ML23215A004
| ML23215A004 | |
| Person / Time | |
|---|---|
| Issue date: | 08/11/2023 |
| From: | Daniel Barnhurst NRC/NMSS/DREFS/ENRB |
| To: | Kenneth Erwin NRC/NMSS/DREFS/ENRB |
| References | |
| Download: ML23215A004 (23) | |
Text
Pre-Application Readiness Assessment of Selected Sections of the Carbon Free Power Project draft Limited Work Authorization and Combined License Application Environmental Reports
Background
In a letter dated February 23, 2023, NuScale Power, LLC (NuScale) requested that the U.S.
Nuclear Regulatory Commission (NRC) staff conduct a pre-application readiness assessment of selected sections of the Carbon Free Power Project (CFPP) draft Limited Work Authorization (LWA)1 and Combined License Application (COLA)2 Environmental Reports (ER) prior to planned submittals in July 2023 and January 2024, respectively.
In that letter, NuScale requested that the NRC staff perform a phased review of selected sections beginning in March and lasting until May 2023. The purpose of this readiness assessment review was to:
help the NRC staff understand the detail in the draft application, identify any major issues or information gaps between the draft application and the technical content required to be included in the application submitted to the NRC and, identify any issues that would be considered a potential docketing issue, so that NuScale can prioritize the NRCs observations and address prior to submittal.
Draft sections were to be uploaded to the electronic reading room (ERR) for review. Content discussions were to be held for sections that were not complete enough for draft submittal.
Observations made by the NRC staff on the ER sections were to be discussed during biweekly meetings with NuScale and Fluor personnel.
NRC Review In a letter dated March 14, 20233, NRC provided its plan to conduct this phased readiness assessment and initiated review activities with the kick-off meeting for Phase 1 of the review on March 20, 2023. The NRC readiness assessment was performed in accordance with guidance presented in LIC-116 Preapplication Readiness Assessment4 and the White Paper on Pre-application Engagement5.
The readiness assessment occurred in four phases and consistent biweekly discussions were held between staff from NRC, NuScale, CFPP, and Fluor to discuss observations from these phased reviews. Beginning in mid-April, the NRC staff were aided in review efforts by task leads and subject matter experts form Pacific Northwest National Laboratory. General information for each phase, including phase names, kick-off dates, and biweekly meeting dates for each phase are provided in table 1, below. In an email dated May 31, 2023, NuScale requested that Phase 3 be extended from the end of May to June 16, 2023, to allow for follow-up discussions on previously reviewed sections and initial review and content discussions on several additional sections.
1 ML23054A250 2 ML23054A263 3 ML23067A301 4 ML20104B698 5 ML21145A106 1
Table 1: General Readiness Review Phase Information Readiness Assessment Phase Phase Timeframe Meetings Phase 1 March 20-31, 2023 March 21, 23, 28, and 30 Phase 2a April 3-14, 2023 April 4, 13, 18, and 20 Phase 2b April 24-May 11, 2023 April 24 and 27 May 4, 9, and 11 Phase 3 May 1-June 16, 2023 May 16 and 17 (site visit)
May 23, 25, and 30 June 1, 8, 13, and 15 During the phased review, the NRC staff provided observations on draft sections that were made available for review in the ERR. The NRC staff also participated in discussions with NuScale, CFPP, Fluor, and contract staff on proposed content and technical approach for sections that were not ready for review. Many of these content discussions occurred during the May site visit. A description of the LWA and COLA sections reviewed and discussed in each phase, the format of the staffs review (draft text or content discussion), and submittal and discussion dates are provided in table 2.
NRC Observations As part of the readiness review, the staff made observations regarding whether the sections contained issues that might create challenges with regard to acceptance or potentially require submittal of additional information after the application was submitted. However, as explained in the NRCs March 14, 2023, letter to NuScale, the readiness assessment is not part of the NRCs official acceptance review process, and observations from the readiness assessment do not predetermine whether the LWA or COLA will be docketed upon submittal.
Observations from each phase of the NRC staffs readiness assessment of selected sections of the ER for the LWA and COLA are located in the following tables:
Table 3: Phase 1 Readiness Assessment Results Summary Table 4: Phase 2a Readiness Assessment Results Summary Table 5: Phase 2b Readiness Assessment Results Summary Table 6: Phase 3b Readiness Assessment Results Summary In general, the ER sections that were available for review appeared to be comprehensive, contained an adequate description of rationale and methodology, and followed applicable regulations and guidance. Based on the review and discussions, staff did not identify any significant information gaps or policy issues that could complicate the staffs acceptance review.
