.
Time Activity Attendees Tuesday, May 16 NRC PNNL Other 8:00 AM-12:00 AM Entrance Meeting, Initial Discussions, Project Overview Environmental Review Team CFPP Environmental Team, DOE staff, Shoshone-Bannock Tribal Representatives 1:00 PM-6:00 PM CFPP Proposed Site Visit Environmental Review Team CFPP Environmental Team, DOE staff, Shoshone-Bannock Tribal Representatives Wednesday, May 17 8:00 AM-9:30 AM Combined Environmental Discussions Overview of project, site activities, and licensing
- approach, Section 3.3 Environmental Review Team CFPP Environmental Team, DOE Staff 9:45 AM-11:45 AM LWA ER Readiness Assessment Breakouts Water Resources (Sections 2.2 and 4.2)
Dan Barnhurst Gerry Stirewalt Phil Meyer Becka Bence*
Rajiv Prasad*
Kazi Tamaddun*
Brian Lipinsky (Rizzo)
Jeff Schubert* (Rizzo)
William Dam (Flour)
Kevin Kostelnik (Flour)
Betsy Holmes (DOE-ID)
Beth Dalick (NuScale)
Fehmida Messania (NuScale)
Land Use and Ecological Resources (Sections 4.1, 4.3 and App A:
Consultation)
Peyton Doub*
Mary Casto Ann Miracle Tracy Fuentes*
Bo Saulsbury Dana Vesty*
Mary Todd-Robertson (Flour)
Roy Woodward (Flour)
Brad Brown (DOE-ID)
4 Non-Rad Health, Rad Health, Non-Rad Waste Management and Rad Env Monitoring (Sections 4.8, 4.9, 4.10. and 4.11)
Don Palmrose Shelley Pitter Zach Gran*
Ed Stutzcage*
Kim Leigh Stephanie Johansen Jon Napier*
Harish Gadey*
Heather Berg (Flour)
Amanda Stevenson (Flour)
Paranda Smith (Flour) 12:30 PM-2:30 PM LWA ER Readiness Assessment Breakouts Air Resources (Sections 2.7 and 4.7)
Brian Glowacki Julia Flaherty*
Lexie Goldberger*
Brian Lipinsky (Rizzo)
William Dam (Flour)
Bob Golus* (North Wind Group)
Socio/EJ (Sections 4.4 and 4.5)
Joe O'Hara*
Dave Anderson Lin Zeng*
Kendall Parker*
Mary Todd-Robertson (Flour)
Roy Woodward (Flour)
Brad Brown (DOE-ID)
Historic and Cultural Resources (Sections 4.6 and App A:
Consultation)
Gerry Stirewalt Shelley Pitter Lucieann Feliciano Lindsey Renaud Tara O'Neil Heather Berg (Flour)
Amanda Stevenson (Flour)
Betsy Holmes (DOE-ID) 2:45 PM-5:30 PM Combined Environmental Discussions (Sections 7.1, 7.2, 10.1 through 10.6) and Wrap-up Entire Team CFPP Environmental Team, DOE Staff Thursday, May 18 9:00 AM-11:00 AM DOE/NRC Discussion on CFPP Environmental Reviews Chris Regan Dan Barnhurst Don Palmrose Shelley Pitter Mary Casto Lucieann Feliciano Ann Miracle Stephanie Johansen Tara O'Neil Lindsey Renaud Quanah Spencer Melissa Bates (DOE-NE)*
Jason Tokey (DOE-NE)
Brad Brown (DOE-ID)
Jason Anderson (DOE-ID)
Betsy Holmes (DOE-ID)
Venessa Jim (DOE-ID)
Doug Herzog (DOE-ID)
5 Craig Richins (DOE-ID)
Chris Harvey (DOE-ID)
Brayton Ford (DOE-ID)
AM USGS Core Library Gerry Stirewalt None Various project and agency staff Friday, May 19 9:30 AM-11:30 AM Shoshone-Bannock Tribes Cultural Resource Management Staff Chris Regan Dan Barnhurst Gerry Stirewalt Don Palmrose Ann Miracle Stephanie Johansen Tara O'Neil Quanah Spencer Lindsey Renaud Larae Bill (Shoshone-Bannock Tribes Interim Tribal DOE Manager)
Anna Bower (Shoshone-Bannock Tribes)
Kyle Denny (Shoshone-Bannock Tribes)
Venessa Jim (DOE-ID)
Betsy Holmes (DOE-ID)
- Virtual attendee
6 Summary of Key Messages and Observations May 16 and 17, 2023 - Site Visit and LWA Readiness Assessment with the CFPP team, NRC and DOE
The CFPP team will provide a LWA and combined license application (COLA) as part of the phased licensing approach described in 10 CFR 2.101(a)(9). The LWA will be submitted with an exemption request in July 2023. The COLA application is expected in January 2024.