However, the observations summarized in table 3 through 6 might require additional clarification or information to enable staff to complete their technical review after the application is accepted.
As indicated, the observations summarized in these tables have been discussed with NuScale, 2
Fluor, and contract staff in biweekly meetings and at the May site visit (see table 2 for specific dates) and relevant details of these discussions are included in the summary table for each phase.
Based on a request from NuScale, staff anticipates that a readiness assessment for additional sections of the COLA will occur in late summer or early fall of 2023.
3
Table 2: Environmental Readiness Assessment Phase Summary Document Section Title Review Format Section Provided to NRC Discussion Date Readiness Assessment Phase 1: Review dates March 20-31 (Kickoff meeting held March 20, 2023)
LWA 1.0 Introduction Draft Text Review 3/20/2023 3/23/2023 LWA 1.1 Plant Owner and Reactor Type Draft Text Review 3/20/2023 3/23/2023 LWA 1.2 Proposed Action and Purpose and Need Draft Text Review 3/20/2023 3/23/2023, 5/17/23*
LWA 1.3 Planned Activities and Schedule. Draft Text Review 3/20/2023 3/23/2023 LWA 1.4 Status of Compliance Draft Text Review 3/20/2023 3/23/2023 2.0 The Proposed Site and the Affected LWA Environment Draft Text Review 3/20/2023 3/23/2023 LWA 2.1 Land Use Draft Text Review 3/20/2023 3/28/2023 Readiness Assessment Phase 2a: Review dates April 3-14 (Kickoff meeting held April 3, 2023)
LWA 2.8 Non-Radiological Resources Draft Text Review 4/3/2023 4/18/2023 2.9 Radiological Environment and LWA Radiological Monitoring Draft Text Review 4/3/2023 4/18/2023 COLA 8.0 Need for Power Draft Text Review 4/3/2023 4/20/23, 5/4/2023 Readiness Assessment Phase 2b: Review dates April 24- May 11, 2023 LWA 2.3 Ecological Resources Draft Text Review 4/10/2023 4/20/2023 LWA 2.4 Socioeconomics Draft Text Review 4/24/2023 5/9/2023. 5/25/23 LWA 2.5 Environmental Justice Draft Text Review 4/24/2023 5/9/2023, 5/25/23 LWA 2.6 Historic and Cultural Resources Draft Text Review 4/24/2023 5/11/2023 Draft Text Review/
COLA 9.0 Alternatives Content Discussion 4/24/2023 5/4/2023, 5/17/23*
Readiness Assessment Phase 3: Review dates May 1- June 16, 2023 Content Discussion/Draft Text LWA 2.2 Water Resources Review 6/2/2023 5/17/2023*, 6/15/23 LWA 2.7 Air Resources Content Discussion Not submitted for review 5/17/2023*
4
Content Discussion/Draft Text LWA 3.3 Building Activities Review Week of May 8,2023 5/17/2023*
Content Discussion/Draft Text LWA 4.0 Construction Impacts of LWA Activities Review 5/31/2023 6/8/2023 Content Discussion/Draft Text LWA 4.1 Land Use Review 5/31/2023 5/17/2023*, 6/8/23 LWA 4.2 Water Resources Content Discussion Not submitted for review 5/17/2023*
LWA 4.3 Ecological Resources Content Discussion Not submitted for review 5/17/2023*
LWA 4.4 Socioeconomics Content Discussion Not submitted for review 5/17/2023*
LWA 4.5 Environmental Justice Content Discussion Not submitted for review 5/17/2023*
LWA 4.6 Historic and Cultural Resources Content Discussion Not submitted for review 5/17/2023*
LWA 4.7 Air Resources Content Discussion Not submitted for review 5/17/2023*
LWA 4.8 Non-Radiological Health Content Discussion Not submitted for review 5/17/2023*
Content Discussion/Draft Text LWA 4.9 Radiological Environmental Monitoring Review week of 5/15/23 5/17/2023*
LWA 4.10 Non-Radiological Waste Management Content Discussion Not submitted for review 5/17/2023*
4.11 Measures and Controls to Limit LWA Adverse Impacts during Construction Content Discussion Not submitted for review 5/17/2023*
7.1 Past, Present and Reasonably LWA Foreseeable Future Projects Content Discussion Not submitted for review 5/17/2023*, 6/13/23 LWA 7.2 Impact Assessment Content Discussion Not submitted for review 5/17/2023*, 6/13/23 LWA 10.1 Impacts of Proposed Actions Content Discussion Not submitted for review 5/17/2023*
10.2 Unavoidable Adverse Environmental LWA Effects Content Discussion Not submitted for review 5/17/2023*
10.3 Relationship between Local Short-Term Use of Environment and Long-Term LWA Productivity Content Discussion Not submitted for review 5/17/2023*
10.4 Irreversible and Irretrievable LWA Commitment of Resources Content Discussion Not submitted for review 5/17/2023*
5
LWA 10.5 Alternatives to the Proposed Action Content Discussion Not submitted for review 5/17/2023*
LWA 10.6 Benefits and Costs Content Discussion Not submitted for review 5/17/2023*
Content Discussion/Draft Text LWA App A: Consultation Review 6/2/2023 5/17/2023*, 6/13/23 Content Discussion/Draft Text LWA App B: Env Protection Plan Review 6/2/2023 6/13/2023 LWA Redress Plan Content Discussion Not submitted for review 6/8/2023
- Discussions which occurred on 5/17/23 took place as part of the site visit.
Italicized text- Section was under development during the readiness assessment and drafts were not provided to the NRC for review. Contents were discussed during and after the May 2023 site visit (as noted).
6
Table 3: Phase 1 Readiness Assessment Results Summary (Review dates March 20-31, 2023)
Observation Document Section/Subsection Observation Observation Discussion/ Resolution Number Title Source*
1 LWA 1.0 Introduction Draft Text Section 1.0 (Introduction) should be updated These issues were identified Review to mention LWA activities, scope, and and discussed in one of the application. biweekly readiness assessment meetings.
2 LWA 1.1 Plant Owner and Draft Text Nothing presented gave any cause for concern These issues were identified Reactor Type Review with CFPPs ability to provide adequate and discussed in one of the information as part of their LWA application in biweekly readiness assessment this area. meetings.
3 LWA 1.2 Proposed Action Draft Text The purpose and need both follow guidance These issues were identified and Purpose and Review from RG 4.2 developed for a COL, not a LWA. and discussed in one of the Need The discussion should be edited to reflect biweekly readiness assessment issuance of a LWA as the proposed federal meetings. CFPP revised Section action. The purpose should relate to a LWA for a 1.2 to focus on the LWA scope.
defined set of activities (listed out) to support a proposed early construction date. Development and clear articulation of an accurate purpose and need is vital because it drives the list of reasonable alternatives to be considered and presented in the LWA EIS.
4 LWA 1.3 Planned Activities Draft Text Nothing presented gave any cause for concern These issues were identified and Schedule. Review with CFPPs ability to provide adequate and discussed in one of the information as part of their LWA application in biweekly readiness assessment this area. meetings.
5 LWA 1.4 Status of Draft Text Nothing presented gave any cause for concern These issues were identified Compliance Review with CFPPs ability to provide adequate and discussed in one of the information as part of their LWA application in biweekly readiness assessment this area. meetings.
6 LWA 2.0 The Proposed Draft Text Nothing presented gave any cause for concern These issues were identified Site and the Affected Review with CFPPs ability to provide adequate and discussed in one of the Environment information as part of their LWA application in biweekly readiness assessment this area. meetings.
7
7 LWA 2.1 Land Use Draft Text Section 2.1 touches on all of the main bases for These issues were identified Review characterizing the land use baseline for an ER and discussed in one of the and then an EIS. However, staff believe that biweekly readiness assessment further information is needed regarding land to meetings.
be used as vehicular entrance to site including identification of land occupied by new entrance roadways.
8 LWA 2.1 Land Use Draft Text The land use discussion should break out and These issues were identified Review quantify land by temporary and permanent and discussed in one of the disturbance, on the site, ROW and applicable biweekly readiness assessment offsite areas. meetings.
9 LWA 2.1 Land Use Draft Text Further information is needed to understand These issues were identified Review the amount of grazing land taken out of service and discussed in one of the due to proximity of site and related BLM biweekly readiness assessment approvals. meetings.
10 LWA 2.1 Land Use Draft Text Clarification is needed to understand if Figure These issues were identified Review 2.1-22 indicates that some land offsite of the and discussed in one of the CFPP and INL may be impacted. biweekly readiness assessment meetings.
- Observations resulting from review of draft text were discussed with the applicant during biweekly readiness assessment meetings held between March and June 2023. Most observations resulting from content discussions came primarily from meetings held during the May 2023 site visit on sections that had not been submitted to the NRC staff for review. In some cases, additional observations were discussed during the May 2023 site visit on previously submitted sections. In addition, observations were developed on draft text submitted for review after the May 2023 site visit.