On Tuesday, May 16th, the CFPP project team, DOE, and NRC staff visited areas of interest to the project. These included:
o A brief visit to the lava flows, where the NRC was given an overview of eastern Snake River Plain volcanics.
o A visit to the proposed CFPP site. Staff discussed characterization efforts, including cultural resource surveys and biological surveys, were shown drawings of site plans and potential building locations, and saw and discussed boring locations, monitoring well locations and meteorological towers used for data collection.
o Representatives from the Shoshone-Bannock Tribes cultural resource team attended to share perspectives on the survey efforts and important cultural and natural resources.
On Wednesday, May 17th, the CFPP project team, DOE and the NRC staff participated in review and discussion of LWA sections that were a part of Phase 3 of the pre-application readiness review. During this time, staff reviewed and provided feedback on completed sections that had been made available in the electronic reading room and participated in overview discussions on the content for sections that were not yet complete.
Specific staff observations from the entire readiness assessment will be provided in a separate summary report. High-level observations from May 16th and 17th include:
o For most subject areas, the staff did not find any significant issues.
o In general, sections that were available for review appeared to be comprehensive, included a description of rationale and methodology and followed regulations and applicable guidance.
o The NRC staff did identify concerns with the approach to cultural resources review and discussed the potential for CFPP to consider avoidance of potential impacts to cultural resources. In addition, staff discussed the potential for the phased licensing approach to result in a more complex Section 106 review and consultation process.
o The NRC staff also identified concerns regarding the initial approach to the cumulative impact evaluation and discussed the importance of addressing cumulative impacts for all stages of the project (preconstruction, LWA, COLA) while considering past, present, and reasonably foreseeable actions.
o CFPP staff acknowledged the issues identified above and the resolution is ongoing.
7
The NRC and CFPP staff discussed the application of the NRC NEPA review process to the applicants proposed licensing approach, including the potential for challenges related to conducting overlapping environmental reviews.
The NRC staff reiterated that submittal of a quality application contributes significantly to effective and efficient reviews and that continued pre-application efforts will enhance the quality of applications (see ML13059A239). The NRC and CFPP staff discussed the potential for future pre-application efforts for the COLA application.
May 18, 2023 - Meeting with DOE
The NRC met with staff from DOE Office of Nuclear Energy and DOE-ID to discuss the CFPP licensing strategy and possible areas of coordination between the agencies on the resultant NEPA reviews and related NHPA Section 106 reviews and consultations.
The NRC and DOE staff discussed the possibility of cooperating on a combined environmental assessment addressing the impacts of activities that are not included under the NRC definition of construction (per 10 CFR 50.10(a)(2)) and those associated with the proposed NRC exemption request.
The NRC and DOE staff discussed potential ways to reduce the complexity of the NHPA Section 106 reviews and resultant burden on the State Historic Preservation Office and Tribes. This discussion included the possibility of DOE completing an overarching Section 106 review encompassing all proposed activities within the areas of potential effect at the proposed site.
A list of action items was developed that would facilitate future decision making on these discussion topics.
May 18, 2023 - Visit to USGS Core Facility at INL
CFPP plans to use groundwater from the Snake River Plane aquifer that underlies the proposed CFPP site for the plant (excluding cooling).
One NRC staff member visited the core facility to examine the core and core log from borehole B-01 and discuss data related to the aquifer and aquicludes with the Rizzo geologist who logged the log.
The aquifer lies between 570-739 feet below the ground surface at the site and comprises fractured basalts, rubbly zones at the tops of flows, and sedimentary interbeds.
May 19, 2023 - Meeting with the Shoshone-Bannock Tribes
The NRC staff traveled to the Fort Hall Reservation of the Shoshone-Bannock Tribes to conduct meetings with the Fort Hall Business Council and tribal cultural resource management staff.
The Fort Hall Business Council meeting with NRC that was scheduled for Friday, May 19th, was cancelled due to a funeral. The NRC staff were invited to return to meet with the newly elected Fort Hall Business Council at a later date.
The NRC and DOE-ID staff met with tribal cultural resources management staff to discuss the CFPP project, the proposed licensing approach, and the DOE and
8 NRC NEPA review processes which include the NHPA Section 106 review and government to government consultation.
The NRC staff sought input from the Tribes on concerns, items of interest and ways to ensure meaningful preapplication engagement and consultation throughout the upcoming review process.
Discussion topics included transportation, waste management, postulated accidents, and the potential impacts of the project on human health, the environment, and cultural resources.
NRC will work to maintain a relationship of trust with the Shoshone-Bannock Tribes for the potential CFPP review and potential future reviews.