8
Table 4: Phase 2a Readiness Assessment Results Summary (Review dates April 3-14, 2023)
Observation Document Section/Subsection Observation Observation Discussion/ Resolution Number Title Source*
1 LWA 2.8 Non-Radiological Draft Text Detailed information is presented for etiological These issues were identified Resources Review agents that may not be present in the CFPP and discussed during the May area. 2023 site visit.
2 LWA 2.8 Non-Radiological Draft Text There is text about chemical hazards at INL, These issues were identified Resources Review industrial hygiene monitoring at INL, and a and discussed during the May survey of chemicals within 5 miles of the CFPP 2023 site visit.
site. Information about specific chemicals to be used at CFPP should be provided.
3 LWA 2.8 Non-Radiological Draft Text The section includes discussion of occupational These issues were identified Resources Review injuries by industry sector and by event or and discussed during the May exposure. This discussion should include site visit.
occupational injury data specific to INL.
4 LWA 2.9 Radiological Draft Text Nothing presented gave any cause for concern These issues were identified Environmental and Review with CFPPs ability to provide adequate and discussed in one of the Radiological information as part of their LWA application in biweekly readiness assessment Monitoring this area. Staff note that a direction should be meetings.
given from the site to Howe, ID.
5 COLA 8.0 Need for Power Draft Text Further information is needed in the ER to These issues were identified Review understand if Idaho has a Certificate of Need and discussed in one of the Process (CPCN), if CFPP is applying for a CPCN biweekly readiness assessment and what the timeline of this might be. In meetings. CFPP understood the addition, further detail should be provided on need to provide the whether the CFPP plant will be a merchant or information.
utility owned plant.
- Observations resulting from review of draft text were discussed with the applicant during biweekly readiness assessment meetings held between March and June 2023. Most observations resulting from content discussions came primarily from meetings held during the May 2023 site visit on sections that had not been submitted to the NRC staff for review. In some cases, additional observations were discussed during the May 2023 site visit on previously submitted sections. In addition, observations were developed on draft text submitted for review after the May 2023 site visit.
9
Table 5: Phase 2b Readiness Assessment Results Summary (Review dates April 24- May 11, 2023)
Observation Document Section/Subsection Observation Observation Discussion/ Resolution Number Title Source*
1 LWA 2.3 Ecological Draft Text The analysis should address existing conditions These issues were identified Resources Review on the proposed offsite rights-of-way (ROWs). and discussed in one of the Staff note that an adequate description could biweekly readiness be compiled from material provided for the assessment meetings. CFPP surrounding landscape. indicated that ROW survey is part of work occurring this spring but there are also multi-decadal INL surveys that are currently available and will inform the review.
2 LWA 2.3 Ecological Draft Text There is no formal wetland delineation for the These issues were identified Resources Review CFPP site or ROWs. A wetland delineation and discussed in one of the report covering the CFPP site and ROWs, or a biweekly readiness statement developed based on the Corps of assessment meetings. CFPP Engineers Wetlands Delineation Manual and indicated they would find supplementary guidance supporting a and provide an existing conclusion that no wetlands are present is document with a wetland needed. determination indicating no jurisdictional wetlands at INL. During the May 2023 site visit, the CFPP again indicated they would provide further clarification on jurisdictional wetlands.
3 LWA 2.3 Ecological Draft Text The ER section should document whether These issues were identified Resources Review offsite ROW might cross Waters of US and discussed in one of the associated with Big Lost River. biweekly readiness assessment meetings. CFPP indicated that only the power lines will cross the Big Lost River using the 10
existing ROW (not the pipeline).
4 LWA 2.3 Ecological Content A discussion of sage grouse habitat should be These issues were identified Resources Discussion included, potentially in the COL ER. and discussed during the May 2023 site visit.
5 LWA 2.4 Socioeconomics Draft Text Further information should be provided on These issues were identified Review whether there any existing community benefits and discussed in one of the payments or payment in lieu of taxes made for biweekly readiness activities on the INL site as this information can assessment meetings. CFPP provide context for the impacts of future understood the need to community benefit payments. provide the information.
6 LWA 2.4 Socioeconomics Draft Text Further information should be provided about These issues were identified Review the workforce (pre-construction, construction, and discussed in one of the etc.), such as residence of current and projected biweekly readiness employees at INL site (breakdown by county) assessment meetings. CFPP and how they may impact the local understood the need to communities/resources. provide the information.
7 LWA 2.5 Environmental Draft Text Nothing presented gave any cause for concern These issues were identified Justice Review with CFPPs ability to provide adequate and discussed in one of the information as part of their LWA application in biweekly readiness this area. assessment meetings.
8 LWA 2.6 Historic and Draft Text Information should be provided on whether an These issues were identified Cultural Resources Review SOI qualified archaeologist was utilized for the and discussed in one of the review. biweekly readiness assessment meetings. CFPP understood the need and will clarify the role of the INL archeologists.
9 LWA 2.6 Historic and Draft Text Clarification on the various APEs is needed These issues were identified Cultural Resources Review (LWA, pre-COLA, COLA, etc.) in order to and discussed in one of the understand the direct vs. indirect APEs, biweekly readiness descriptions of activities covered under each assessment meetings. CFPP APE, and associated acreage or a map of each. understood the need and will better explain in the documents and in-person during the pre-app trip.
11
10 LWA 2.6 Historic and Draft Text Further information is needed on the These issues were identified Cultural Resources Review prehistoric context including an adequate and discussed in one of the history of what happened prior to European biweekly readiness arrival and whether other Tribes that may have assessment meetings. CFPP historically used this area. will add some more information on the prehistoric context.
11 LWA 2.6 Historic and Draft Text Clarification should be provided on what These issues were identified Cultural Resources Review surveys have been conducted and what and discussed in one of the resources are present within the APEs. More biweekly readiness information needed on whether surveys and assessment meetings, at results from October 2022 and spring 2023 the May 2023 site visit, and surveys have been incorporated. in subsequent meetings. All parties have discussed the potential need for NRC staff to access summary reports.
12 LWA 2.6 Historic and Draft Text Figures and photos that are referenced These issues were identified Cultural Resources Review throughout document are missing. and discussed in one of the biweekly readiness assessment meetings.
Figures will be included when available.
13 LWA 2.6 Historic and Draft Text Clarification should be provided on the These issues were identified Cultural Resources Review differences between Class I, II, and III and discussed in one of the inventories. biweekly readiness assessment meetings. CFPP will clarify the difference between classes in future submittals.
14 LWA 2.6 Historic and Draft Text Sensitive cultural information, such as site These issues were identified Cultural Resources Review numbers or sacred areas, needs to be redacted and discussed in one of the or removed. biweekly readiness assessment meetings and the May 2023 site visit.
CFPP will determine the path for omitting sensitive 12
cultural resources information.
15 LWA 2.6 Historic and Draft Text The section should address whether staff These issues were identified Cultural Resources Review members of the State Historic Preservation and discussed in one of the Office (SHPO) have been engaged. biweekly readiness assessment meetings and the May 2023 site visit. INL archaeologists have had conversations with SHPO, and determinations are being worked on between DOE and SHPO.
16 COLA 9.0 Alternatives Draft Text Some of the information from the site selection These issues were identified Review study may need to be carried into Section 9.3 to and discussed in one of the provide sufficient context. biweekly readiness assessment meetings and the May 2023 site visit.
17 COLA 9.0 Alternatives Draft Text Further context should be provided to Section These issues were identified Review 9.4.3 to support the statement that alternative and discussed in one of the system designs are not warranted. biweekly readiness assessment meetings and the May 2023 site visit.
Guidance in RG4.2 indicates that alternatives are limited design when the purpose and need is for demonstration of a new design.
18 COLA 9.0 Alternatives Content Regarding site alternatives, the Site Selection These issues were identified Discussion Study developed by the applicant appears to be and discussed in one of the comprehensive and includes a robust rationale biweekly readiness for comparing alternative sites, including many assessment meetings and different criteria. Outstanding questions for the May 2023 site visit.
future COL discussions include how these various factors were weighted, along with a rationale for eliminating Utah alternative sites and other sites not at INL.
13
19 COLA 9.0 Alternatives Content Regarding the no action alternative, the ER These issues were identified Discussion should address potential beneficial ecological and discussed in one of the and socioeconomic impacts of not constructing biweekly readiness the proposed reactor, including availability of assessment meetings and the site for future uses. the May 2023 site visit.
- Observations resulting from review of draft text were discussed with the applicant during biweekly readiness assessment meetings held between March and June 2023. Most observations resulting from content discussions came primarily from meetings held during the May 2023 site visit on sections that had not been submitted to the NRC staff for review. In some cases, additional observations were discussed during the May 2023 site visit on previously submitted sections. In addition, observations were developed on draft text submitted for review after the May 2023 site visit.
14
Table 6: Phase 3 Readiness Assessment Results Summary (Review dates May 1- June 16, 2023)
Observation Document Section/Subsection Observation Observation Discussion/ Resolution Number Title Source*
1 LWA 2.2 Water Content At the time of the May 2023 site visit, no water These issues were identified Resources Discussion resources sections of the ER were available for and discussed during the May review in the electronic reading room. CFPP staff 2023 site visit.
provided a verbal summary of the water resources affected environment section. Nothing presented gave any cause for concern with CFPPs ability to provide adequate information as part of their LWA application in the water resources area.
2 LWA 2.2 Water Draft Text ER Section 2.2.2.1, Surface Water Use, refers to These issues were identified Resources Review irrigated acreage and consumptive use values and discussed in one of the from 1967. Confirm that these are the most biweekly readiness assessment recent available surface water use values. Suggest meetings.
referring to more recent values if available.
3 LWA 2.2 Water Draft Text ER Section 2.2.1.2.3, Groundwater Flow, refers to These issues were identified Resources Review a water table map developed in 1980. Confirm and discussed in one of the that this is the most recent regional water table biweekly readiness assessment map available. Suggest referring to a more recent meetings.
map if available.
4 LWA 2.2 Water Draft Text ER Tables 2.2-2 and 2.2-3 appear to have captions These issues were identified Resources Review that do not reflect content of the tables). Provide and discussed in one of the corrected captions. A related editorial issue: some biweekly readiness assessment paragraphs throughout the section have meetings.
duplicated sentence fragments at the beginning of paragraphs that should be corrected.
5 LWA 2.2 Water Draft Text ER Tables 2.2-3 and 2.2-4 provide a range of These issues were identified Resources Review values for each water quality analyte entry. and discussed in one of the Provide a definition for what the range means biweekly readiness assessment (e.g., minimum and maximum values measured). meetings.
15
6 LWA 2.2 Water Draft Text LWA ER Table 2.2-4 summarizes the groundwater These issues were identified Resources Review quality at the CFPP site and surrounding areas. and discussed in one of the Table footnote 2 states that water samples for the biweekly readiness assessment CFPP wells were collected between July and meetings.
November 2022 and 15 samples were collected from 10 wells. This indicates that most wells were sampled once. Provide information on any groundwater sampling that has been conducted since November 2022. Provide information on plans for additional sampling to support the baseline groundwater quality characterization for the COL ER.
7 LWA 2.2 Water Draft Text Confirm that the source for ER Figures 2.2-8 and These issues were identified Resources Review 2.2-9 is correctly given in the captions (Reference and discussed in one of the 2.2-46, which is NWIS, does not appear to be biweekly readiness assessment correct). meetings.
8 LWA 2.2 Water Draft Text For ER Figure 2.2-9, label the cross-section bounds These issues were identified Resources Review (A and A) on the figure, define or delete GRRA, and discussed in one of the define Pz and Pzu which are used in the figure, biweekly readiness assessment and indicate what is signified by the dashed meetings.
bounding box on the figure. Suggest including the approximate location of the CFFP site on the cross-section (Fig. 2.2-8) and on Figure 2.2-14, the regional groundwater map.
9 LWA 2.2 Water Draft Text For any figures provided, ensure the resolution is These issues were identified Resources Review high enough to clearly read all text and lines at and discussed in one of the some zoom level (i.e., not blurry when zoomed biweekly readiness assessment in). LWA ER Figure 2.2-10 has poor quality meetings.
resolution 16
10 LWA 2.2 Water Draft Text In ER Section 2.2.1.2.5, Conceptual Groundwater These issues were identified Resources Review Budget, underflow from the Lost River Range is and discussed in one of the discussed and noted to have been assumed to be biweekly readiness assessment zero for the regional groundwater conceptual meetings.
model (Reference 2.2-5 and Figure 2.2-12).
Consider whether the local and regional water table maps shown in Figures 2.2-13 and 2.2-14 are consistent with this assumption, or whether the water table elevations observed at the site provide evidence for nonzero underflow as a source of recharge to the ESRP aquifer northwest of the CFPP site. The regional water table map in Figure 2.2-14 appears to infer recharge from the Lost River Range in the form of the dashed contours.
11 LWA 2.2 Water Draft Text Confirm the status of groundwater withdrawal These issues were identified Resources Review water rights and other required permits, including and discussed in one of the any role designated for the Bureau of Land biweekly readiness assessment Management regarding its interest/authority in meetings.
groundwater withdrawals for the proposed project. (LWA ER 3.3.1.1.4, Temporary Utilities and Services, describes a temporary well located on the CFPP site. LWA ER Section 3.3.6, Water for Building Activities, and LWA ER Table 3.3-1 describe estimated water rates required for project building activities.)
17
12 LWA 2.7 Air Resources Content At the time of the May 2023 site visit, no air These issues were identified Discussion resources sections of the ER were available for and discussed during the May review in the electronic reading room. CFPP staff 2023 site visit. CFPP plans to provided a general description of the leverage NOAA Climatology of meteorological monitoring station that was the Idaho National Laboratory.
established and the monitoring that has occurred.
Details about the tower design, tower boom length or orientation were not provided. CFPP described the use of data from long-term meteorological stations within the vicinity of the CFPP site to compensate for data gaps from the on-site met tower. CFPP should provide data recovery percentage for comparison with the 90 percent criterion from RG 1.23. CFPP is currently missing sections on severe weather.
13 LWA 3.3 Building Draft Text Nothing presented gave any cause for concern These issues were identified Activities Review with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit.
this area.
14 LWA 4.0 Construction Draft Text Nothing presented gave any cause for concern These issues were identified Impacts of LWA Review with CFPPs ability to provide adequate and discussed in one of the Activities information as part of their LWA application in biweekly readiness assessment this area. meetings.
15 LWA 4.1 Land Use Content At the time of the May 2023 site visit, Section 4.1 These issues were identified Discussion was not available for review. Preliminary and discussed during the May discussions did not result in any land use 2023 site visit.
concerns.
16 LWA 4.1 Land Use Draft Text Clarification is needed on how the temporary and These issues were identified Review permanent onsite acreage breakout data and discussed in one of the presented in Table 4.1-3 fits the total onsite land biweekly readiness assessment disturbance footprint of 575 acres. Table 4.1-3 meetings.
could be restructured so that the component areas of disturbance total an area equaling the total area of disturbance.
18
17 LWA 4.1 Land Use Draft Text Table 4.1-7 should align with the description on These issues were identified Review page 4.1-7. Specifically, the table breaks out each and discussed in one of the component, and should present the total biweekly readiness assessment disturbed acreage. Please also indicate if there meetings.
any temporary offsite land disturbances.
18 LWA 4.1 Land Use Draft Text The term "significant was used potentially out of These issues were identified Review context in Section 4.1. Staff needs to understand and discussed in one of the context of the discussion and usage of that term biweekly readiness assessment to produce an accurate EIS writeup of this section. meetings.
19 LWA 4.1 Land Use Draft Text Clarification should be provided on how could These issues were identified Review plant affect the potential extraction of minerals by and discussed in one of the other entities. biweekly readiness assessment meetings.
20 LWA 4.2 Water Resources Content Nothing presented gave any cause for concern These issues were identified Discussion with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit.
this area. (See additional comment from review of Section 2.2 above.)
21 LWA 4.3 Ecological Content Characterization of temporary and permanent These issues were identified Resources Discussion habitat losses, by habitat type, should be and discussed during the May provided. In general, nothing presented gave any 2023 site visit.
cause for concern with CFPPs ability to provide adequate information as part of their LWA application in this area.
22 LWA 4.4 Socioeconomics Content At the time of the May 2023 site visit, Section 4.4 These issues were identified Discussion was not available for review. CFPP presented and discussed during the May some of their impact analysis but noted that they 2023 site visit.
are using an IMPLAN model for the economic impacts of the full construction and operations of CFPP and that the IMPLAN analysis was not ready to share as of the visit. Nothing presented gave any cause for concern with CFPPs ability to provide adequate information as part of their LWA application in this area.
19
23 LWA 4.5 Environmental Content Nothing presented gave any cause for concern These issues were identified Justice Discussion with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit.
this area.
24 LWA 4.6 Historic and Content During the May 2023 site visit, staff from the NRC These issues were identified Cultural Resources Discussion and DOE indicated that efforts should be made to and discussed during the May avoid impacts to archeological sites, cultural 2023 site visit and in resources, and natural resources that may exist subsequent meetings. CFPP will within the direct and indirect APE. evaluate the need to take steps to avoid impacts, include adjusting project plans, if needed.
25 4.6 Historic and Content During the May 2023 site visit, staff from the NRC These issues were identified Cultural Resources Discussion and DOE requested that CFPP coordinate with INL and discussed during the May archeologists to develop an inadvertent discovery 2023 site visit.
plan and monitoring plan that reflect pre-existing commitments to the Shoshone-Bannock Tribes in the CFPP plan.
26 LWA 4.7 Air Resources Content A basis for the impacts to air resources was not These issues were identified Discussion explicitly provided, beyond broad discussion of and discussed during the May comparable construction activities. CFPP should 2023 site visit.
provide more detail regarding the emissions-producing activities included and the resultant impact.
27 LWA 4.8 Non- Content Nothing presented gave any cause for concern These issues were identified Radiological Health Discussion with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit.
this area.
28 LWA 4.9 Radiological Draft Text Section 4.9.1 of the ER notes that after the first Based on the discussions at the Environmental Review module starts operation, the construction workers May 2023 site visit, Monitoring are evaluated under occupational radiation construction is completed once exposure. However, it is not stated that these the installation of the first workers would have the necessary training to be module starts or is considered as radiation workers. completed. All work after that would be by radiation workers.
20
29 LWA 4.9 Radiological Draft Text Further information is needed regarding doses to Based on discussions at the Environmental Review construction workers for the modules under May 2023 site visit, staff Monitoring construction when other modules are operating understand that once a module (based on P.I. No. 3 (Section 4.9.1). is installed and begins operations, all workers must be radiation protection qualified (i.e., radiation worker) 30 LWA 4.10 Non-Rad Content Nothing presented gave any cause for concern These issues were identified Waste Management Discussion with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit.
this area.
31 LWA 4.11 Measures and Content Nothing presented gave any cause for concern These issues were identified Controls to Limit Discussion with CFPPs ability to provide adequate and discussed during the May Adverse Impacts information as part of their LWA application in 2023 site visit.
during Construction this area.
32 LWA 7.1 Past, Present Content CFPP used a 250-mile radius for geographic area These issues were identified and Reasonably Discussion of interest for all resources and $250 million as and discussed during the May Foreseeable Future the lower threshold of projects to include in 2023 site visit and in Projects cumulative analysis; the rationale for these subsequent biweekly readiness assumptions was not well defined and assessment meetings. In the submittal, CFPP plans to provide better rationale for the parameters and the projects included in cumulative analysis.
33 LWA 7.2 Impact Content In the discussion of the approach to the proposed These issues were identified Assessment Discussion cumulative analysis staff indicated that the and discussed during the May cumulative impacts of all stages of the project 2023 site visit and in (preconstruction, LWA, COLA) should be discussed subsequent biweekly readiness along with all past, present, and reasonably assessment meetings. CFPP foreseeable actions. plans to revisit the proposed cumulative analysis to include cumulative impacts of all stages of the project (preconstruction, LWA, COLA) in one table that considers past, present, and reasonably foreseeable future actions.
21
34 LWA 10.1 Impacts of Content Nothing presented gave any cause for concern These issues were identified Proposed Actions Discussion with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit.
this area.
35 LWA 10.2 Unavoidable Content Nothing presented gave any cause for concern These issues were identified Adverse Discussion with CFPPs ability to provide adequate and discussed during the May Environmental information as part of their LWA application in 2023 site visit.
Effects this area.
36 LWA 10.3 Relationship Content Nothing presented gave any cause for concern These issues were identified between Local Discussion with CFPPs ability to provide adequate and discussed during the May Short-Term Use of information as part of their LWA application in 2023 site visit.
Env and Long-Term this area.
Productivity 37 LWA 10.4 Irreversible and Content Nothing presented gave any cause for concern These issues were identified Irretrievable Discussion with CFPPs ability to provide adequate and discussed during the May Commitment of information as part of their LWA application in 2023 site visit.
Resources this area.
38 LWA 10.5 Alternatives to Content Nothing presented gave any cause for concern These issues were identified the Proposed Action Discussion with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit.
this area.
39 LWA 10.6 Benefits and Content Nothing presented gave any cause for concern These issues were identified Costs Discussion with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit.
this area.
40 LWA App A: Consultation Draft Text Nothing presented gave any cause for concern These issues were identified Review with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit and subsequent this area. biweekly readiness assessment meetings.
41 LWA App B: Env Draft Text Nothing presented gave any cause for concern These issues were identified Protection Plan Review with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit and subsequent this area. biweekly readiness assessment meetings.
22
42 LWA Redress Plan Content Nothing presented gave any cause for concern These issues were identified Discussion with CFPPs ability to provide adequate and discussed during the May information as part of their LWA application in 2023 site visit and subsequent this area. biweekly readiness assessment meetings.
- Observations resulting from review of draft text were discussed with the applicant during biweekly readiness assessment meetings held between March and June 2023. Most observations resulting from content discussions came primarily from meetings held during the May 2023 site visit on sections that had not been submitted to the NRC staff for review. In some cases, additional observations were discussed during the May 2023 site visit on previously submitted sections. In addition, observations were developed on draft text submitted for review after the May 2023 site visit.
Italicized text- Section was under development during the readiness assessment and drafts were not provided to the NRC for review. Contents were discussed during and after the May site visit (as noted).
23